PACIFICEQUITY

M A N A G E M E N T
 Pacific Equity, LLC
Firm Brochure - Form ADV Part 2A

This brochure provides information about the qualifications and business practices
Pacific
of Equity, LLC. If you
have any questions about the contents of this brochure, please contact us at office@pacificequity.net
The information in this brochure has not been approved or verified by the United States
Securities and Exchange Commission or by any state securities authority.

2150 Columbus Pkwy.

Benicia, CA, 94510
(646) 893-0288

office@pacificequity.net
-

Pacific Equity, LLCis a registered investment adviser. Registration

does not imply a certain level of skill or training.

Version Date: 2/10/2020

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 Item 2: Material Changes

Since our last annual amendment filing dated February 2019, we have made the following material
changes to this brochure:

Item 5 – Pacific Equity will utilize Adhesion Wealth’s platform and third -party managers for
asset management services.

Item 5 and 14 - Pacific Equity will utilize Synergy Financial Management, LLC for third -party
asset management services.

Item 4 and 5 – Pacific Equity will now offer asset management services.

Item 12 – Pacific Equity has made arrangements with TD Ameritrade for c ustody and trade
execution services.

Item 16 – Pacific Equity will offer discretionary and non -discretionary asset management.

We will ensure that you receive a summary of any material changes to this and subsequent disclosure
brochures within 120 days after our firm’s fiscal year ends. Our firm’s fiscal year ends on December 31,
so you will receive the summary of material changes no later than April 30 each year. At that time, we
will also offer or provide a copy of the most current disclosure brochure. We may also provide other
ongoing disclosure information about material changes as necessary.

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 Item 4: Advisory Business

A. Description of the Advisory Firm

Pacific Equity, LLC (hereinafter “Pacific Equity, LLC”) is a Limited Liability Company
organized in the State of California.

B. Types of Advisory Services

Selection of Other Advisers

Pacific Equity, LLC directs clients to third -party investment advisers to manage client
assets. Before selecting other advisers for clients, Pacific Equity, LLC will always ensure
those other advisers are properly licensed or registered as an investment adviser. Pacific
Equity, LLC will review the ongoing performance of the third -party adviser as a portion
of the client's portfolio.

Pacific Equity, LLC generally limits its investment advice to third -party investment
advisers focusing on stocks, bonds, mutual fun ds, ETFs and will use other securities as
well to help diversify a portfolio when applicable.

Asset Management Services

Pacific Equity offers asset management services, which involves Pacific Equity
providing you with continuous and ongoing supervision over your specified accounts.

You must appoint my firm as your investment adviser of record on specified accounts
(collectively, the “Account”). The Account consists only of separate account(s) held by
qualified custodian(s) under your name. The qualifi ed custodians maintain physical
custody of all funds and securities of the Account, and you retain all rights of ownership
(e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive
transaction confirmations) of the Account.

The Account is managed by me based on your financial situation, investment objectives

and risk tolerance. I actively monitor the Account and provide advice regarding buying,
selling, reinvesting or holding securities, cash or other investments of the Account.

I will need to obtain certain information from you to determine your financial situation
and investment objectives. You will be responsible for notifying me of any updates
regarding your financial situation, risk tolerance or investment objective a nd whether

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Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading

A. Code of Ethics

Pacific Equity, LLC has a written Code of Ethics that covers the following areas: Prohibited
Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted
Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment,
Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance
with Laws and Regulations, Procedures and Reporting, Certification of Compliance,

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 Reporting Violations, Compliance Officer Duties, Training and Educatio n,
Recordkeeping, Annual Review, and Sanctions. Pacific Equity, LLC's Code of Ethics is
available free upon request to any client or prospective client.

B. Recommendations Involving Material Financial Interests

Pacific Equity, LLC does not recommend that c lients buy or sell any security in which a
related person to Pacific Equity, LLC or Pacific Equity, LLC has a material financial
interest.

C. Investing Personal Money in the Same Securities as Clients

Representatives of Pacific Equity, LLC do not recommend individual securities to clients

nor will its representatives trade in the same securities as clients.

D. Trading Securities At/Around the Same Time as Clients’ Securities

Please see Item 11C above.

