Important Disclosures - The Swarthmore Group

IMPORTANT DISCLOSURE INFORMATION

The Swarthmore Group, Inc. (“Company”) is an SEC registered investment adviser located in Philadelphia, Pennsylvania. Company may only transact business in those states in which it is registered, or qualifies for an exemption or exclusion from registration requirements. Company’s web site is limited to the dissemination of general information pertaining to its advisory services, together with access to additional investment-related information, publications, and links. Accordingly, the publication of Company’s web site on the Internet should not be construed by any consumer and/or prospective client as Company’s solicitation to effect, or attempt to effect transactions in securities, or the rendering of personalized investment advice for compensation, over the Internet. Any subsequent, direct communication by Company with a prospective client shall be conducted by a representative that either is registered or qualifies for an exemption or exclusion from registration in the state where the prospective client resides. A copy of Company’s current written disclosure Brochure discussing Company’s business operations, services, and fees is available from Company upon written request. Company does not make any representations or warranties as to the accuracy, timeliness, suitability, completeness, or relevance of any information prepared by any unaffiliated third party, whether linked to Company web site or incorporated herein, and takes no responsibility therefore. All such information is provided solely for convenience purposes only and all users thereof should be guided accordingly.

Please remember that different types of investments involve varying degrees of risk, and there can be no assurance that the future performance of any specific investment or investment strategy (including those undertaken or recommended by Company), will be profitable or equal any historical performance level(s).

Certain portions of Company’s web site (i.e. newsletters, articles, commentaries, etc.) may contain a discussion of, and/or provide access to, Company (and those of other investment and non-investment professionals) positions and/or recommendations as of a specific prior date. Due to various factors, including changing market conditions, such discussion may no longer be reflective of current position(s) and/or recommendation(s). Moreover, no client or prospective client should assume that any such discussion serves as the receipt of, or a substitute for, personalized advice from Company, or from any other investment professional. Company is neither an attorney nor an accountant, and no portion of the web site content should be interpreted as legal, accounting or tax advice.

Please Note: Limitations: Neither rankings and/or recognitions by unaffiliated rating services, publications, media, or other organizations, nor the achievement of any designation, certification, or license should be construed by a client or prospective client as a guarantee that he/she will experience a certain level of results if the Company is engaged, or continues to be engaged, to provide investment advisory services. Rankings published by magazines, and others, generally base their selections exclusively on information prepared and/or submitted by the recognized adviser. Rankings are generally limited to participating advisers (see link as to participation data/criteria, to the extent applicable). Unless expressly indicated to the contrary, the Company did not pay a fee to be included on any such ranking. No ranking or recognition should be construed as a current or past endorsement of the Company by any of its clients. ANY QUESTIONS: The Company’s Chief Compliance Officer remains available to address any questions regarding rankings and/or recognitions, including the criteria used for any reflected ranking.

PRIVACY AND DATA PROTECTION POLICY

The Swarthmore Group is committed to protecting the confidentiality and security of your information. As required by law, this notice has been provided to you to describe how we maintain the information we gather from and about you and the situations under which we may need to share it.

Q: What type of information does The Swarthmore Group collect and how do we use it?

A: As an investment advisor, we obtain information about you upon the application for our financial products and services, and as we perform our duties as an investment advisor.

We limit the collection and use of information within our firm to only those individuals associated or employed with us that must have information to provide financial services to you. Such services include establishing and maintaining your accounts, processing transactions, complying with legal and regulatory requirements, and other services described in our Form ADV.

Q: How does The Swarthmore Group share this information?

A: We do not sell, rent or otherwise disclose information obtained in the course of our practice without your consent except as required or permitted under law. Permitted disclosures include, for instance, providing information to unrelated third parties who need to know such information in order to assist us in providing services to you. Unrelated third parties may include broker/dealers, insurance companies, and the custodian with which your assets are held. In such situations, we require these third parties to treat your private information with the same degree of confidentiality as we do.

Q: How does The Swarthmore Group safeguard your information?

A: The Swarthmore Group protects your information from vulnerability and unauthorized use by restricting access to your personal information to those employees that require the information to provide you with products and services. These employees may access information only when there is an acceptable reason to do so, such as to service your account or provide you with financial services. Employees who violate our Privacy Policy are subject to disciplinary action up to and including termination from employment.

In addition to maintaining physical and procedural safeguards, we use a variety of security technologies and operational functions to protect your information. However, due to the increasingly sophisticated strategies of today’s cyber terrorists, please be advised that the perfect network security does not exist. Although The Swarthmore Group continually reevaluates our security measures to combat any potential risks and threats to our system, The Swarthmore Group does not warrant that its information is impenetrable or invulnerable to hackers.

Q: How does The Swarthmore Group inform clients about its Privacy Policy?

