Bonsai Advisors is a investment adviser based in Boulder, CO, that holds a 89.4/100 Fidelon TransparencyScore (52nd percentile among state-registered advisers), with 3 registered advisors. Score based on public SEC and FINRA filings.
Bonsai Advisors
Bonsai Advisors LLC · CRD #323938
A fee-only investment adviser with a clean regulatory record and fiduciary commitment.
Fidelon Fact Sheet
Bonsai Advisors LLC is a state-registered investment adviser in Boulder, CO. It used to be called Family Office Financial Planning INC. It has 3 registered advisors. It manages $21.1 million across 94 client accounts. It charges a yearly percentage of your account that gets smaller as the account grows, and it does not report earning commissions. Its services include financial planning and portfolio management. Its record shows no customer complaints, regulatory actions or fines.
Peer Context
7,526th of 15,825
state-registered advisers
Top 48%
277th of 519
state-registered advisers in CO
Bottom 47%
18th of 28
state-registered advisers in Boulder, CO
Bottom 36%
How This Firm Works
Registration & Standard of Care
Investment Adviser — this firm is a registered investment adviser, held to a fiduciary standard — legally required to act in clients' best interests.
How This Firm Gets Paid
- Charges a percentage of assets under management
- Does not earn commissions on product sales
What you’d pay
Your balance falls in the $0 - $1,000,000 band, charged at 1.25% on the full amount.
Above $2M the rate drops to 0.75% — $10,000 less per year.
This fee is negotiable
“The annual fees listed are negotiable at our discretion.”
From their Form ADV Part 2A. Most investors never ask.
Not included above
- • Platform Fee (minimum monthly $12.50 per account)
- • TPMM Fees
- • custody fees, transaction fees, administrative fees, brokerage commissions, trading costs
- • mutual fund/ETF underlying expenses
Estimated from the firm’s Form ADV Part 2A brochure — not a quote. Actual fees are set in your agreement and may differ. Costs charged by others (custodians, fund managers) are not included.
What This Firm Charges
| Account Size | Annual Fee |
|---|---|
| $0 - $1,000,000 | 1.25% |
| $1,000,000 - $1,999,999 | 1.00% |
| $2,000,000 - $2,999,999 | 0.75% |
| $3,000,000 and above | 0.50% |
Billed monthly, based on the average daily balance of the prior month, paid in arrears
Extracted from Form ADV Part 2A brochure
Specializations
Extracted from Form ADV Part 2A brochure
Key Findings
Strengths
- Fee-only compensation — no commission income reported
- Registered as investment adviser with fiduciary obligation
- No broker-dealer registration — advisory services only
- Clean regulatory record — no disclosures, arbitrations, or fines
- Transparent fee structure — charges advisory fees, no commissions
Things You Should Know
- Its brochure says its people can earn commissions on products, but it does not say you can buy the same products elsewhere, commissions can shape what they recommend, or whether commissions lower your advisory fee. Ask whether you could buy any recommended product through another broker or insurer.Item 5.E
Conflict Audit
Zero material conflicts identified in regulatory filings.
Source: Form ADV Part 1, Items 6-8; Part 2A, Items 10-14
Regulatory Track Record
0
Disclosures
Clean record — no disclosures found
$0
Total Fines
Clean record — no fines found
Regulatory Events
TransparencyScore Dimensions
Disclosure Record
Customer complaints, arbitrations, and fines. Frequency and recency matter.
100/100
Strong
Avg for investment adviser firms: 82.6 | Top 10%: 99.5
Filing Quality
How clearly the firm describes services, fees, and investment approach in regulatory filings.
92/100
Strong
Avg for investment adviser firms: 84.1 | Top 10%: 100
Conflict Disclosure
How openly the firm explains who pays it and what it's paid to sell. The conflict isn't the problem — hiding it is.
68/100
Fair
Avg for investment adviser firms: 54 | Top 10%: 67
Enforcement History
Self-reported legal and disciplinary history from Form ADV Item 11.
