Quartz Partners Investment Management is a investment adviser based in Saratoga Springs, NY, that holds a 84.7/100 Fidelon TransparencyScore (44th percentile among SEC-registered advisers), with 29 registered advisors. Score based on public SEC and FINRA filings.
Quartz Partners Investment Management
Quartz Partners · CRD #174327
A fee-only investment adviser with a clean regulatory record and fiduciary commitment.
Fidelon Fact Sheet
Quartz Partners Investment Management is an SEC-registered investment adviser in Saratoga Springs, NY. It used to be called Quartz Partners Retirement Plan Services and Cameron Harrod Wealth Management. Its 29 registered advisors typically serve pension and profit-sharing plans, institutional investors and corporations. It manages $611.9 million across 1,277 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, portfolio management, educational seminars and market-timing advice. Its record shows no customer complaints, regulatory actions or fines.
Peer Context
6,045th of 10,815
SEC-registered advisers
Bottom 44%
601st of 1,070
SEC-registered advisers in NY
Bottom 44%
7th of 14
SEC-registered advisers in Saratoga springs, NY
Top 50%
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
- Does not earn commissions on product sales
Specializations
Extracted from Form ADV Part 2A brochure
Who They Typically Serve
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 names payments received for referring clients elsewhere or an affiliated broker-dealer as conflicts, but it does not name this conflict where the SEC requires, explain what this arrangement tempts the firm to do, or say what the firm is paid for it. Ask whether the firm is paid when it sends you to another company, and by whom.Items 10, 11, 12.B and 14
- Its brochure says it receives research or services from brokers, but it does not say those perks can shape which broker it picks for you or whether every client benefits or only some. Ask how the firm chooses the broker for your trades and whether perks play any part.Item 12.A.1
Conflict Audit
Zero material conflicts identified in regulatory filings.
Source: Form ADV Part 1, Items 6-8; Part 2A, Items 10-14
What this firm says about how it gets paid
“The more assets there are in a retail investor’s advisory account, the more a retail investor will pay in fees, and this creates an incentive for us to encourage you to increase the assets in your account.”
“Many financial professionals associated with our firm as an investment adviser representative are also registered representatives of EP and many are also licensed insurance agents.”
Source: the firm’s own Form CRS, filed 2026-06-08 — quoted directly
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.
91/100
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.
53/100
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?
- Does it include everything the SEC requires?
- Required sections
- 79/100
- Does it explain how the firm's conflicts affect you?
- Conflicts of interest
What to askAsk the advisor to name every way the firm gets paid besides your fee, and how each one can affect their advice.
- 54/100
- Can you tell what you would pay?
- What you pay
- 73/100
- Is it written in plain English?
- Plain language
- 86/100
This firm's Form CRS averages 73 out of 100. It adds 3.25 points once the firm's filings and record score 90 on their own; they score 84.72 today.
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 specific advisory fee, any breakpoints and schedule (e.g., advance or arrears, monthly or quarterly) for the advisory services is outlined and agreed upon in either our client agreement specific to the advisory services the client has selectedp. 12
- 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.
Our fees are typically negotiable, based upon but not limited to (i) Clients with multiple accounts, (ii) size of the account, (iii) a prior or existing relationship, (iv) a Client’s particular needs or financial characteristics.p. 12
- 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 stated, clients agree in writing to have our fees deducted from client Accounts by the Custodian based on the specific advisory fee schedule contained within the client agreementp. 14
- 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.
The specific advisory fee, any breakpoints and schedule (e.g., advance or arrears, monthly or quarterly) for the advisory services is outlined and agreed upon in either our client agreement specific to the advisory services the client has selectedp. 12
- 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.
In addition to our fees described above, Clients may be responsible for additional expenses from entities which are unaffiliated with our Firm.p. 14
- 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.
Advisory fees for Accounts opened or terminated during a billing period that are paid in advance will be refunded pro rata based on the number of days the Account was managed during the billing period.p. 15
Does it explain each conflict of interest and what it could cost you?Brochure Conflict Specificity46/100
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 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.