A: We send our Privacy Policy to new clients when they open a new account. We also send the policy to current clients yearly. We may revise this privacy notice. If we make any material changes, we will notify you as required by law.

Q: How does this Privacy Policy apply to former clients?

A: Even if we cease to provide you with financial services, our Privacy Policy will continue to apply to you and we will continue to treat your non-public information with strict confidentiality.

If you have any questions regarding our Privacy Policy, or should you require additional information, please contact Denise Caruso, Chief Compliance Officer, at 215.557.9300 or via email at dcaruso@swarthmoregroup.com. A copy of our ADV is available upon request.

The Swarthmore Group, Inc.
Form CRS Relationship Summary
June 30, 2020

Introduction	The Swarthmore Group is registered with the Securities and Exchange Commission (SEC) as an investment advisor. Brokerage and investment advisory services and fees differ and it is important for you to understand these differences. Free and simple tools are available to research firms and financial professionals at Investor.gov/CRS, which also provides educational materials about broker-dealers, investment advisors, and investing.
What investment services and advice can you provide me?	We offer a range of wealth management, financial planning, consulting and investment advisory services to retail investors. We manage investment accounts on both a discretionary and a non-discretionary basis. A discretionary account allows us to buy and sell investments in your account without asking for your approval in advance. A non-discretionary account means that you decide what investments to buy and sell. The Swarthmore Group does not have an annual minimum fee for wealth management services. As part of your portfolio management services, we will continuously monitor your investments and provide advice. We do not limit the types of investments that we recommend. *For additional information,* please see our Form ADV Part 2A, Items 4, 7, 13 and 16. *Conversation Starters.* Ask your financial professional: · Given my financial situation, should I choose an investment advisory service? Why or why not? · How will you choose investments to recommend to me? · What is your relevant experience, including your licenses, education and other qualifications? What do these qualifications mean?
What fees will I pay?	The services and fees of the wealth management services paid to The Swarthmore Group are based on a percentage of the market value of a client’s portfolio are as follows: First $5,000,000 – 1%, next $5,000,000 – 0.75%, over $10,000,000 – 0.50%. Financial planning and consulting services are provided under an hourly fee arrangement that is negotiated based on the complexity of the client, scope of work, and other factors. The Swarthmore Group, in its sole discretion, may charge a lesser investment advisory fee and/or charge a flat fee based upon certain criteria (i.e. anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, competition, negotiations with client, etc.). Please Note: As result of the above, similarly situated clients could pay different fees. In addition, similar advisory services may be available from other investment advisors for similar or lower fees. The more assets there are in your account, the more you will pay in fees, so we have an incentive to encourage you to increase the assets in your account. Clients may pay other expenses in addition to the fees paid to us. For example, clients may pay costs such as brokerage commissions, transaction fees, custodial fees, transfer taxes, wire transfer fees, and other fees and taxes charged to brokerage accounts and securities transactions, which are unrelated to the fees collected by us. Mutual funds and ETFs also charge internal management fees, which are disclosed in a fund’s offering documents. We do not charge performance-based fees. You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time. Please make sure you understand what fees and costs you are paying. *For additional information,* please see our Form ADV Part 2A brochure Items 5 and 6.
What are your legal obligations to me when acting as my investment advisor? How else does your firm make money and what conflicts of interest do you have?	When we act as your investment advisor, we have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. You should understand and ask us about these conflicts because they affect the recommendations we provide you. Here are some examples to help you understand what this means. · Third-Party Payments: Certain products offered by us, such as funds, can pay us additional compensation related to your investments. These are not charges to you, but these payments can create a conflict of interest in that there are additional financial incentives for us to recommend such funds. *Conversation Starter.* Ask your financial professional: · How might your conflicts of interest affect me, and how will you address them? *For additional information,* please see our Form ADV Part 2A.
How do your financial professionals make money?	Our financial professionals are primarily compensated with a fixed annual salary. Additional compensation may be based on the amount of client assets they service, the time and complexity needed to meet a client’s needs and the revenue the firm earns from advisory services. There is no compensation linked to the investments offered or from sales commissions.
Do your financial professionals have legal or disciplinary history?	No. Visit Investor.gov/CRS for a free and simple search tool to research us and our financial professionals. *Conversation Starter.* Ask your financial professional: · As a financial professional, do you have any disciplinary history? For what type of conduct?
Additional Information	*For additional information about our services or to request a copy of Form CRS, please contact us at:* 1650 Arch Street, Suite 2100, Philadelphia, PA 19103, Tel.: (215) 557-9300, www.swarthmoregroup.com *Conversation Starter.* Ask your financial professional: · Who is my primary contact person? Is he or she a representative of an investment-advisor or broker-dealer? Who can I talk to if I have concerns about how this person is treating me?