Targeted Financial Services is a investment adviser based in Seminole, FL, that holds a 80.4/100 Fidelon TransparencyScore (24th percentile among SEC-registered advisers), with 4 registered advisors. Score based on public SEC and FINRA filings.
Targeted Financial Services
Targeted Financial Services, LLC · CRD #129049
A fee-only investment adviser with a clean regulatory record and fiduciary commitment.
Fidelon Fact Sheet
Targeted Financial Services, LLC is an SEC-registered investment adviser in Seminole, FL. It has 4 registered advisors. It manages $353.4 million across 788 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. 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
8,225th of 10,815
SEC-registered advisers
Bottom 24%
623rd of 799
SEC-registered advisers in FL
Bottom 22%
1st of 1
SEC-registered advisers in Seminole, FL
#1 ranked
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
What you’d pay
Your balance falls in the All accounts band, charged at 0.50%–1.50% on the full amount. The brochure files a range for this band, so the exact rate is set in your agreement.
This fee is negotiable
“TFS, in its sole discretion, may negotiate to charge a lesser management fee based upon certain criteria”
From their Form ADV Part 2A. Most investors never ask.
Not included above
- • Clients incur certain charges imposed by the Financial Institutions and other third parties such as securities brokerage commissions, transaction fees, custodial fees, recharges imposed directly by a mutual fund or ETF in the account, which shall be disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), fees and expenses associated with alternative investments, deferred sales charges, odd-lot differentials, margin costs, reporting fees, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions
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 | 0.50%–1.50% |
Billed quarterly, 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 names research or services received from a custodian or broker (soft dollars) as a conflict, but it does not explain what this arrangement tempts the firm to do, say what the firm is paid for it, or say what it can cost you. Ask what the firm receives from the custodian or broker it uses for you, and whether that costs you anything.Items 10, 11, 12.B and 14
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 your advisory accounts, the more you will pay in fees, so the firm may therefore have an incentive to encourage you to increase the assets in your account or manage them in a way where we charge higher fees.”
“our supervised persons or affiliates can do this in their individual capacities as registered representatives of an unaffiliated broker-dealer”
Source: the firm’s own Form CRS — 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.
70/100
Fair
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.
62/100
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?
- Does it include everything the SEC requires?
- Required sections
- 100/100
- Does it explain how the firm's conflicts affect you?
- Conflicts of interest
- 71/100
- Can you tell what you would pay?
- What you pay
- 69/100
- Is it written in plain English?
- Plain language
- 94/100
This firm's Form CRS averages 84 out of 100. It adds 5.88 points once the firm's filings and record score 90 on their own; they score 80.44 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 Clarity75/100
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?Not found in the brochureItem 5.A
Without a fee schedule you cannot compare this firm with any other.
What to askAsk for the fee schedule in writing, including what you would pay at your account size.
- 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.
TFS, in its sole discretion, may negotiate to charge a lesser management fee based upon certain criteriap. 7
- 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.
Clients generally provide TFS with the authority to directly debit their accounts for payment of the investment advisory fees.p. 7
- 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.
TFS’s annual fee is prorated and charged quarterly, in arrears, based upon the market value of the assets being managed by TFS on the last day of the previous quarter.p. 7
- 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.
TFS’s annual fee is exclusive of, and in addition to brokerage commissions, transaction fees, and other related costs and expenses which are incurred by the client.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.
In the event that there are any prepaid, unearned fees, they will be promptly refunded to the Client.p. 8
Does it explain each conflict of interest and what it could cost you?Brochure Conflict Specificity55/100
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.
The Firm’s recommendation that clients maintain their assets in accounts at Fidelity and Schwab may be based in part on the benefits received and not solely on the nature, cost or quality of custody and brokerage services provided by Fidelity and Schwab, which raises a potential conflict of interest.p. 17
- 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?CoveredStaff Bulletin Q11
Benefits that are not cash, like free services or referrals, still shape advice.
The software and related systems support may benefit TFS, but not its clients directly.p. 15
- 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 its people can earn insurance commissions, does it explain them?
Insurance commissions
An adviser's own license, not the firm's — scored once under Sales Compensation
Some representatives of TFS are licensed insurance agents. From time to time, thye will offer clients advice or products from those activities. Clients should be aware that these services pay a commission and involve a conflict of interestp. 13
Do they earn commissions on products, and do they say so?Brochure Sales Compensation71/100
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 presents a conflict of interest and gives the supervised person an incentive to recommend products based on the compensation received rather than on the client’s needs.p. 8
- 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.
This presents a conflict of interest and gives the supervised person an incentive to recommend products based on the compensation received rather than on the client’s needs.p. 8
- 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?Does not applyItem 5.E.4
If the firm earns a commission and the full advisory fee, you pay twice for one recommendation.
Do they get free research or services from brokers, and does it affect you?Brochure Soft Dollars75/100
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.
Fidelity also makes available to the Firm, at no additional charge, certain research and brokerage services, including research services obtained by Fidelity directly from independent research companies, as selected by TFS (within specified parameters).p. 16
- 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.
The receipt of investment research products and/or services poses a conflict of interest because TFS does not have to produce or pay for the products or services.p. 15
- 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.
The receipt of investment research products and/or services poses a conflict of interest because TFS does not have to produce or pay for the products or services.p. 15
- 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?CoveredItem 12.A.1.c
Paying up for trades to earn the firm a perk comes straight out of your returns.
Clients may pay commissions that are higher than another qualified Financial Institution might charge to affect the same transaction where TFS determines that the commissions are reasonable in relation to the value of the brokerage and research services received.p. 14
- 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
4 advisors
| Advisor | CRD | Score | Grade |
|---|---|---|---|
| James Charles Payne Jr | 2776808 | — | — |
| Jill Linda Gibb | 4784885 | — | — |
| Alan Rubin | 2190957 | — | — |
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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 #129049