Legacy Group is a investment adviser based in Tyler, TX, that holds a 89.5/100 Fidelon TransparencyScore (53rd percentile among state-registered advisers), with 1 registered advisor. Score based on public SEC and FINRA filings.
Legacy Group
Evans, Michael Wayne · CRD #134797
A registered investment adviser with a clean regulatory record.
Fidelon Fact Sheet
Legacy Group is a state-registered investment adviser in Tyler, TX. It has one registered advisor. It manages $89.4 million across 509 client accounts. It charges a yearly percentage of your account that gets smaller as the account grows, and it can also earn commissions when it sells you a product. Its services include financial planning, portfolio management and investment newsletters. Its record shows no customer complaints, regulatory actions or fines.
Peer Context
7,366th of 15,825
state-registered advisers
Top 47%
653rd of 1,355
state-registered advisers in TX
Top 48%
2nd of 3
state-registered advisers in Tyler, TX
Bottom 33%
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
- Charges fixed fees for specific services
- Can earn money selling products alongside advice — the product company pays that, so it never appears on an advisory invoice
What you’d pay
Blended across 1 tiers, from $500,000 - $1,000,000.
This fee is negotiable
“These fees are negotiable and the final fee schedule will be detailed in the Investment Management Agreement.”
From their Form ADV Part 2A. Most investors never ask.
Not included above
- • Portfolio MRI flat fee $300-$600 (negotiable)
- • hourly $200 (negotiable)
- • Schwab/Pershing 6 bp asset-based
- • Free Market Funds total expenses 0.64%-0.85% (Matson 0.49% management)
- • custodian fees for margin, wires, etc.
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 - $500,000 | 1.25% |
| $500,000 - $1,000,000 | 1.00% |
| $1,000,000 - $4,000,000 | 0.79% |
| $4,000,000 and above | 0.59% |
Billed quarterly in advance
Extracted from Form ADV Part 2A brochure
Specializations
Extracted from Form ADV Part 2A brochure
Key Findings
Strengths
- Registered as investment adviser with fiduciary obligation
- Clean regulatory record — no disclosures, arbitrations, or fines
- TransparencyScore in the top 47% of state-registered advisers
Conflict Audit
Our analysis identified 2 potential conflicts of interest 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.
100/100
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.
85/100
Strong
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.
The first $500,000 = 1.25% annually, payable quarterly in advance The next $500,000 = 1.00% annually, payable quarterly in advance The next $3,000,000 = 0.79% annually, payable quarterly in advance The remainder over $4,000,000 = 0.59% annually, payable quarterly in advancep. 6
- 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.
These fees are negotiable and the final fee schedule will be detailed in the Investment Management Agreement.p. 6
- 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.
Fees are paid quarterly in advance by deducting them from each client account.p. 8
- 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.
Fees are paid quarterly in advance by deducting them from each client account.p. 8
- 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 are responsible for the payment of all third-party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.).p. 8
- 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.
Refunds would be paid for clients who were charged in advance for any unused days in the quarter after the termination date.p. 8
Does it explain each conflict of interest and what it could cost you?Brochure Conflict Specificity85/100
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 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.
Schwab Advisor Services also makes available to LEGACY GROUP other products and services that benefit LEGACY GROUP but may not directly benefit its clients’ accounts.p. 19
- 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.
In evaluating whether to recommend or require that clients custody their assets at Schwab, LEGACY GROUP may take into account the availability of some of the foregoing products and services and other arrangements as part of the total mix of factors it considers and not solely the nature, cost or quality of custody and brokerage services provided by Schwab, which may create a potential conflict of interest.p. 19
- 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.
Schwab’s products and services that assist LEGACY GROUP and Matson Money, Inc. in managing and administering clients’ accounts include software and other technology that (i) provide access to client account data (such as trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of fees from its clients’ accounts; and (v) assist with back-office functions, recordkeeping and client reporting.p. 19
- 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.
Schwab Advisor Services also offers other services intended to help LEGACY GROUP and Matson Money, Inc. manage and further develop its business enterprise.p. 19
- 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.
This practice of recommending Charles Schwab & Co. Inc. may potentially cost clients money due to the possibility that best execution for client transactions may be obtained at other custodians or competitors of Charles Schwab & Co. Inc.p. 20
- 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.
Do they earn commissions on products, and do they say so?Brochure Sales CompensationNot applicable
Not applicable: the brochure describes no product-sales commissions
Do they get free research or services from brokers, and does it affect you?Brochure Soft DollarsNot applicable
Not applicable: the brochure describes custodian services only, not research or other benefits received
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
1 advisor
| Advisor | CRD | Score | Grade |
|---|---|---|---|
| Michael Wayne Evans | 1014182 | — | — |
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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 #134797