A. Information About the Firm.
Wealth Management Solutions, LLC (“WMS”) has been in business since September 2015. The
principal owners of the Firm are Silver Birch Partners, LLC, which is owned by M. Tanu Happonen,
and M.L. Hopkins & Co., LLC, which is in turn owned by the Martin L. Hopkins Revocable Trust.
B. Types of Advisory Services WMS Offers
WMS provides asset management services, which frequently include financial planning services,
though planning is also offered on a stand-alone basis. We typically work with individuals, families,
trusts, and pension plans, but are available to provide investment advice and financial planning services
to charitable organizations, foundations, and corporations.
Asset Management
When working with a new client, WMS seeks to be a long-term partner in that client’s wealth
preservation and accumulation. Our engagement process begins with gathering information from the
client regarding their current financial circumstances. WMS then reviews this information and provides
to the client a preliminary proposal of recommendations and action items. This may result in the
delivery of a written financial plan, but may also be a brief summary presented to the client, depending
on the specific needs. WMS relies upon the client to inform us whenever they have changes in their
financial situation or investment objectives so we can review advice previously provided and the
client’s investments.
Many of our clients are small business owners, with somewhat complex concerns as to family issues,
estate and tax concerns, and wealth accumulation towards specific goals. This means that a
computer-generated program is not going to meet the client’s needs, and most importantly, will not
allow for the kind of partnership that we believe gives that business owner client the best chance at
reaching their goals. Therefore, the WMS approach is to provide a responsive resource to clients, which
means providing service in the form of thoughtful asset management which requires significant input
at both inception of the relationship and on an ongoing basis from both the client and adviser. We
believe this approach most assists us in developing the customized portfolio required by each client’s
unique goals and objectives.
When we perform asset management services, we do so on a discretionary basis, which means we
communicate with clients regarding changes in circumstances, goals, and objectives, and we do not
seek specific approval of changes to client accounts. Clients can always make deposits or withdrawals,
or place restrictions on the types of investments in an account or portfolio. Because we take discretion
when managing accounts, clients engaging us will be asked to execute a Limited Power of Attorney
(granting us the discretionary authority over the client accounts) as well as an Investment
Management Agreement that outlines the responsibilities of both the client and WMS. Specific
investment changes will be implemented by WMS, or in the case of assets managed by a third-party
manager, by such third-party manager. WMS retains the discretion to hire and fire any third-party
manager without obtaining the client’s consent, if such an action is consistent with the client’s
investment objectives.
Use of Third-Party Managers
For some clients, WMS selects certain Third-Party Managers to actively manage a portion of its
clients’ assets. The specific terms and conditions under which a Third-Party Manager is engaged will
be set forth in a separate written agreement with the designated Third-Party Manager. In addition to
this brochure, clients will also receive the written disclosure documents of the respective Third-Party
Managers engaged to manage their assets. WMS evaluates various information about Third-Party
Managers, which includes the Third-Party Managers’ public disclosure documents, materials supplied
by the Third-Party Managers themselves and other third-party analyses WMS believes are reputable.
To the extent possible, WMS seeks to assess the Third-Party Managers’ investment strategies, past
performance, and risk results in relation to its clients’ individual portfolio allocations and risk
exposure. WMS also takes into consideration each Third-Party Manager’s management style,
returns, reputation, financial strength, reporting, pricing, and research capabilities, among other factors.
WMS continues to provide services relative to the discretionary selection of the Third-Party Managers.
On an ongoing basis, WMS monitors the performance of those accounts being managed by Third-
Party Managers. WMS seeks to ensure that the Third-Party Managers’ strategies and target allocations
remain aligned with its clients’ investment objectives and overall best interests.
Rollover Recommendations
For clients who are participants in a retirement plan, we will evaluate whether it is in their best
interest to “roll over” their plan account to an individual retirement account (“IRA”), move their
assets to a different retirement plan, leave the plan as is, or reallocate the assets in the plan account.
WMS will generally earn a fee if the client elects to rollover the plan account or to contract with
WMS for the provision of investment advice on the plan account assets. This creates a conflict of
interest and an incentive for WMS to recommend a rollover rather than leaving the account as is.
WMS discloses this conflict, advises the client of its fiduciary status, and documents the rationale for
any rollover recommendation.
Other Securities Fees
All fees paid to WMS for investment advisory services are separate and distinct from the fees and
expenses charged by custodians, mutual fund companies and other third parties, including but not
limited to management fees, incentive fees, private fund expenses, mutual fund sales charges and
expenses, and commissions on trades charged by broker dealers.
