AMA with Alan Moore and Michael Kitces, Part Two

23 min read
December 13, 2018

In our last blog, Michael and I tackled 30 questions from our #XYPNLIVE AMA. Now, we're back for round two, taking on topics like regulation, the future of the subscription-based model, and how much you should really charge for financial planning. 

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Where do you see redundancy in organizations serving financial planners? Do we really need the FPA, CFP Board, NAPFA, XYPN, etc.?

I feel like we all provide different services. The CFP Board is critical in terms of creating and maintaining the designation and standards held to that designation.

NAPFA is the association that is advocating for the financial advisor and for the consumer. That is different from what the CFP Board does. The CFP Board has been making some plays lately to move in the direction where, quite honestly, they may start competing with some of the Associations. But NAPFA and FPA are there to advocate for the advisor. NAPFA has been very successful in spreading the brand awareness of fee-only and fiduciary for decades.

XYPN is a different model. We’re a for-profit business that’s here to help support advisors in building their businesses. We really view our platform as an advisor support platform to help advisors better run their businesses to be able to serve Gen X and Y clients.

There’s room in the industry for all of the organizations because we’re providing very different services. In fact, this is why we pay for XYPN members to be NAPFA members as well—because XYPN and membership associations are fundamentally different (albeit complementary) services.

How can we trust you will advocate for XYPN members when you are building out separate companies that profit directly from the membership (AdvicePay and XYIS)? This seems like a conflict of interest.

Our mission is to provide a platform—and continue to expand that platform—to be able to better serve financial advisors. We’re really only building services and solutions that our advisors need that they’re not finding in the marketplace.

We built AdvicePay because there was not a compliant payment processor or billing solution that was acceptable to state regulators. So we ended up building our own.

Same with XY Investment Solutions (XYIS). We found there just wasn’t another TAMP that was really specialized and built from the ground up with the types of advisors we have as members in mind (i.e., those who work with younger clients and often smaller accounts of ongoing savers). Other TAMPs had really high asset or fee minimums that just didn’t make sense for our Network and its members.

Our long-term vision is to continue to roll out additional services that help our advisors succeed and better run their businesses. XYPN members don’t have to use these services. We don’t require that members use XYIS to be part of XYPN, so that’s where the conflict of interest is eliminated. If you want to use another TAMP or self-manage, we have the relationship with TD Ameritrade; we have a massive discount service offering with Orion; or if you want to use another TAMP, that’s totally fine too. We aren’t requiring anyone to use these services unlike a broker-dealer, which would require you to use the CRM or planning software or whatever it is they offer. 

At XYPN, it’s up to you to pick and choose what works best for you and what you want to leverage inside your firm. We’re simply trying to build additional valuable services where necessary to fill the voids we can’t fulfill from other third-party providers. 

A lot of us (me included) started out with a rate of about $150/month, because for a long while, that's the price that XYPN leadership talked up a lot. And many of us have raised our fees significantly since then because we found that rate woefully too low. What is XYPN's current take on how people should charge out of the gate, so that new owners don't have to struggle so much in years 2 and 3 to get their rates up to what they really NEED to be?

When looking at  industry benchmarking studies with respect to what people are charging for financial planning services, we do still see that $150/month sticks pretty well—and that’s outside of XYPN membership. That’s what people in the industry at large are charging for financial planning.

We recommend not starting with a price in mind, but rather with your niche market in mind. Who do you want to serve? Who are you the best at serving? How much value are you able to provide that target market, and what are they willing to pay for that value? 

You will have a very different pricing model if you’re working with specialized physicians who make $500K/year versus missionaries stationed overseas making $15K/year, or teachers making $40-$80K/year (depending on where they live). The $150/month was a rule of thumb that was meant to serve as a jumping off point. It was never intended to be a one-size-fits-all recommendation.

The “rule of thumb” we believe in is looking at your target market and charging somewhere between 1-2% of client income. We find that charging more than 2% of income becomes painful for clients, and it’s hard to be profitable charging less than 1% of income (unless you’ve got some very affluent clientele!).

If you’re working with doctors who make $500K/year, charging $5-$10K/year for financial planning is appropriate. If you’re working with a young couple who make $100K/year, charging $1-$2K/year is appropriate, so that $150/month recommendation may work here.

