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| Divergent Planning LLC
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| CRD # | 285688 |
| SEC # | 801-112962 |
| CIK # | 0001730787 |
| AUM | 423.1 M (2026-01-10) |
| Employees | 8 (50% Investors, 0% Brokers) |
| Fees | |
| Minimum | |
| Phone | 240-428-8911 |
| Address | 6701 Democracy Blvd Bethesda, MD 20817 |
| Source | [IAPD] [EDGAR] [Website] [Twitter] [LinkedIn] |
| Total AUM ($M) |
|---|
| Fees and Compensation — Form ADV Part 2A (1/10/2026) [Brochure] |
|---|
Item 5: Fees & Compensation
Compensation for Our Advisory Services
Portfolio Management:
Assets Under Management Annual Percentage of Assets Charge
$0 to $499,999.99 1.55%
$500,000 to $999,999 1.30%
$1,000,000 to $1,999,999 0.90%
$2,000,000 to $2,999,999 0.75%
$3,000,000 & Over 0.65%
Clients must maintain a minimum household average daily balance of $750,000 for a billing quarter
to receive the combination of asset management and financial planning or consulting services
bundled together for a single fee. This requirement may be waived on a case-by-case basis. Portfolio
Management clients who do not meet the minimum household average daily balance of $750,000 will
be required to sign a separate Financial Planning & Consulting Agreement and pay a separate fee if
they want to receive financial planning or consulting services. Our firm will terminate the Financial
Planning & Consulting Agreement and cease charging a separate fee for financial planning or
consulting services when a Portfolio Management client exceeds the minimum household average
daily balance of $750,000 for a billing quarter.
Fees to be assessed for our Portfolio Management service will be outlined in the advisory agreement
to be signed by the client. Annualized fees are billed on a pro-rata basis quarterly in advance based
on the time-weighted daily average value of household account(s) during the previous quarter. Our
firm bills on cash unless indicated otherwise in writing. In rare cases, our firm will agree to directly
invoice. Should an invoice be sent, clients will be required to pay via check. Fees are negotiable and
will be deducted from client account(s). As part of this process, clients understand the following:
ADV Part 2A – Firm Brochure Page 5 Divergent Planning
a) The client’s independent custodian sends statements at least quarterly showing the market
values for each security included in the assets and all account disbursements, including the
amount of the advisory fees paid to our firm.
b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our
firm will send an invoice directly to the custodian.
c) If our firm sends a copy of our invoice to the client, it will include a disclosure urging the
comparison of information provided in our statement with those from the qualified
custodian.
If agreed upon in the signed advisory agreement, our firm will manage client account(s) that are held
at a custodian that is not directly accessible by our firm using the Pontera Solutions, Inc. (“Pontera”)
order management system. Pontera enables our firm to view and manage held away accounts. The
Pontera fee and advisory fee payable for any held away accounts will be deducted directly from
another client account, and if there are insufficient funds available in another client account or our
firm believes that deducting the advisory fee from another client account would be prohibited by
applicable law, we will invoice the client directly.
Financial Planning & Consulting:
Our firm charges a flat annual fee assessed quarterly for financial planning and consulting services.
The total estimated fee, as well as the ultimate fee charged, is negotiable and based on the scope and
complexity of our engagement with the client. The minimum annual fee is $7,000 ($1,750 per
quarter). The total flat fee shall not exceed $20,000 annually. Our firm will not require a retainer
exceeding $1,200 when services cannot be rendered within 6 months.
Other Types of Fees & Expenses
Clients will incur transaction charges for trades executed in their accounts. These transaction fees
are separate from our firm’s advisory fees and will be disclosed by the chosen custodian. Clients may
also pay holdings charges imposed by the chosen custodian for certain investments, charges imposed
directly by a mutual fund, index fund, or exchange traded fund, which shall be disclosed in the fund’s
prospectus (i.e., fund management fees and other fund expenses) initial or deferred sales charges,
mutual fund sales loads, 12b-1 fees, surrender charges, variable annuity fees, IRA and qualified
retirement plan fees. Our firm does not receive a portion of these fees.
Our recommended custodian, Charles Schwab & Co., Inc. (“Schwab”), does not charge transaction fees
for U.S. listed equities and exchange traded funds.
