Pushkin Advisory Group is a investment adviser based in Skaneateles, NY, that holds a 88.8/100 Fidelon TransparencyScore (48th percentile among state-registered advisers), with 1 registered advisor. Score based on public SEC and FINRA filings.
Pushkin Advisory Group
Pushkin Advisory Group, LLC · CRD #226674
A fee-only investment adviser with a clean regulatory record and fiduciary commitment.
Fidelon Fact Sheet
Pushkin Advisory Group, LLC is a state-registered investment adviser in Skaneateles, NY. It has one registered advisor. It manages $51 million across 189 client accounts. It charges a percentage of the money it manages for you, and it does not report earning commissions. Its services include financial planning. It reports that it can hold or access client money, which the SEC requires firms to disclose. Its record shows no customer complaints, regulatory actions or fines.
Peer Context
8,160th of 15,825
state-registered advisers
Bottom 48%
408th of 709
state-registered advisers in NY
Bottom 42%
3rd of 3
state-registered advisers in Skaneateles, NY
Bottom 1%
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
Blended across 1 tiers, from $0 - $1,000,000.
This fee is negotiable
“The fees shown above are negotiable under certain circumstances at our discretion.”
From their Form ADV Part 2A. Most investors never ask.
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 | 0.75% |
| $1,000,000 - $3,000,000 | 0.65% |
| $3,000,000 and above | 0.50% |
Billed monthly 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
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.
84/100
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.
70/100
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.
On Assets Under Management from $0 to $1M – 0.75% to 1.0% per annum On Assets Under Management from $1M to $3M – 0.65% to 0.75% per annum On Assets Under Management above $3M – 0.5% to 0.65% per annump. 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.
The fees shown above are negotiable under certain circumstances at our discretion.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.
The fee is directly deducted from the client’s account according to the written authorization in the Investment Advisory Agreement; however, under certain rare circumstances, clients may elect to be billed directly for fees.p. 6
- 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 Services are billed monthly, in ARREARS, meaning that we invoice you at the end of each monthly billing period.p. 6
- 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.
Custodians charge transaction fees on purchases or sales of individual stocks, exchange- traded funds and certain mutual funds.p. 7
- 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.
Any unused portion of fees collected in advance will be refunded within 30 days.p. 7
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.
PAG does not have any arrangements or commitments to use research, research-related products and other services obtained from broker-dealers and/or custodians on a soft dollar basis.p. 11
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 no research or services from brokers
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 |
|---|---|---|---|
| Andrew Christopher Russo | 5806389 | — | — |
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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 #226674