Item 12: Brokerage Practices

A. Factors Used to Select Custodians and/or Broker/Dealers

1. Research and Other Soft Dollar Benefits

An investment adviser receives soft dollar benefits from a broker -dealer when the
investment adviser receives research orother products and services in exchange for
client securities transactions or maintaining an account balance with the broker-dealer.

Pacific Equity utilizes the services of TD Ameritrade. While there is no direct linkage
(except in certain circumstances)between the investment advice given to clients and
Pacific Equity’s participation in the TD Ameritrade program, economic benefits are
received by Pacific Equity which would not be received if I did not give investment
advice to clients.

Although I don’t allow directed brokerage, I may still receive benefits from program
sponsors and product issuers. These benefits may be used for both research and non -
research purposes and allows me to supplement, at no cost, my own research and
analysis activities. These benefits include: a dedicated trade desk that services the
program participants exclusively, a dedicated service group and an account services
manager dedicated to Pacific Equity’s accounts, access to a real -time order matching
system, the ability to “block” clients’ trades, electronic download of trades, balances and

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position information, duplicate and batched client statements, confirmations, year -end
summaries, the ability to have advisory fees directly debited from client accounts (in
accordance with federal and state requirements), availability of third -party research and
technology, a quarterly newsletter and access to mutual funds.

The benefits received through participation in the TD Ameritrade program do not

depend upon the amount of transactions directed to or amount of assets managed
through TD Ameritrade.

Research obtained with soft dollars is not necessarily utilized for the specific account
that generated the soft dollars. I do not attempt to allocate the relative costs or benefits
of research among clients becauseI believe that, in the aggregate, the researchI receive
benefits all clients and assistsme in fulfilling my overall duty to you.

These arrangements may be deemed to create a conflict of interest to the extent that I
woul d have to pay for some or all of the research and/or services with “hard dollars” if I
were unable to obtain the research and services in exchange forbrokerage expensesin
connection with client transactions. Client trades are always implemented based on the
goals and objectives of the client and not on any research, products or other incentives
available.

2. Brokerage for Client Referrals

Pacific Equity recommends that you establish brokerage accounts with TD Ameritrade
through their Institutional Platfo rm. TD Ameritrade, Inc. (“TD Ameritrade”) is a
member of FINRA/SIPC. TD Ameritrade is an independent (and unaffiliated) SEC -
registered broker-dealer and is recommended by Pacific Equity to maintain custody of
clients' assets and to effect trades for theiraccounts.

At least annually, I will review alternative custodians in the marketplace for comparison
to the currently used custodian, evaluating criteria such as overall expertise, cost
competitiveness, and financial condition. Quality of execution for custodians will be
reviewed through trade journal evaluations.

Pacific Equity is independently owned and operated and not affiliated with TD
Ameritrade.

The primary factor in suggesting a broker/dealer or custodian is that the services of the
recommended firm are provided in a cost -effective manner. While quality of execution
at the best price is an important determinant, best execution does not necessarily mean
lowest price and it is not the sole consideration. The trading process of any
broker/dealer sug gested by Pacific Equity must be efficient, seamless, and straight-

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forward. Overall custodial support services, trade correction services, and statement
preparation are some of the other factors determined when suggesting a broker/dealer.

TD Ameritrade, Inc. provides me with access to their institutional trading and custody
services, which are typically not available to retail investors. These services generally are
available to independent investment advisors at no charge to them so long as the
independent investment advisors maintain a minimum amount of assets with the
custodian.

TD Ameritrade, Inc. also makes available to me other products and services that benefit
my firm but may not benefit clients' accounts. Some of these other products and services
assist me in managing and administering clients' accounts. These include software and
other technology that provide access to client account data (such as trade confirmation
and account statements); provide research, pricing information and other market data;
facilitate payment of the firm’s fees from its clients' accounts; and assist with back-office
functions; record keeping and client reporting. Many of these services generally may be
used to service all or a substantial number of our accounts, including accounts not
maintained at a recommended custodian. Pacific Equity is also providing other services
intended to help my firm manage and further develop my business enterprise. These
services may include consulting, publications and conferences on practice management,
information technology, business succession, regulatory compliance and marketing.

