Peckham, David A is a investment adviser based in Santa Barbara, CA, that holds a 81.0/100 Fidelon TransparencyScore (12th percentile among state-registered advisers), with 1 registered advisor. Score based on public SEC and FINRA filings.
Peckham, David A
Peckham, David Arthur · CRD #235790
A registered investment adviser with a clean regulatory record.
Fidelon Fact Sheet
Peckham, David A is a state-registered investment adviser in Santa Barbara, CA. It has one registered advisor. It manages $6.1 million across 116 client accounts. It charges one yearly percentage of your account, and it can also earn commissions when it sells you a product. Its services include financial planning and portfolio management. Its record shows no customer complaints, regulatory actions or fines.
Peer Context
13,906th of 15,825
state-registered advisers
Bottom 12%
2,140th of 2,392
state-registered advisers in CA
Bottom 11%
28th of 31
state-registered advisers in Santa barbara, CA
Bottom 10%
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
- Can earn money selling products alongside advice — the product company pays that, so it never appears on an advisory invoice
What you’d pay
Your balance falls in the All accounts band, charged at 0.25% on the full amount.
Not included above
- • Clients may pay other fees in connection with advisory services, such as custodian fees for Individual Retirement Accounts and mutual fund expenses for all mutual funds offered by Invesco Distributors, Inc.
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 |
|---|---|
| All accounts | 0.25% |
Billed monthly
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
Things You Should Know
- Its brochure says it receives research or services from brokers, but it does not say the firm benefits by not paying for those things, list what the firm gets from brokers for free, or say whether every client benefits or only some. Ask what the firm would have to pay for those services if it bought them itself.Item 12.A.1
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.
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.
60/100
Weak
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 Clarity90/100
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.
Each point is marked Covered or Not found. When a point is not found, we say what to ask.
- Can you tell what you'd pay?CoveredItem 5.A
Without a fee schedule you cannot compare this firm with any other.
The Maximum Annual fees shall not exceed 0.25% per year of the average account balance.p. 3
- Does it say whether the fee can be negotiated?Not found in the brochureItem 5.A
If fees are negotiable, other clients may be paying less than you for the same service.
What to askAsk whether the fee is negotiable, and what other clients at your account size pay.
- 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.
Investment management fees are calculated by Invesco Distributors, Inc. and paid monthly.p. 3
- 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.
Investment management fees are calculated by Invesco Distributors, Inc. and paid monthly.p. 3
- 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 may pay other fees in connection with advisory services, such as custodian fees for Individual Retirement Accounts and mutual fund expenses for all mutual funds offered by Invesco Distributors, Inc.p. 3
- 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.
Therefore, a refund of a pre-paid advisory fee is not applicable.p. 3
Does it explain each conflict of interest and what it could cost you?Brochure Conflict Specificity70/100
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.
The brochure answers every one of these.
The brochure states the firm has no conflicts of this kind, and its Form ADV Part 1 agrees.
- Does the brochure say the firm has no conflicts of this kind?CoveredItems 10/11/12.B/14 + Part 1A
A clear statement that the firm earns nothing from commissions, perks or referrals is the simplest answer there is.
Commissions from the sale of insurance products has no bearing on investment advisory fees, since Invesco Funds Group does not offer any insurance products.p. 5
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 Dollars29/100
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?Not found in the brochureItem 12.A.1.e
Research, software and data paid for by your trades are a cost you never see.
What to askAsk what research, tools or services the firm receives from brokers or custodians at no charge.
- Does it say the firm benefits by not paying for those things?Not found in the brochureItem 12.A.1.a
A perk the firm would otherwise buy is money in the firm's pocket, paid with your trades.
What to askAsk what the firm would have to pay for those services if it bought them itself.
- 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.
There is an incentive to the adviser as a result to recommend a given broker-dealer that provides soft-dollar benefits such as research or other products or services.p. 6
- 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
1 advisor
| Advisor | CRD | Score | Grade |
|---|---|---|---|
| David Arthur Peckham | 1551271 | — | — |
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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 #235790