And then, of course, it also comes back to how much money you want to make. We have some advisors who are really happy making a net income of $60K/year. Some just want to make at least six figures (i.e. $100K+), others want to make $300K or more.

All of those goals, wants, and decisions go into figuring out the best way to structure your pricing model.

I'm currently affiliated with a broker-dealer. I'm in the process of making an agreement with a senior advisor at the broker-dealer to purchase his book of business. The book has approximately $100K/yr of recurring revenue but is mostly A-share 12b1's with American Funds (which is much different than the comprehensive planning approach we take with our clients). My heart, along with my two colleagues, tells us to forget the succession plan and start our own RIA serving the kind of people we actually want to work with. However, our recurring revenue is currently only $100K/year between the 3 of us and I'm concerned forgoing the succession plan and the corresponding existing revenue associated with the book (in addition to delivering actual financial planning to these clients) will only prolong the financial grind we've gone through to even get to where we're at now. What should I do?

Tough question. I was faced with this when I was trying to decide whether or not to start my own firm. There were plenty of opportunities to buy books of business from RIAs or people who had trailing commissions coming from the broker-dealer world.

But ultimately, I made the decision that those were not the clients I wanted to serve. I wanted to serve the clients who really wanted to work with me. You may decide something different.

It’s also worth noting that A-shares can be converted (with American Funds, to F-class advisory shares). So you may have the option of buying a book of $100K of recurring revenue, and converting it to advisory shares and continuing to get 1% of income moving forward (as a 1% AUM fee on an advisory account, as a fee-only RIA).

The concern I would still have, though, is that you have a big chunk of clients who are not your target market. Those clients will refer other clients like them, and you’ll continue to build this book of clients you don’t really want to be working with. And I’m presuming that there will be a cost for acquiring the clients in this succession plan in the first place, so I’m not certain how much you’ll really be netting for these non-target-market clients, either.

So, I’d be very cautious to take on a group of clients just for the revenue. In the long run, I think it will distract you from working with the clients you want to be working with and building the business you want to build. 

If you were going to start an RIA that could only serve people who make $60K/year or less, what would your service model look like to run a profitable business?

When I think about the 1-2% of income “rule of thumb” I mentioned earlier, somewhere between $600-$1200 a year if you’re working with 100 clients (which I believe you can do at scale) you’re talking about making between $60K and $120K of revenue.

The math works out such that you can expect when you charge between 1-2% of income at 100 clients, you will make approximately the same amount of money as your target client.

How much do you want to make? Are you okay making $60-$80K working with clients who make $60K? If you want to bring in clients who make $1 million, you’ll really need to scale and have a lot of advisors working for you to get there.

If you’re okay making $60-$80K, somewhere in that 1-2% of income is a good start. That’s $600-$1200 per year, or roughly $75/month for financial planning. In this case, you might consider a test run doing some group work; pull like-minded clients together so you can provide group-level service versus one-on-one.

Or maybe reduce the service model so you aren’t meeting quarterly, but rather once a year, or once a year plus email service. Any of these options are appropriate for the fee your clients would be paying. You can still provide an immense amount of value to those clients even with a “reduced” service model.

Given the choice of continuing to register in 15 states or jump to the SEC registration, what are the pros and cons? Our AUM is only $30M but we are registering in 15+ states currently.

Quite honestly, I think the way I would lean is to register with the SEC. That way you only have one set of rules you have to worry about.

The SEC is a little more adept at managing firms like yours. The individual states are a little behind when it comes to regulations and trying to keep up with what financial planning is and how to regulate and oversee the delivery of financial planning advice.

The SEC seems to be a little further ahead on that. So, I don’t really see a con of registering with the SEC that should deter you from going that direction. Most firms are eager to register with the SEC simply to get out of the administrative burdens and hassles of managing 15+ state registrations (which is literally the purpose and source of the 15-state rule for SEC registration).

It seems to me that people tell me they "have a niche", but they are describing a demographic swath of millions. How small is a niche?

A niche by definition is simply a group of people with a need. So technically "women" is a niche. Now I cringe when people say their niche is women, because women represent 51% of the population. But technically, “women” is a group of people with a need. And to the extent they’re not well-served by a huge swath of today’s advisors, arguably they’re an underserved niche (even though they’re a majority of the population).