100/100
Strong
Avg for investment adviser firms: 99.7 | Top 10%: 100
Their two-page relationship summary
The SEC requires every SEC-registered investment adviser to hand you this summary, called a Form CRS, and says what it must cover. We checked this firm's against that list. What is a Form CRS?
Not required
This firm is not required to file a Form CRS.
Without a Form CRS, the score above cannot go over 90. A firm that gives us one is scored on the same yardstick and can earn up to 10 more points.
What their brochure tells you
The firm must give you this brochure, Form ADV Part 2A, before you sign. We read it against the SEC's own instructions, item by item. Quotes are the firm's own words; page numbers refer to the filed brochure. What is in a brochure?
Can you tell what you'd pay and when?Brochure Fee Clarity100/100
The SEC asks every brochure to spell out the fee schedule, whether fees can be negotiated, how and when you are billed, the other costs you pay, and refunds.
The brochure answers every one of these.
- Can you tell what you'd pay?CoveredItem 5.A
Without a fee schedule you cannot compare this firm with any other.
Assets Under Management Standard Annual Fee Under $1,000,000 1.25% $1,000,000 - $1,999,999 1.00% $2,000,000 - $2,999,999 0.75% $3,000,000 Plus 0.50%p. 5
- Does it say whether the fee can be negotiated?CoveredItem 5.A
If fees are negotiable, other clients may be paying less than you for the same service.
The annual fees listed are negotiable at our discretion.p. 5
- Does it say whether the fee comes out of your account or gets billed?CoveredItem 5.B
A fee taken straight from your account is easy to stop noticing.
Unless otherwise agreed upon in a client investment agreement, Bonsai’s management fee shall be debited from the client’s account in accordance with the custody exemptionp. 5
- Does it say how often you're charged?CoveredItem 5.B
Monthly, quarterly, in advance or in arrears changes what you owe when you leave.
Bonsai’s annual investment management fee will be paid monthly, based on the average daily balance of the prior month.p. 5
- Does it list the other costs you pay, like fund and custodian fees?CoveredItem 5.C
The advisory fee is rarely the whole bill; fund, trading and custody costs come on top.
Clients of Bonsai may incur additional expenses in addition to Bonsai’s management fee, including but not limited to custody fees, transaction fees, and administrative fees.p. 6
- Does it say how you get money back if you leave mid-period?CoveredItem 5.D
If you pay in advance and leave early, the refund rule decides what you get back.
Fees will be prorated for an account that is terminated during a billing period based on the number of days the account was actively managed through the termination date.p. 8
Does it explain each conflict of interest and what it could cost you?Brochure Conflict Specificity76/100
The SEC asks the brochure to name each way the firm gets paid besides your fee, what that tempts the firm to do, and what it can cost you.
Each point is marked Covered or Not found. When a point is not found, we say what to ask.
If it has an affiliated insurance agency, does it explain what that means for you?
An affiliated insurance agency
- Does the brochure name this conflict where the SEC requires?CoveredItems 10/11/12.B/14
A conflict named in the right place is one the firm has thought about; one buried elsewhere is easy to miss.
Bonsai Advisors LLC is under common control with Bonsai LLC, a Colorado insurance agency which deals in insurance products including securities.p. 10
- Does it explain what this arrangement tempts the firm to do?CoveredStaff Bulletin Q11
You can only judge advice when you know which way it is being pulled.
Clients of Bonsai Advisors LLC should be aware that this relationship inherently presents a conflict of interest, as representatives of Bonsai Advisors LLC are incentivized to recommend services of an entity under common ownership.p. 10
- Does it describe what the arrangement actually is?CoveredStaff Bulletin Q11
A conflict described in one vague sentence tells you it exists but not how it works.
Bonsai Advisors LLC may recommend services of Bonsai LLC to its clients and vice versa.p. 10
- Does it say what the firm is paid for it?Not found in the brochureStaff Bulletin Q11
The size of the payment tells you how strong the pull is.
