A. General Description of Company
Facet Wealth Inc. is a corporation formed on August 3, 2016 in the State of
Delaware. Facet became registered as an Investment Adviser in November
2016. Anders Jones serves as Facet’s Chief Executive Officer and Patrick
McKenna serves as Executive Chairperson, and each individually owns more
than 5% of the firm. In addition, Durable Capital Partners through one
investment fund, has an ownership interest of greater than 10% in the firm and
Warburg Pincus, through two investment funds, has an ownership interest of
greater than 25% in the firm.
B. Summary of Investment Advisory Services
FINANCIAL PLANNING AND CONSULTING SERVICES
Facet provides Members with the financial planning and/or consulting
services as designated by the Member. The services provided depend on the
nature and complexity of the Member’s situation and could include some or
all of the following: financial goal setting, portfolio design and asset allocation,
risk tolerance and capacity analysis, investment management, cash flow and
expense planning, debt management and planning, employee benefits
planning, employer stock plan analysis, retirement planning, education
planning, risk management and insurance planning, estate planning and
beneficiary, income tax planning, trust planning, small business planning, and
small business retirement plans.
Prior to engaging Facet to provide financial planning and consulting services,
the Member will be required to enter into a Financial Planning and Consulting
Agreement with Facet setting forth the terms and conditions of the
engagement and describing the scope of the services to be provided. Facet
and the Member will work together to determine the specific suite of services
to be provided. Facet’s financial planning and consulting fees are negotiable,
but generally range from $2,400 to $8,000 per year on a flat fee basis,
depending upon the level and scope of the services required.
The recommendations provided by Facet are focused solely on the individual
needs of the Member. Facet engages in a Member intake process involving
communication with prospective Members and the collection of their
financial information to help determine each Member’s investment objectives
and risk tolerance.
In performing its services, Facet shall not be required to verify any information
received from the Member or from the Member’s other professionals and is
expressly authorized to rely thereon. If requested by the Member, Facet shall
recommend the services of other professionals for implementation purposes.
The Member is under no obligation to engage the services of any such
recommended professional. If the Member engages any such recommended
professional, and a dispute arises thereafter relative to such engagement, the
Member agrees to seek recourse exclusively from and against the engaged
professional/firm.
The Member retains absolute discretion over all such implementation
decisions and is free to accept or reject any recommendation from Facet.
Members are encouraged to renew Facet’s financial planning and consulting
services on an annual basis for the purpose of reviewing and updating
Facet’s previous recommendations and/or services.
It remains the Member’s responsibility to promptly notify Facet if there is ever
any change in their financial situation or investment objectives for the
purposeofreviewing,evaluating,orrevisingFacet’sprevious
recommendations or services.
●Non-Investment Consulting/Implementation Services. For Members,
Facet may provide consulting services regarding non-investment
related matters, such as estate planning, tax planning, insurance, etc. or
direct services such as tax preparation. Any of those services will be
provided under the Financial Planning and Consulting Agreement.
Some services may require a separate agreement with Facet or with
the third party providing those services. Neither Facet, nor any of its
representatives, serves as an attorney and no portion of Facet’s
services should be construed as legal services. Accordingly, Facet does
not prepare estate planning documents. To the extent requested by a
Member, Facet may recommend the services of other professionals for
certain non-investment
implementation purposes (i.e. attorneys,
accountants, insurance, etc.), including certain of Facet’s related
persons in their separate registered capacities as discussed below. The
Member is under no obligation to engage the services of any such
recommended professional. The Member retains absolute discretion
over all such implementation decisions and is free to accept or reject
any recommendation from Facet. No Member is under any obligation to
purchase any securities or insurance commission products from a
representative of Facet. Members are reminded that they may
purchase securities and insurance products recommended by Facet
through other, non-affiliated registered representatives of a custodian
and/or insurance agencies.
●Retirement Plan Rollovers — No Obligation / Potential for Conflict of
Interest. A Member or prospective Member leaving an employer
typically has four options regarding an existing retirement plan (and
may engage in a combination of these options): (i) leave the money in
the former employer’s plan, if permitted, (ii) roll over the assets to the
new employer’s plan, if one is available and rollovers are permitted, (iii)
roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the
account value (which could, depending upon the Member’s age, result
in adverse tax consequences). If Facet recommends that a Member roll
over their retirement plan assets into an account to be managed by
Facet, such a recommendation creates a conflict of interest if Facet will
earn a new (or increase its current) advisory fee as a result of the
rollover. To the extent that Facet recommends that Members roll over
assets from their retirement plan to an IRA managed by Facet, then
Facet represents that it and its investment adviser representatives are
fiduciaries under the Employment Retirement Income Security Act of
1974 (“ERISA”), or the Internal Revenue Code, or both. No Member is
under any obligation to roll over retirement plan assets to an account
managed by Facet. Facet’s Chief Compliance Officer, Christopher
Hufman, remains available to address any questions that a Member or
prospective Member may have regarding the conflict of interest
presented by such rollover recommendation.
●ERISA / IRC Fiduciary Acknowledgment. (i) a participant or beneficiary of
a Plan subject to Title I of ERISA or described in section 4975(e)(1)(A) of
the Internal Revenue Code, with authority to direct the investment of
assets in his or her Plan account or to take a distribution; (ii) the
beneficial owner of an IRA acting on behalf of the IRA
INVESTMENT MANAGEMENT SERVICES
Facet does not generally offer standalone investment management services.
However, the Member can determine to engage Facet to provide
discretionary investment management as part of its financial planning and
consulting services. The list of such services available to a Member will be
denoted on the relevant financial planning and consulting services
agreement.
Prior to accepting discretionary authority over a Member’s assets, Facet
engages in a Member intake process to determine each Member’s
investment objectives and risk tolerance.
C. Tailored Services and Investment Restrictions
Facet shall provide advisory services specific to the needs of each Member.
Prior to providing advisory services, an investment adviser representative will
ascertain each Member’s investment objective(s). Thereafter, Facet shall
recommend that the Member allocate investment assets consistent with the
designated investment objective(s). The Member may, at any time, impose
reasonable restrictions, in writing, on Facet’s services.
D. Wrap Fee Program
Facet does not participate in a wrap fee program.
E. Assets Under Management
As of March 2023, Facet had $2,078,080,182 in assets under management on a
discretionary basis.
Facet considers every aspect of our Member’s financial lives in our approach
to financial planning. We use a metric called Total Financial Life Resources
(TFLR) which includes but is not limited to investments, cash, home equity,
retired debt, and workplace retirement benefits and pensions. As of January
2023, our most recent TFLR calculation is over $15 billion.