There are some very large demographics that have been largely underserved. For example, religious affiliations such as Christians or Catholics or Muslims—those are demographics (or prospective clients) who have unique needs, unique values, and unique perspectives that their advisor really needs to understand to be able to best serve them. I believe there are roughly 1-billion Catholics in the world, which is obviously a huge number, but that can still be a niche—Kingdom Advisors is an example of an advisor organization that has built an entire community of advisors focused on serving Christians as a niche.

Conversely, you can also have a much smaller niche. I would describe a niche as well-defining who it is that you are the best at serving and the value that you provide those clients that exceeds the value that other advisors provide those clients. Thinking through these questions will really help you identify your niche. 

Can a 1-person RIA manage $100 million from a home office?

Absolutely. People have been doing it for years. You have to work with fairly large clients—$1million plus clients, maybe $1.5-$2million clients—if you truly don’t ever want to hire staff while reaching $100M of AUM.

There are also opportunities to outsource, whether you outsource investments to a TAMP platform like XYIS or hire a virtual assistant or paraplanner who provides support. You can be a “team of one” while still getting some support.

It’s doable if that fits in with your goals and vision for the business you want to build. The limiting factor is not AUM, but simply the number of clients you serve and the number of relationships you can manage (before you need a second advisor to help or have to stop growing).

I've been doing AUM business for about 25 years. We have a typical fee schedule with clients who average $800k in assets. Not that it's everything, but typically, an advice-only business isn't going to be as lucrative as that, is it?

This is a tough question because a lot of times the fee-for-service billing model does get applied to people who simply don’t have the assets to support an AUM fee. Commission-based sales people said the same thing about AUM that you’re saying about fee-for-service. “No one is going to pay me a 5.75% ongoing fee, but I can get that from a commission, so aren’t commissions more lucrative?”

It may be in the short run, but ultimately, it’s all about the value you are providing and the fee a client is willing to pay for that value. AUM fees can be a little easier to charge in the sense that clients aren’t seeing it—it’s not as painful because they aren’t paying out of their checkbook every month or quarter. But ultimately, your clients can find out how much they’re paying and when they do, they’re going to evaluate whether or not they’re getting enough value from you for the service they’re paying for. And that decision will be up to them. 

What is the biggest threat to the industry? Other professionals (e.g. CPAs), broker-dealers, regulators, something else?

I think there are a couple of ways you can look at threats to the industry. One of the biggest threats overall is the fact that we can’t actually evolve as a profession if we don’t find a way to serve the average American.

Only 5-7% of Americans have $$500k or more in investable assets, so as long as the industry continues to focus on wealthy households, we’re not able to serve the average consumer and we won’t ever evolve into the helping profession we know financial planning can be. So, I think this focus on the limited number of clients who already have financial wealth is something that will undermine the industry.

I also think regulation—and the evolution of regulation—is a huge threat. FINRA has made multiple plays at trying to take over regulation of the RIA marketplace, which would be a disaster and create huge conflicts of interest for them in terms of regulating both RIAs and the broker-dealer space.

Another threat is the SEC potentially trying to water down the fiduciary rule and make it more of a suitability rule, which I think will really hold back the progress we’ve made and set us back in terms of the work we do.

Yes, CPAs are starting to see wealth management as an opportunity to expand their client base, but again, we have 285,000 people who live in the world of financial advising; there are probably 17,000 state-registered RIAs that say they do financial planning. There are 115-million US households. We have plenty of room to grow. There are plenty of clients out there for us to serve, so I’m not really worried about it.

Do you think the financial planning profession would be better off with less regulation?

In general, I am a fan of less regulation and letting the marketplace sort itself out. The challenge we’ve had though, and the challenge you’re faced with whenever you believe in less regulation, is when there is false advertising and people who are willing to lie in their advertising.

For example, the majority of consumers believe their financial advisor is a fiduciary and yet the vast majority of people who call themselves financial advisors are not fiduciaries (and most are literally not even advisors, but salespeople by law).

As a result, we have an entire population of consumers who believe their advisor is working in their best interest when in actuality, they’re not. That’s where I see a huge issue. I do think that the regulations can evolve.

We’d love to see more regulation of job titles. For example, regulations that would disallow someone from calling themself a financial advisor if they’re not actually advising (and being held to a fiduciary standard appropriate for advice).