Other benefits we receive include, but are not necessarily limited to: receipt of duplicate
client confirmations and bundled duplicate statements; access to a trading desk; access
to block trading which provides the ability to aggregate securities transactions and
allocate the appropriate shares to client accounts; access to an electronic communications
network for client order entry and account information; and access to mutual funds that
generally require significantly higher minimum initial investments or are generally only
available to institutional investors.

Specifically, Pacific Equity participates in the TD Ameritrade Institutional program. TD

Ameritrade Institutional is a division of TD Ameritrade, Inc. TD Ameritrade offers to
independent investment Advisors services which include c ustody of securities, trade
execution, clearance and settlement of transactions. Adviser receives some benefits from
TD Ameritrade through its participation in the program. (Please see the disclosure under
Item 14 below.)

3. Clients Directing Which Broker/Dealer/Custodian to Use

Clients should understand that not all investment advis ers require the use of a particular
broker/dealer or custodian. Some investment advisers allow their clients to select
whichever broker/dealer the client decides. By requiring clients to use a particular

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broker/dealer, Pacific Equity may not achieve the most favorable execution of client
transactions and the practice requiring the use of specific broker/dealers may cost
clients more money than if the client used a different brok er/dealer or
custodian. However, for compliance and operational efficiencies, Pacific Equity has
decided to require my clients to use broker/dealers and other qualified custodians
determined by Pacific Equity.

4. Handling Trade Errors

Pacific Equity has implemented procedures designed to prevent trade errors; however,
trade errors in client accounts cannot always be avoided. Consistent with its fiduciary
duty, it is the policy of Pacific Equity to correct trade errors in a manner that is in the
best interest of the client. In cases where the client causes the trade error, the client is
responsible for any loss resulting from the correction. Depending on the specific
circumstances of the trade error, the client may not be able to receive any gains
generated as a result of the error correction. In all situations where the client does not
cause the trade error, the client is made whole and any loss resulting from the trade
error is absorbed by Pacific Equity if the error is caused by Pacific Equity. If the error is
caused by the broker-dealer, the broker-dealer is responsible for handling the trade
error. If an investment gain results from the correcting trade, the gain remains in the
client’s account unless the same error involved other client account(s) that should also
receive the gains. It is not permissible for all clients to retain the gain. Pacific Equity
may also confer with a client to determine if the client should forego the gain (e.g., due
to tax reasons).

Pacific Equity will never benefit o r profit from trade errors.

B. Aggregating (Block) Trading for Multiple Client Accounts

Pacific Equity does not engage in block trading. It should be noted that implementing
trades on a block or aggregate basis may be less expensive for client accounts; however,
it is my trading policy is to implement all client orders on an individual basis.
Therefore, I do not aggregate or “block” client transactions.

Item 13: Review of Accounts

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A. Frequency and Nature of Periodic Reviews and Who Makes Those
Reviews

All client accounts for Pacific Equity, LLC's advisory services provided on an ongoing
basis are reviewed at least quarterly by Keith Ponthieux, Managing Member, with regard
to clients’ respective investment policies and risk tolerance levels. All accounts at Pacific
Equity, LLC are assigned to this reviewer.

B. Factors That Will Trigger a Non-Periodic Review of Client Accounts

Reviews may be triggered by material market, economic or political events, or by changes

in client's financial situations (such as retirement, termination of employment, physical
move, or inheritance).

C. Content and Frequency of Regular Reports Provided to Clients

Each client of Pacific Equity, LLC’s advisory services provided on an ongoing basis will
receive a quarterly report detailing the advisory fee and the breakdown. In addition, each
client will receive a monthly statement from the custodian detailing account values, assets
held and any advisory fee withdrawn.

Item 14: Client Referrals and Other Compensation

A. Economic Benefit s Provided by Third Parties for Advice Rendered

to Clients (Includes Sales Awards or Other Prizes)

Pacific Equity, LLC currently has in place an arrangement to utilize the platform and
third -party advisers and funds through Adhesion Wealth . Pacific Equity, LLC also hasan
arrangement to utilize Synergy Financial Management, LLC for third -party asset
management services.

The fees charged by Pacific Equity, Adhesion , TD Ameritrade and Synergy Financial
Management, LLC are disclosed in Item 5 above.