Financial Planning
For clients with assets under management at WMS in excess of $500,000, financial planning services
are generally offered as part of the asset management process. For clients below that minimum
or clients who do not yet wish to place assets under management, financial planning is offered on a
stand-alone basis,
which means the financial planning services are performed separately, for a separate
and additional fee. Each financial planning engagement involves a review of a number of factors,
which can include life goals, tax status and planning, estate planning, retirement concerns and planning
for education needs. The plan WMS ultimately produces is intended to be a suggested blueprint of
how to meet the goals the client presents. In many cases, the client will then elect to have WMS
provide asset management services, though they are under no obligation to do so.
Non-Investment Consulting/Implementation Services
In some circumstances, WMS provides consulting services requested by the client regarding matters
which do not relate directly to investment advice, such as estate planning, tax planning, insurance, etc.
Neither WMS nor any of its representatives serves as an attorney, accountant, or licensed insurance
agent, and no portion of WMS’s services should be construed as legal, tax, or similar professional
advice. If the client requests, WMS will recommend the services of other professionals for
implementation purposes. Clients are under no obligation to engage the services of any such
recommended professional, retain absolute discretion over all such implementation decisions, and are
free to accept or reject any recommendation from WMS. If a client engages any professional
recommended by WMS and a dispute arises thereafter relative to such engagement, the client must seek
recourse exclusively from and against the engaged professional.
Pension Consulting
Many of our clients are small businesses, and at times, these businesses have retirement plans
established for their employees. Recognizing that part of their fiduciary obligation to their plans is to
ensure that participants have adequate choices to which they may allocate their contributions, plan
sponsors may request that WMS provide assistance. WMS will in these cases assist the plan sponsor
by reviewing the investment options for the plan and recommending a course of action (changing
options or keeping current options). WMS may be engaged to perform this service on an ongoing basis,
or, in some cases, the engagement may be consultative in nature and end after the review and
recommendations are completed. This advice is rendered on a non-discretionary basis, meaning the
plan sponsor is free to accept or reject WMS’ recommendations.
Financial Institution Consulting Services
WMS may contract directly with and receive payments from broker/dealers, insurance companies,
investment companies, and other registered investment advisers to provide investment advisory
consulting services to the clients of those contracted financial institutions. Such contractual
engagements do not include assuming discretionary authority over brokerage accounts or the
monitoring of securities positions. Services offered to financial institution clients may include a general
review of client investments holdings, which may or may not result in a WMS investment adviser
representative making specific securities recommendations or offering general investment advice.
MISCELLANEOUS
WMS recommends that investment accounts be held in custody by Charles Schwab and Co., Inc.
(“Schwab”). Schwab offers enhanced services to independent investment advisors. These services
include custody of securities, trade execution platforms, and access to research not available to the
general public. Schwab is wholly independent from WMS. It is expected that most, if not all,
transactions in a given client account will be cleared through the custodian of that account in its
capacity as a broker-dealer.
Non-Discretionary Service Limitations. Clients that determine to engage WMS on a non-
discretionary investment advisory basis must be willing to accept that WMS cannot effect any account
transactions without obtaining prior verbal consent to any such transaction(s) from the client. Thus, in
the event of a market correction during which the client is unavailable, WMS will be unable to effect
any account transactions (as it would for its discretionary clients) without first obtaining the client’s
verbal consent.
Inverse/Enhanced Market Strategies. WMS may utilize long and short mutual funds and/or exchange
traded funds that are designed to perform in either an: (1) inverse relationship to certain market indices
(at a rate of 1 or more times the inverse [opposite] result of the corresponding index) as an investment
strategy and/or for the purpose of hedging against downside market risk; or (2) enhanced relationship
to certain market indices (at a rate of 1 or more times the actual result of the corresponding index) as
an investment strategy and/or for the purpose of increasing gains in an advancing market. There can be
no assurance that any such strategy will prove profitable or successful. In light of these enhanced
risks/rewards, a client may direct WMS, in writing, not to employ any or all such strategies for their
accounts.
Trade Error Policy. WMS shall reimburse accounts for losses resulting from WMS’s trade errors but
shall not credit accounts for such errors resulting in market gains. The gains and losses are reconciled
within WMS’s custodian firm account.
C. Tailored Advisory Services
WMS provides investment advisory services specific to the needs of each client. Prior to providing
investment advisory services, an investment adviser representative will ascertain each client’s
investment objective(s). Thereafter, WMS will allocate and/or recommend that the client allocate
investment assets consistent with the designated investment objective(s). The client may, at any time,
impose reasonable restrictions, in writing, on WMS’s services.
D. Wrap Program
WMS previously offered a “wrap fee” program, under which WMS included the cost of certain
transactional costs in the client’s management fee. That program has been discontinued and there are
no clients remaining in that program. The separate Wrap Fee Program Brochure has been retired.
E. Assets Under Management
As of December 31, 2023, WMS managed approximately $388,877,348 in assets under management
across 1,803 accounts, all of which are managed on a discretionary basis.