Our Firm is affiliated through common control with Etico Partners, LLC an SEC registered broker-dealer and member of FINRA.p. 21
- Does it explain what this arrangement tempts the firm to do?Not found in the brochureStaff Bulletin Q11
You can only judge advice when you know which way it is being pulled.
What to askAsk what this arrangement gives the firm a reason to recommend, and how often that happens.
- 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?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 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.
The fact that we receive these benefits from these qualified custodians is an incentive for us to recommend the use of these qualified custodians rather than making such decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions.p. 24
- 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.
The fact that we receive these benefits from these qualified custodians is an incentive for us to recommend the use of these qualified custodians rather than making such decision based exclusively on your interestp. 24
- 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?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.
The availability of these services from these qualified custodians benefits us because we do not have to produce or purchase them.p. 24
- 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.
We may establish written Solicitor or Promoter agreements to pay a portion of our advisory fee for referring or promoting Clients to our Firm.p. 27
- 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 type of arrangement with a Financial Intermediary, Financial Professional or Referring Party may create an incentive for the Referring Party to refer Clients to our Firm rather than another Financial Intermediary, based on the compensation the Referring Party receivesp. 27
- 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?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.
If the firm is paid for referring clients elsewhere, does it explain those payments?
Payments received for referring clients elsewhere
- Does the brochure name this conflict where the SEC requires?Not found in the brochureItems 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.
What to askAsk the advisor to walk you through every way the firm gets paid besides your fee.
- Does it explain what this arrangement tempts the firm to do?Not found in the brochureStaff Bulletin Q11
You can only judge advice when you know which way it is being pulled.
What to askAsk what this arrangement gives the firm a reason to recommend, and how often that happens.
- 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?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 the firm is paid when it sends you to another company, and by whom.
Do they earn commissions on products, and do they say so?Brochure Sales Compensation75/100
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.
There is an inherent conflict of interests between registered investment advisers and brokerage firms, due to their respective pricing models: A broker, to earn commissions, would want to affect as many trades as possible.p. 21
- Does it say commissions can shape what they recommend?CoveredItem 5.E.1
Naming the pull is the first step to controlling it; silence leaves it working on you.
Thus, there is a conflict of interest caused by the fee structures affects dual-registered representatives (meaning personnel who are both registered representatives and investment adviser representatives).p. 21
- 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?CoveredItem 5.E.4
If the firm earns a commission and the full advisory fee, you pay twice for one recommendation.
Our Firm does not reduce its advisory fees to offset commissions and brokerage compensation.p. 21
Do they get free research or services from brokers, and does it affect you?Brochure Soft Dollars53/100
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.
However, through our relationship with various Custodians, we receive research, products, discounts, and certain other services.p. 25
- 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.
Although these arrangements may not benefit Clients individually, we benefit by not having to source or pay for these products or services that benefit our clients as a whole.p. 25
- Does it say those perks can shape which broker it picks for you?Not found in the brochureItem 12.A.1.b
Your trades should go where you get the best deal, not where the firm gets the best perks.
What to askAsk how the firm chooses the broker for your trades and whether perks play any part.
- Does it say whether those perks stay within what the law allows?CoveredItem 12.A.1.e note
The law allows research paid for with client trades only within limits; outside them, it is your money.
We do not charge commission markups and have no formal soft-dollar arrangements in which fees generated from trading commissions are used to pay for third party services.p. 25
- 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
29 advisors
| Advisor | CRD | Score | Grade |
|---|---|---|---|
| Lambert Cadwalader Bunker | 2640621 | — | — |
| Stephen Howard Lulla | 1365623 | — | — |
| Mark Joseph Landau | 5072160 | — | — |
| Kyle Patrick Webber | 5093059 | — | — |
| Joseph William Arena | 4997368 | — | — |
| David Joseph Stock | 5189740 | — | — |
| Charles Thomas Howard | 5493021 | — | — |
| Andrew Charles Howard | 5583741 | — | — |
| Pierre Duchmann | 8026727 | — | — |
| Jonathan Hoenig | 8080318 | — | — |
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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 #174327