What to askAsk how much the firm or its people receive from this arrangement in a typical year.
- Does it say how the firm comes out ahead?Not found in the brochureStaff Bulletin Q11
Benefits that are not cash, like free services or referrals, still shape advice.
What to askAsk what the firm gains from this arrangement beyond fees.
- Does it say what it can cost you?Not found in the brochureStaff Bulletin Q11
Every conflict has a price; the question is whether the brochure puts it in your hands.
What to askAsk what this arrangement can cost you, in fees, returns or choices you do not get.
- Does it say how the firm keeps this conflict in check?Not assessed yetItems 10.C-D, 11.B-D, 14.A
A conflict with no control on it is left to the advisor's goodwill.
What to askAsk whether insurance recommended to you is sold by a company tied to the firm, and who earns what.
If it uses an affiliated broker-dealer, does it explain what that means for you?
An affiliated broker-dealer
- Does the brochure name this conflict where the SEC requires?CoveredItems 10/11/12.B/14
A conflict named in the right place is one the firm has thought about; one buried elsewhere is easy to miss.
Certain investment adviser representatives of Bonsai Advisors LLC are registered representatives of Simplicity (formerly The Leaders Group, Inc.), an unaffiliated broker-dealer registered with the Financial Industry Regulatory Authority (“FINRA”).p. 10
- Does it explain what this arrangement tempts the firm to do?CoveredStaff Bulletin Q11
You can only judge advice when you know which way it is being pulled.
This arrangement creates a conflict of interest because Bonsai’s representatives who are registered with Simplicity have an incentive to recommend securities transactions or products through Simplicity for which they may receive additional compensation.p. 10
- Does it describe what the arrangement actually is?Not found in the brochureStaff Bulletin Q11
A conflict described in one vague sentence tells you it exists but not how it works.
What to askAsk the advisor to explain this arrangement in plain terms, including who pays whom.
- Does it say what the firm is paid for it?CoveredStaff Bulletin Q11
The size of the payment tells you how strong the pull is.
As registered representatives of Simplicity, these individuals may spend a portion of their time on broker-dealer activities and may receive commissions, trails, 12b-1 fees, or other compensation in connection with securities transactions effected through Simplicity.p. 10
- Does it say how the firm comes out ahead?Not found in the brochureStaff Bulletin Q11
Benefits that are not cash, like free services or referrals, still shape advice.
What to askAsk what the firm gains from this arrangement beyond fees.
- Does it say what it can cost you?CoveredStaff Bulletin Q11
Every conflict has a price; the question is whether the brochure puts it in your hands.
Clients should understand that transaction charges, commissions, or other costs associated with transactions effected through Simplicity may be higher or lower than those available through other broker-dealers.p. 10
- Does it say how the firm keeps this conflict in check?Not assessed yetItems 10.C-D, 11.B-D, 14.A
A conflict with no control on it is left to the advisor's goodwill.
What to askAsk whether your trades or products go through a company the firm owns or is tied to, and what that costs.
If the firm gets research or services from a custodian or broker, does it explain them?
Research or services received from a custodian or broker (soft dollars)
- Does the brochure name this conflict where the SEC requires?CoveredItems 10/11/12.B/14
A conflict named in the right place is one the firm has thought about; one buried elsewhere is easy to miss.
Bonsai receives various support services from Schwab. Some of these services benefit Bonsai but do not directly benefit the client or the client's account.p. 12
- Does it explain what this arrangement tempts the firm to do?CoveredStaff Bulletin Q11
You can only judge advice when you know which way it is being pulled.
This creates a conflict of interest, but we ensure this benefit does not compromise our commitment to act in our clients' best interests.p. 12
- Does it describe what the arrangement actually is?CoveredStaff Bulletin Q11
A conflict described in one vague sentence tells you it exists but not how it works.
