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Institutional Investment Management:
Independent investment consulting firms can select the Firm’s strategies for their clients that wish to
utilize one or more of the Firm’s investment strategies. The client or the client’s representative will
make the final decision on selecting the Firm and the appropriate strategy for the client.
The Firm is not a custodian of the client’s assets. The client always maintains control of his/her assets
through the independent, third-party custodian selected by the client. WWM’s authority, as defined in
its Investment Advisory Agreement, is to implement investment decisions on behalf of the client
entities.
The client can engage other professionals (e.g. lawyers, accountants, consultants) to assist them in
establishing their financial goals and objectives. The Firm will often meet with the designated parties
to review the appropriateness of the investment strategies employed by WWM, but its role is solely
that of investment manager implementing the client’s investment strategy by buying securities on
his/her behalf.
Use of Third-Party Managers:
We may also, when appropriate, recommend direct investment with independent third-party
managers. Before selecting other advisers, we make sure that the other advisers are properly licensed
or registered. Our IAR’s examine the experience, investment philosophies, and past performance of
independent third-party managers to determine if a manager has demonstrated an ability to invest
over a period and in different economic conditions. They monitor the manager’s holdings, strategies,
and leverage as part of our overall risk assessment. Additionally, as part of their due-diligence process,
the IAR may survey the manager’s compliance and business enterprise risks. The third-party manger
is responsible for managing the assets and the IAR of our firm is responsible for managing the ongoing
relationship with the client and ensuring suitability of investments.
Financial Planning and/or Consulting:
We provide a variety of financial planning and/or consulting services to individuals, families and other
clients regarding the management of their financial resources based upon an analysis of the client’s
current situation, goals, and objectives. Such financial planning services will involve preparing a
financial plan and/or rendering a financial consultation for clients based on the client’s financial goals
and objectives. This planning and/or consulting may encompass one or more of the following areas:
Investment Planning, Divorce Planning, Retirement Planning, 401k Investment Advice, Estate
Planning, Charitable Planning, Education Planning, Corporate and Personal Tax Planning, Cost
Segregation Study, Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance
Analysis, Lines of Credit Evaluation, Business, and Personal Financial Planning.
Our written financial plans and/or financial consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the clients. For example,
recommendations may be made that the clients begin or revise investment programs, create or revise
wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish
education or charitable giving programs. It should also be noted that we refer clients to an accountant,
attorney, or other specialist, as necessary for non-advisory related services. For written financial
planning engagements, we provide our clients with a written summary of their financial situation,
observations, and recommendations. For financial consulting engagements, we usually do not provide
our clients with a written summary of our observations and recommendations as the process is less
formal than our planning service. Plans and/or consultations are usually completed within six (6)
months of the client signing a contract with us, if all the information and documents we request from
the client are provided to us promptly. Implementation of the recommendations will be at the
discretion of the client.
Retirement Plan Consulting:
We provide Retirement Plan Consulting services to employer plan sponsors on an ongoing basis.
Generally, such retirement plan consulting services consist of assisting employer plan sponsors in
establishing, monitoring, and reviewing their company's participant-directed retirement plan. As the
needs of the plan sponsor dictate, areas of advising could include:
• Investment Policy Statement assistance
• Ongoing investment monitoring
• Assistance with changes in investment options
• Performance reports
• Ongoing investment recommendations
• Education services
• Participant education and enrollment
• 404(c) assistance
• Qualified Default Investment Alternative (QDIA) assistance
• Plan search support/vendor analysis
All Retirement Plan Consulting services shall be in compliance with the applicable state law(s)
regulating retirement plan consulting services. This applies to client accounts that are pensions or
other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of
1974, as amended (“ERISA”). If the client accounts are part of a Plan, and we accept appointments to
provide our services to such accounts, we acknowledge that we are a fiduciary within the meaning of
Section 3(21) of ERISA or Section 3(38) of ERISA (but only with respect to the provision of services
described in section 1 of the Retirement Plan Consulting Agreement).
LPL Financial Sponsored Advisory Programs:
Our firm may provide advisory services through certain programs sponsored by LPL Financial (“LPL”),
a registered investment advisor and broker-dealer. Below is a brief description of each LPL advisory
program available to our firm. For more information regarding the LPL programs, including more
information on the advisory services and fees that apply, the types of investments available in the
programs and the potential conflicts of interest presented by the programs, please see the LPL
Financial Form ADV Part 2 or the applicable program’s Appendix 1 (wrap fee program brochure) and
the applicable client agreement.
Optimum Market Portfolios Program (OMP)
OMP offers clients the ability to participate in a professionally managed asset allocation program using
Optimum Funds Class I shares. Under OMP, client will authorize LPL on a discretionary basis to
purchase and sell Optimum Funds pursuant to investment objectives chosen by the client. Advisor will
assist the client in determining the suitability of OMP for the client and assist the client in setting an
appropriate investment objective. Advisor will have discretion to select a mutual fund asset allocation
portfolio designed by LPL consistent with the client’s investment objective. LPL will have discretion to
purchase and sell Optimum Funds pursuant to the portfolio
selected for the client. LPL will also have
authority to rebalance the account if authorization is provided by the client.
A minimum account value of $10,000 is required for OMP.