Or regulations that would prohibit advisors from switching between giving advice and selling a product without some really clear conversations. Or regulations that completely limit it to where you just can’t—you can never go from being a fiduciary to being a non-fiduciary (though you can step up and go the other way). 

I do think there are some areas of targeted regulation that make sense. Quite honestly, the regulation space is really not that bad. People are really scared of compliance and feel like it’s a big deal when the regulators and auditors come in, but ultimately if you compare the regulation of our industry to being a lawyer or an accountant or a doctor, I really don’t think it’s that arduous. I know it can be a lot for small companies, which is why we offer compliance services as part of our membership to make it as streamlined as possible, but I do think there are some areas where additional regulation would be helpful.

And probably going through and “rewriting” some rules that were written in 1940 to be more applicable today would be a huge help.

Thoughts on current status of fiduciary rule, BIC, state of SEC commission and, with the November elections and possible shuffle of the Senate, when we could expect the fiduciary rule to re-enter public conversation?

The SEC is working on this. The latest indication is that a new/updated proposal from the SEC will come by September of 2019, likely with some substantial revisions given the negative feedback especially to the proposed Form CRS. In addition, the Democrats taking control of the House will result in the House Financial Services Committee (which has oversight of the SEC) being led by Maxine Waters, who has been a strong fiduciary advocate (including for the DoL’s more stringent fiduciary rule). So stay tuned for a lot more discussion on this in 2019.

But anything that requires politicians and lawmakers is going to take years to do. So, we’ll continue to fight the good fight and try to work with the SEC and the Associations to write a fiduciary standard that is actually a true fiduciary standard. 

What do you think will happen to the subscription-based business model in the next 2008?

One of the reasons we advocate for using flat fees for planning—and if you’re going to use AUM for investment management, we suggest you keep those separate—is because with the monthly subscription, or the fee-for-service model of billing monthly or quarterly, the flat fee for financial planning really becomes the bond in your own personal income portfolio as an advisor—the AUM is your stock (with more upside potential but also more downside exposure).

So, it remains to be seen what happens in the middle of another huge recession, should that happen again, but my expectation is that your relationship with your clients will survive because of how valuable you are. Though clients who feel cash-strapped in a recession may still take a hard look at advisory firms (but that’s likely more related to their employment situation than their portfolio returns).

If clients are dropping their financial advisor because the markets are dropping, then we have a value proposition problem and we’re not adequately describing the value of what we do to our clients. I would expect your AUM revenue to go down as the market goes down (as it’s gone up when markets were up), but the revenue for ongoing financial planning services should stay where it’s at. 

I think XYPN advisors are better positioned with their existing client relationships than most advisors who are relying strictly on AUM whenever the market is dropping. 

Could you speak to the trend of large “national” RIAs rolling up small firms vs the outlook for small firms succeeding in the future?

We are starting to see the mega RIA firms—Mariner, Creative Planning, United Capital—some of these firms that are starting to hit $20 or even $50 billion AUM as regional or nationwide firms. We’ve long predicted that this would be the case. We expected that ultimately there were going to be a few big brand names in the RIA space providing financial planning. But I see no issues with smaller advisory firms being able to succeed in the future. 

Ultimately the larger a firm gets, the less personalized the service becomes. There are great things that scale—the marketing and sales side in terms of the services you can offer—but ultimately the big CPA firms haven’t put the small CPA firms out of business. It just doesn’t happen. We see there is plenty of opportunity for small firms to carve out a niche in the marketplace and serve that niche better than any large firm could possibly because you’re more knowledgeable, accessible, and you have more expertise. And the rise of both better technology, and platforms like XYPN, make it easier to be a solo advisor more so than ever in the past! 

On the other hand, growing a firm to the $1-$3 billion AUM mark may become more difficult. Scaling through that growth barrier will be more of a challenge than it has in the past because there will be some national brands that are top of mind for consumers. But for the type of business the average XYPN advisor is looking to build, I don’t see any issues with what the large firms are doing.

What are the benefits to an established 20-year-old RIA to joining XYPN?

One of the common misconceptions is that only startups join XYPN. About 60% of firms that are joining XYPN are registering a new firm, but that also means 40% already have an existing RIA. Those existing firms span from several years in business to 20+ years in business. 