These include investment research, access to client account data, trade execution facilitation, market data provision, fee payment facilitation, back-office functions, recordkeeping, and client reporting assistance.p. 12
- Does it say what the firm is paid for it?Not found in the brochureStaff Bulletin Q11
The size of the payment tells you how strong the pull is.
What to askAsk how much the firm or its people receive from this arrangement in a typical year.
- Does it say how the firm comes out ahead?CoveredStaff Bulletin Q11
Benefits that are not cash, like free services or referrals, still shape advice.
This availability of services from Schwab benefits Bonsai because we do not have to produce or purchase them.p. 12
- Does it say what it can cost you?Not found in the brochureStaff Bulletin Q11
Every conflict has a price; the question is whether the brochure puts it in your hands.
What to askAsk what this arrangement can cost you, in fees, returns or choices you do not get.
- Does it say how the firm keeps this conflict in check?Not assessed yetItems 10.C-D, 11.B-D, 14.A
A conflict with no control on it is left to the advisor's goodwill.
What to askAsk what the firm receives from the custodian or broker it uses for you, and whether that costs you anything.
If the firm pays people who refer clients, does it explain those payments?
Payments to people who refer clients to the firm
- Does the brochure name this conflict where the SEC requires?CoveredItems 10/11/12.B/14
A conflict named in the right place is one the firm has thought about; one buried elsewhere is easy to miss.
Bonsai Advisors, LLC may compensate unaffiliated professionals or entities (“Promoters”) for referring clients to the Firm.p. 13
- Does it explain what this arrangement tempts the firm to do?CoveredStaff Bulletin Q11
You can only judge advice when you know which way it is being pulled.
This arrangement creates a material conflict of interest because Promoters have a financial incentive to refer clients to Bonsai.p. 13
- Does it describe what the arrangement actually is?CoveredStaff Bulletin Q11
A conflict described in one vague sentence tells you it exists but not how it works.
Promoters are paid in cash when a referred prospect becomes an advisory client, generally equal to 20% of the advisory fee Bonsai receives from the referred client for up to three years after the client’s account is opened.p. 13
- Does it say what the firm is paid for it?Not found in the brochureStaff Bulletin Q11
The size of the payment tells you how strong the pull is.
What to askAsk how much the firm or its people receive from this arrangement in a typical year.
- Does it say how the firm comes out ahead?Not found in the brochureStaff Bulletin Q11
Benefits that are not cash, like free services or referrals, still shape advice.
What to askAsk what the firm gains from this arrangement beyond fees.
- Does it say what it can cost you?Not found in the brochureStaff Bulletin Q11
Every conflict has a price; the question is whether the brochure puts it in your hands.
What to askAsk what this arrangement can cost you, in fees, returns or choices you do not get.
- Does it say how the firm keeps this conflict in check?Not assessed yetItems 10.C-D, 11.B-D, 14.A
A conflict with no control on it is left to the advisor's goodwill.
What to askAsk whether anyone was paid to refer you to the firm, and whether that affects what you pay.
Do they earn commissions on products, and do they say so?Brochure Sales Compensation40/100
When a firm or its people sell products for a commission, the SEC asks the brochure to say so, name the pull, and tell you whether you could buy elsewhere.
Each point is marked Covered or Not found. When a point is not found, we say what to ask.
- Does it say that earning commissions is a conflict of interest?CoveredItem 5.E.1
A firm paid to sell a product has a reason to recommend it that has nothing to do with you.
This arrangement creates a conflict of interest because Bonsai’s representatives who are registered with Simplicity have an incentive to recommend securities transactions or products through Simplicity for which they may receive additional compensation.p. 10
- Does it say commissions can shape what they recommend?Not found in the brochureItem 5.E.1
Naming the pull is the first step to controlling it; silence leaves it working on you.
What to askAsk how the firm keeps commissions from steering the advice you get.
- Does it say you can buy the same products elsewhere?Not found in the brochureItem 5.E.2
You may be able to buy the same product for less somewhere else.
What to askAsk whether you could buy any recommended product through another broker or insurer.