Personal Wealth Portfolios Program (PWP)
PWP offers clients an asset management account using asset allocation model portfolios designed by
LPL. Advisor will have discretion for selecting the asset allocation model portfolio based on client’s
investment objective. Advisor will also have discretion for selecting third party money managers
(PWP Advisors) or mutual funds within each asset class of the model portfolio. LPL will act as the
overlay portfolio manager on all PWP accounts and will be authorized to purchase and sell on a
discretionary basis mutual funds and equity and fixed income securities.
A minimum account value of $250,000 is required for PWP.
Model Wealth Portfolios Program (MWP)
MWP offers clients a professionally managed mutual fund asset allocation program. Our firm will
obtain the necessary financial data from the client, assist the client in determining the suitability of the
MWP program and assist the client in setting an appropriate investment objective. The Advisor will
initiate the steps necessary to open a MWP account and have discretion to select a model portfolio
designed by LPL’s Research Department consistent with the client’s stated investment objective. LPL’s
Research Department is responsible for selecting the mutual funds within a model portfolio and for
making changes to the mutual funds selected.
The client will authorize LPL to act on a discretionary basis to purchase and sell mutual funds
(including in certain circumstances exchange traded funds) and to liquidate previously purchased
securities. The client will also authorize LPL to effect rebalancing for MWP accounts.
The MWP program makes available model portfolios designed by strategists other than LPL’s
Research Department. Advisor will have discretion to choose among the available models designed by
LPL and outside strategists.
A minimum account value of $10,000 is required for MWP.
Manager Access Select Program (MAS)
MAS provides clients access to the investment advisory services of professional portfolio management
firms for the individual management of client accounts. Advisor will assist client in identifying a third-
party portfolio manager (Portfolio Manager) from a list of Portfolio Managers made available by LPL.
The Portfolio Manager manages client’s assets on a discretionary basis. Advisor will provide initial and
ongoing assistance regarding the Portfolio Manager selection process.
A minimum account value of $50,000 is required for Manager Access Select, however, in certain
instances, the minimum account size may be lower or higher.
Manager Access Network (MAN)
MAN enables high net-worth investors to access a variety of institutional portfolio managers. A broad
range of managers and multiple investment styles are available, including equity, fixed income, asset
classes, mutual funds, exchange traded funds (ETFs), and specialty strategies.
A minimum account value of $100,000 is required for MAN.
Guided Wealth Portfolios Program (GWP)
GWP is an advisor-enhanced robo solution that combines a digital investment platform with access to
a IAR. Investment models are strategically managed by LPL Research on a discretionary basis. The
GWP models use up to nine beta-focused ETFs selected by LPL Research and spread across three major
ETF sponsors to create a diversified portfolio. Future Advisor’s rebalancing and tax-loss harvesting
algorithms are used for comprehensiveness. Advisor reviews suggested portfolio allocations, signs off
on paperwork and reviews and approves any changes that clients make to their profile. LPL Research
strategically manages the GWP Models and rebalancing.
A minimum account value of $5,000 is required for Guided Wealth Portfolios, however, in certain
instances, the minimum account size may be lower or higher.
Conflicts of Interest:
Transactions in LPL advisory program accounts are effected through LPL as the executing broker-
dealer.
Advisor receives compensation because of a client’s participation in an LPL program. Depending on,
among other things, the size of the account, changes in its value over time, the ability to negotiate fees
or commissions, and the number of transactions, the amount of this compensation may be more or
less than what the Advisor would receive if the client participated in other programs, whether through
LPL or another sponsor, or paid separately for investment advice, brokerage, and other services.
Participation in Wrap Fee Programs:
We offer wrap fee programs as further described in Part 2A, Appendix 1 (the “Wrap Fee Program
Brochure”) of our Brochure. Our wrap fee and non-wrap fee accounts are managed on an
individualized basis per the client’s investment objectives, financial goals, risk tolerance, etc. We do not
manage wrap fee accounts in a different fashion than non-wrap fee accounts. As further described in
our Wrap Fee Program Brochure, we receive a portion of the wrap fee for our services.
Assets Under Management:
As of December 31, 2023, we manage $3,161,992,422 on a discretionary basis and $88,110,703 on a
non-discretionary basis for a total of $3,250,103,125 under management.
Comprehensive Portfolio Management:
The maximum annual fee charged for this service will not exceed 3.0% of assets under management.
The details and frequency of each client’s specific billing arrangement is determined by the custodial
platform of choice, and client preferences.
Alternatively, a flat fee, not to exceed 2.5% of assets under management or a negotiated flat rate may
be applied in certain circumstances. Our fees may be negotiable. The exact billing details will be
spelled out in the executed client agreement.
Fees will be automatically deducted from your managed account. Further it is important to note that
our firm assesses fees on all assets held in client accounts including cash and cash equivalents. As part
of this process, you understand and acknowledge the following:
a) Your qualified custodian sends quarterly statements to you showing all disbursements for your
account, including the amount of the advisory fees paid to us.
b) Accounts custodied at LPL will be automatically adjusted for deposits and withdrawals during
the billing period. LPL will calculate and deduct advisory fees for accounts custodied with them.
c) Accounts custodied at Charles Schwab or Fidelity will utilize the fee arrangement specified
on Schedule A of the Comprehensive Portfolio Management Agreement. Our firm will use
Orion Advisor services to calculate fees that Charles Schwab & Co. and/or Fidelity
Investments will deduct from accounts custodied with them;
d) You provide authorization permitting your accounts to be debited by these terms and for us to
be directly paid by these terms.