So, without knowing more about the firm that’s asking this question, we have several groups of established RIAs that join XYPN for various reasons.

We do have large firms that will join that have one or two or more of their younger advisors who are building out a next-gen service model inside the existing practice. We call this the intrapreneurship model, or building a “firm-within-a-firm”—we’ve also used the term peer-to-peer financial planning model. We’re still working on the best way to describe this, but it’s basically a brand within a brand.

You have a brand that is focused specifically on serving next-gen clients inside of a larger firm. Those people are joining because they want access to the tools, the technology, the resources, the expertise, and the community that offers a comprehensive knowledge base on how to best serve these clients without having to recreate the wheel. There’s no reason for younger advisors inside of larger firm to try and figure out all of this on their own when they can join XYPN and get access to the brain trust creating by over 800 financial advisors all working on this service model—continuously refining it—and learning from each other. 

If you own a smaller existing RIA, really the advantage to joining XYPN is to be able to join the platform of the future; to be able to surround yourself with advisors who are thinking about the future and who aren’t mired in the way things have always been done. XYPN advisors are cutting-edge and always thinking about the best way to do things. Getting access to the tools and technology, compliance services, and all of that we find generally pays for itself in terms of our membership fee. But getting access to the community is usually the big value-add and what people are typically looking for (even if they don’t realize it when they join)—the community is why many firms stay members of XYPN. 

What are some factors that paraplanners should consider when deciding if and when they should start their own RIA?

It really comes down to “Do you want to be a business owner? Do you want to be an entrepreneur? Do you want to be able to own your own firm and serve your own clients?” 

We see a lot of different motivations for why someone starts a business. Maybe they want to be independent. Maybe they want to own the business so they can build the business for themselves instead of for someone else. Maybe they want to be able to work with younger clients and can’t inside their existing firm structure.

There are a lot of reasons why someone wants to start their own RIA, but at its core it’s because they aren’t finding from their existing firm what they need. So, some of the things you’ll say when you know it’s time—you’ll feel frustrated, you’ll feel like you can’t make the decisions you want to make, or work with the clients you want to work with.

It also comes down to personal finances. Are you in a position where you can support yourself starting a business? We generally recommend having 2-3 years of savings in the bank to cover both business and personal expenses. If you don’t have that, perhaps you have a partner who has a pretty stable income and who can support your lifestyle while you’re getting your business going. So, there’s also this financial component of whether or not you’re ready.

I think when deciding if you want to start a business, you need to ask yourself what your motivation is and if starting a business will help you achieve your goals. If so, fantastic. If not, maybe consider switching firms or going to work for an XYPN firm. Many of our advisors are now at a point where they’re hiring their first couple of people, so there are a lot of ground floor opportunities to work inside of an existing firm if starting a business isn’t something you want to do. 

How can I get a CFP to sign off on my CFP hours if I’ve never worked for or with a CFP?

We actually recommend a couple of approaches.

One is look inside your study group. If you aren’t part of a study group and you’re a member of XYPN, contact your MES.

If you aren’t a member, form a study group of advisors and talk about different situations and things you are doing, make review plans together (and remove personal information to protect your clients). Do those types of things together so members of your study group can validate and say “Yes, this advisor is providing financial planning.” 

For a paraplanner coming in with no experience, what is the typical timeline for passing their Series 65 exam, getting their CFP designation, and taking on clients themselves?

For the Series 65, we generally see it takes 2-3 months of studying in order to pass the exam. If you have a background in financial planning, usually about a week of review will suffice. But in general, probably plan on 40-60 study hours.

The CFP certification is a longer process. We generally see it takes around 9-18 months to get through the CFP education requirement and the seven required CFP courses, depending on the program. After you’ve completed your CFP education, expect to spend 3-6 months studying and preparing for the comprehensive exam.

So, I see two years being an average from start to finish of beginning a CFP program to passing the exam. You can certainly do it faster, but you do need three years of work experience to qualify to use the CFP designation anyway, so we don’t often see people are in that much of a rush.

In terms of taking on clients, it’s not always tied to having the CFP designation. It all depends on how fast you can get involved in and get experience with managing client relationships. Some firms require you have your CFP designation first, others don’t. I encourage all young advisors to try and get involved in meetings from day one. Ask the principal of the firm to let you be in on the meetings and take notes, or handle follow-ups, or maybe present analyses to some clients. Take any opportunity to have conversations with clients. 