Pacific Equity may refer clients to Asset Preservation and Associated Insurance Services,
LLC. Asset Preservation and Associated Insurance Services , LLC may also refer clients to
Pacific Equity.

B. Compensation to Non – Advisory Personnel for Client Referrals

Pacific Equity, LLC does not directly or indirectly compensate any person or receive any
compensation from any person who is not advisory personnel for client referrals.

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 Item 15: Custody

Pacific Equity, LLC does not take custody of client accounts at any time. Custody of client’s
accounts is held primarily at the client’s custodian. Clients will receive account stateme nts from
the custodian and should carefully review those statements for accuracy.

Item 16: Investment Discretion

When providing asset management services, Pacific Equity maintains trading authorization
over your Account and can provide management services on a discretionarybasis. When
discretionary authority is granted, I will have the authority to determine the type of securities
and the amount of securities that can be bought or sold for your portfolio without obtaining
your consent for each transaction. However, it is the policy of Pacific Equity to consult with
you prior to making significant changes in the account even when discretionary trading
authority is granted.

If you decide to grant trading authorization on a non-discretionarybasis, I will be required to

contact you prior to implementing changes in your account. Therefore, you will be contacted
and required to accept or reject our investment recommendations including:

• The security being recommended

• The number of shares or units
• Whether to buy or sell

Once the above factors are agreed upon, I will be responsible for making decisions regarding
the timing of buying or selling an investment and the price at which the investment is bought or
sold. If your accounts are managed on a non-discretionary basis, you need to know that if I am
not able to reach you or you are slow to respond to my request, it can have an adverse impact
on the timing of trade implementations and I may not achieve the optimal trading price.

Client will grant Pacific Equity discretionary authority (without first consulting with Client) to
establish and/or terminate a relationship with third -party advisers for purposes of managing
the Account or a portion of the Account determined by Pacific Equity.

You will grant the third -party adviser selected by Pacific Equity with the discretionary
authority (without first consulting with client) to make all decisions to buy, sell or hold
securities, cash or other investments for the account managed by the third-party advis er. You
also grant the third -party adviser with the power and authority to carry out these decisions by
giving instructions, on your behalf, to the broker dealers and/or the qualified custodian of your
account.

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 Item 17: Voting Client Securities (Proxy Voting)

Pacific Equity, LLC will not ask for, nor accept voting authority for client securities. Clients have
the option to receive proxies directly from the issuer of the security or the custodianor clients can
request the proxies be s ent to the third -party manager or fund manager to be voted . Clients
should direct all proxy questions to the issuer of the security.

Item 18: Financial Information

A. Balance Sheet

Pacific Equity, LLC does not solicit prepayment of fees per client and ther efore is not
required to include a balance sheet with this brochure.

B. Financial Conditions Reasonably Likely to Impair Ability to Meet

Contractual Commitments to Clients

Neither Pacific Equity, LLC nor its management has any financial condition that is l ikely
to reasonably impair Pacific Equity, LLC’s ability to meet contractual commitments to
clients.

C. Bankruptcy Petitions in Previous Ten Years

Pacific Equity, LLC has not been the subject of a bankruptcy petition in the last ten years.

Item 19: Requirements For State Registered Advisers

A. Principal Executive Officers and Management Persons; Their

Formal Education and Business Background

Pacific Equity, LLC currently has only one management person: Keith James Ponthieux.
Education and business background can be found on the individual's Form ADV Part 2B
brochure supplement.

B. Other Businesses in Which This Advisory Firm or its Personnel are

Engaged and Time Spent on Those (If Any)

Other business activities for each relevant individual can be found on the Form ADV Part
2B brochure supplement for each such individual.

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C. Calculation of Performance-Based Fees and Degree of Risk to Clients

Pacific Equity, LLC does not accept performance-based fees or other fees based on a share
of capital gains on or capital appreciation of the assets of a client.

E. Material Relationships That Management Persons Have With

Issuers of Securities (If Any)

Neither Pacific Equity, LLC , nor its management persons, has any relationship or
arrangement with issuers of securities. See Item 10.C and 11.B.

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PACIFICEQUITY
M A N A G E M E N T