Termination & Refunds
Either party may terminate the advisory agreement signed with our firm for Portfolio Management
services by providing written notice to the other party at any time. Upon notice of termination, our
firm will process a pro-rata refund of the unearned portion of the advisory fees charged in advance
at the beginning of the quarter.
Either party may terminate the advisory agreement signed with our firm for Financial Planning &
Consulting services by providing written notice to the other party at any time. For purposes of
calculating refunds, all work performed by us up to the point of termination shall be calculated at
$350 per hour. Clients will receive a pro-rata refund of unearned fees based on the time and effort
expended by our firm.
ADV Part 2A – Firm Brochure Page 6 Divergent Planning
Commissionable Securities Sales
Our firm and representatives do not sell securities for a commission in advisory accounts. |
| Account Minimums and Types of Clients — Form ADV Part 2A (1/10/2026) [Brochure] |
|---|
Item 7: Types of Clients & Account Requirements
Our firm has the following types of clients: Individuals, High Net Worth Individuals, Trusts, Estates
and/or Charitable Organizations.
Clients must maintain a minimum household average daily balance of $750,000 for a billing quarter
to receive the combination of asset management and financial planning or consulting services
bundled together for a single fee. This requirement may be waived on a case-by-case basis. Clients
who do not meet the minimum household average daily balance of $750,000 will be required to sign
a Financial Planning & Consulting Agreement and pay a separate fee to receive financial planning or
consulting services. Our firm will terminate the Financial Planning & Consulting Agreement and cease
charging a separate fee for financial planning or consulting services when a client exceeds the
minimum household average daily balance of $750,000 for a billing quarter. For example, we may
reduce the minimum to $250,000 for individuals who are under 45 years of age and are active
accumulators.
For standalone financial planning or consulting services, we charge a minimum annual fee of $7,000
($1,750 per quarter). This requirement may be waived on a case-by-case basis. |
| Sector | Form 13F Holdings | Value ($M) | |
|---|---|---|---|
| Apple Inc | 2.3 | ||
| Marriott International Inc /MD/ | 0.9 | ||
| Morgan Stanley | 0.8 | ||
| Microsoft Corp | 0.7 | ||
| Amazon Com Inc | 0.6 | ||
| Visa Inc | 0.6 | ||
| Lockheed Martin Corp | 0.5 | ||
| Alphabet Inc | 0.4 | ||
| SPDR Gold Trust | 0.3 | ||
| Holdings by Sector ($M) |
|---|
| AUM Breakdown | Accounts | AUM ($M) |
|---|---|---|
| By Client Type | ||
| (a) Individuals (other than high net worth individuals) | 68 | 20.6 |
| (b) Individuals (high net worth individuals) | 200 | 402.5 |
| (c) Banking or thrift institutions | 0 | 0.0 |
| (d) Investment companies | 0 | 0.0 |
| (e) Business development companies | 0 | 0.0 |
| (f) Pooled investment vehicles | 0 | 0.0 |
| (g) Pension and profit sharing plans | 0 | 0.0 |
| (h) Charitable organizations | 0 | 0.0 |
| (i) State or municipal government entities | 0 | 0.0 |
| (j) Other investment advisers | 0 | 0.0 |
| (k) Insurance companies | 0 | 0.0 |
| (l) Sovereign wealth funds and foreign official institutions | 0 | 0.0 |
| (m) Corporations or other businesses not listed above | 0 | 0.0 |
| (n) Other | 0 | 0.0 |
| Total | 960 | 423.1 |
| By Discretionary | ||
| Discretionary | 960 | 423.1 |
| Non-Discretionary | 0 | 0.0 |
| Total | 960 | 423.1 |
| By Non-United States Persons | ||
| Non-United States Persons | 0.8 | |
| United States Persons | 422.3 | |
| Total | 960 | 423.1 |
| EDGAR Form | CIK | 2011 - 2026 |
|---|---|---|
| 13F-HR | [0001730787] |
| Firm Profile (Form ADV) | |
|---|---|
| Clients | 32 (1 non-US) |
| Serves | Institutional, Retail |
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|---|---|---|
|
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|
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|
Investment Planning Advisors
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