The only way to learn to be a financial planner is to 1) watch a financial advisor operate and 2) actually dive in and try it yourself, hopefully with oversight.

So, separate from getting the CFP, getting clients comes down to your experience in actually providing financial planning and potentially, depending on the way your firm is set up, your experience in securing clients. Once you are comfortable and confident in your ability to provide the service, it’s all about going out putting in the time and effort to find clients you’re able to work with.

Can you become an RIA and do this part-time, successfully?

This is another area where we’ve had varying levels of success when it comes to starting an RIA part-time. I think there are three ways to start an RIA part-time. You can have a full-time job and start an RIA on the side; you can start an RIA and it be the bulk of what you do, but have a side hustle or side gig to bring in some income; or you can run an RIA but only work part-time.

  1. Full-time job and RIA on the side. If you have a full-time job, starting an RIA on the side is very challenging. We’ve seen very limited success rates with firms that do this. It’s hard to start a business when it’s not your full-time focus. Full-time doesn’t necessarily mean 40-45 hours a week. But when you’re sitting there having a cup of coffee, are you thinking about your new advisory firm or about solving problems for your old/current employer? If you’re employed full-time, you should be thinking about solving problems for your employer because that’s what they’re paying you to do. Starting a business really demands your time and energy, and that can pull away from your current job. We see low success rates when people only commit a couple of hours a week to getting their RIA started.
  2. Starting an RIA with a side hustle. We see greatly increased success rates because the firm is your full-time focus, but there is something else you’re doing to generate income. Bringing in additional income helps support the firm and ease the financial strain while you’re getting it up and running.
  3. Being a part-time firm owner. We do see this too. One of the really cool things about financial planning firms is that you can start your business and run it part-time. We see a lot of parents who want to work 20 hours a week and spend more time with their kids—and they’re running very successful practices because they’ve set a limit on the amount of time they’re going to spend on their business. I often say you can get as much done in 20 hours a week as you can in 40 if you put your mind to it. So, we absolutely see very successful firms built this way. You just need to be intentional about what you’re building, put restraints on your time appropriately, and make sure you have enough time to focus on building the business and getting new clients.

Does Michael own any dress shirts that aren't blue? LOL!

He does...NOT!

Why did you cut the ZZ Top beard?

Simply put, I met a girl.

When I met my now wife, about two weeks into dating she made the comment that my beard “could be done at any time.” So I shaved it in order to maintain our relationship. She has now decided that she likes me better with a beard. So, it’s growing out a little longer every day. 

How much time do you allocate weekly to reading articles and other current information sources? Any recommendations?

Michael spends a lot more time on this than I do. I don’t spend a ton of time on industry reading. My goal is to read a book a week. I’m a little closer to one every two weeks right now. I consume business books, docuseries, or biographies. I consume anything that will help me be a better business owner, a better CEO, a better leader.

I probably spend about 5-6 hours a week, maybe an hour a day, trying to learn and consume information. For me, it comes down to finding that time within time. I listen to books because I don’t have the patience to sit and read. I’ll listen to an audiobook when I’m driving to the ski hill, or when I’m on the ski lift, or when I’m dropping my kids off at school. All that “time within time” really adds up.

Read the first blog in this two-part series, AMA with Alan Moore and Michael Kitces, Part One

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Alan-Moore-Square-ColorAbout the Author
Alan Moore, MS, CFP® is the co-founder of the XY Planning Network, a support network for advisors looking to serve next generation clients. He is also the CEO of AdvicePay, the first and only compliant payment processor for financial advisors. He is passionate about helping financial planners start and grow their own fee-only firms to serve Gen X & Gen Y clients largely ignored by traditional firms. Alan has been recognized by Investment News as a top “40 Under 40″ in financial planning, by Wealth Management as one of a “The 10 to Watch in 2015″, and was the first recipient of the NAPFA Young Professional award in 2015. Alan frequently speaks on topics related to technology, marketing, and business coaching, and has been quoted in publications including The Wall Street Journal, Forbes and The New York Times. He is also the host of XYPN Radio, one of the largest podcasts for independent financial advisors. He currently lives in Bozeman, MT so that he can hit the slopes on powder days.

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