- Does it say whether commissions lower your advisory fee?Not found in the brochureItem 5.E.4
If the firm earns a commission and the full advisory fee, you pay twice for one recommendation.
What to askAsk whether any commission the firm earns is credited against your advisory fee.
Do they get free research or services from brokers, and does it affect you?Brochure Soft Dollars71/100
When brokers give the firm research or services in return for your trades, the SEC asks the brochure to say what the firm gets and what it may cost you.
Each point is marked Covered or Not found. When a point is not found, we say what to ask.
- Does it list what the firm gets from brokers for free?CoveredItem 12.A.1.e
Research, software and data paid for by your trades are a cost you never see.
These include investment research, access to client account data, trade execution facilitation, market data provision, fee payment facilitation, back-office functions, recordkeeping, and client reporting assistance.p. 12
- Does it say the firm benefits by not paying for those things?CoveredItem 12.A.1.a
A perk the firm would otherwise buy is money in the firm's pocket, paid with your trades.
This availability of services from Schwab benefits Bonsai because we do not have to produce or purchase them.p. 12
- Does it say those perks can shape which broker it picks for you?CoveredItem 12.A.1.b
Your trades should go where you get the best deal, not where the firm gets the best perks.
This creates a conflict of interest, but we ensure this benefit does not compromise our commitment to act in our clients' best interests.p. 12
- Does it say whether those perks stay within what the law allows?Not found in the brochureItem 12.A.1.e note
The law allows research paid for with client trades only within limits; outside them, it is your money.
What to askAsk whether everything the firm receives from brokers is research the law lets it take in return for your trades.
- Does it say whether you pay more in trading costs because of those perks?Does not applyItem 12.A.1.c
Paying up for trades to earn the firm a perk comes straight out of your returns.
- Does it say whether every client benefits or only some?Not found in the brochureItem 12.A.1.d
Your trades may be paying for research that helps other clients' accounts, not yours.
What to askAsk whether the research your trades help pay for is used for your account.
A point not found is not a finding against the firm; many points apply only when the firm has that arrangement, and state-registered firms file the same brochure form.
Next Steps
Advisor Roster
3 advisors
| Advisor | CRD | Score | Grade |
|---|---|---|---|
| Roberto Nmn Dechellis | 1979472 | — | — |
| Michele Ayres Osterberg | 2986046 | — | — |
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Frequently Asked Questions
What does the TransparencyScore measure?
The TransparencyScore measures how clearly and completely an advisor or firm discloses important information in their regulatory filings — things like fees, conflicts of interest, disciplinary history, and business practices. A higher score means better disclosure quality, not better investment performance.
Where does this data come from?
All data comes from public regulatory filings: SEC Form ADV (Parts 1, 2, and 3), FINRA BrokerCheck, and the SEC's Investment Adviser Public Disclosure (IAPD) database. These are official filings that firms and advisors are legally required to submit.
Does a low score mean they're a bad advisor?
Not necessarily. A low score means the firm's public filings are less transparent — they may use vague language about fees, skip details about conflicts, or have a more complex regulatory history. Some excellent advisors work at firms with poor disclosure practices. The score measures the filing, not the person.
How often is this data updated?
Fidelon refreshes data from SEC and FINRA sources on a regular schedule. Form ADV filings are updated annually by firms (with amendments throughout the year), and BrokerCheck data is updated as events are reported. Scores are recalculated after each data refresh.
Can an advisor or firm improve their score?
Yes. Scores are based on what's in public filings. A firm that rewrites its ADV brochure in clearer language, discloses conflicts more specifically, or resolves outstanding regulatory issues will see its score improve at the next refresh. The incentive structure is intentional.
Data Sources
Scores are generated using Fidelon's published scoring methodology and reflect the quality of public disclosures, not the quality of investment advice. A firm that improves its disclosures will see its score improve. Fidelon does not provide investment advice.
Verify on SEC IAPD
Last scored: · Score version: 3.15 · CRD #323938