Our firm is dedicated to providing individuals and other types of clients with a wide array of
investment advisory services. Our firm is a general partnership formed under the laws of the State of
California in 2016 and an investment adviser since 2017. Our firm is owned by Brickley Wealth
Holding Inc. and Brickley Wealth Investment Inc.
Our firm provides comprehensive portfolio management and financial planning services for many
different types of clients to help meet their financial goals while remaining sensitive to risk tolerance
and time horizons. As a fiduciary, it is our duty to always act in the client’s best interest. This is
accomplished in part by knowing the client. Our firm has established a service-oriented advisory
practice with open lines of communication. Working with clients to understand their investment
objectives while educating them about our process, facilitates the kind of working relationship we
value.
We have a fiduciary duty to exercise good faith and act solely in the best interest of clients and
maintain policies and procedures, including a Code of Ethics which requires the interests of clients
to be placed ahead of our firm or staff interests.
Types of Advisory Services Offered
Comprehensive Portfolio Management:
As part of our Comprehensive Portfolio Management services, Clients will be provided with a
combination of asset management and financial planning or consulting services. This service is
designed to assist clients in meeting their financial goals through the use of a financial plan or
consultation. Our firm conducts meetings with new clients to understand their current financial
situation, existing resources, financial goals, and tolerance for risk (in person, if possible, otherwise
via telephone conference or through electronic communication means). Based on what is learned, an
investment approach is presented to the client that may consist of individual stocks, bonds, Exchange
Traded Funds (“ETFs”), options, mutual funds and other public and private securities or investments.
Once the appropriate portfolio has been determined, portfolios are continuously and regularly
monitored, and if necessary, rebalanced based upon the client’s individual needs, stated goals and
objectives. Upon client request, our firm provides a summary of observations and recommendations
for the planning or consulting aspects of this service.
Retirement Plan Consulting:
Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing
basis. Generally, such 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 may include:
• Establishing an Investment Policy Statement – Our firm will assist in the development of a
statement that summarizes the investment goals and objectives along with the broad
strategies to be employed to meet the objectives.
• Investment Options – Our firm will work with the Plan Sponsor to evaluate existing
investment options and make recommendations for appropriate changes.
ADV Part 2A – Firm Brochure Page 5 Brickley Wealth Management
• Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation
models to aid Participants in developing strategies to meet their investment objectives, time
horizon, financial situation, and tolerance for risk.
• Investment Monitoring – Our firm will monitor the performance of the investments and
notify the client in the event of over/underperformance.
• Participant Education – Our firm will provide opportunities to educate plan participants
about their retirement plan offerings, different investment options, and general guidance on
allocation strategies.
In providing services for retirement plan consulting, our firm does not provide any advisory services
with respect to the following types of assets: real estate (excluding real estate funds and publicly
traded REITS), participant loans, non-publicly traded securities or assets, other illiquid investments,
or brokerage window programs(collectively, “Excluded Assets”). All retirement plan consulting
services shall be in compliance with the applicable state laws regulating retirement consulting
services. This applies to client accounts that are retirement 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 our firm accepts an appointment to provide services to such
accounts, our firm acknowledges its fiduciary standard within the meaning of Section 3(21) or 3(38)
of ERISA as designated by the Retirement Plan Consulting Agreement with respect to the provision
of services described therein.
A client or prospective client leaving an employer typically has four options regarding an existing
retirement plan (and could 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 client’s age, result in adverse tax
consequences).
If we recommend that a client roll over their retirement plan assets into an account to be managed
by us such a recommendation creates a conflict of interest if we will earn an advisory fee on the rolled
over assets, which in most cases will be greater than the fees being paid in a 401K plan or other
retirement plan. No client is under any obligation to rollover retirement plan assets to an account
managed by us.
Referrals to Third Party Money Managers:
Our firm utilizes the services of a third-party money manager for the management of client accounts.
Investment advice and trading of securities will only be offered by or through the chosen third party
money manager. Our firm will not offer advice on any specific securities or other investments in
connection with this service. Prior to referring clients, our firm will provide initial due diligence on third
party money managers and ongoing reviews of their management of client accounts. In order to assist
in the selection of a third-party money manager, our firm will gather client information pertaining to
financial situation, investment objectives, and reasonable restrictions to be imposed upon the
management of the account.
Our firm will contact clients from time to time in order to review their financial situation and
objectives; communicate information to third party money managers as warranted; and, assist the
client in understanding and evaluating the services provided by the third-party money manager.
Clients will be expected to notify our firm of any changes in their financial situation, investment
objectives, or account restrictions that could affect their financial standing.
ADV Part 2A – Firm Brochure Page 6 Brickley Wealth Management
Tailoring of Advisory Services
Our firm offers individualized investment advice to our Comprehensive Portfolio Management
clients. General investment advice will be offered to our Retirement Plan Consulting and Referrals to
Third Party Money Management clients. Each Comprehensive Portfolio Management client has the
opportunity to place reasonable restrictions on the types of investments to be held in the portfolio.
Restrictions on investments in certain securities or types of securities may not be possible due to the
level of difficulty this would entail in managing the account.
Client Directed Transactions
Our firm shall accept client directed transactions as well as manage those assets as part of the clients
billable portfolio. This arrangement will be outlined in the client’s signed advisory agreement.
Further, documentation shall be provided to the client if an advisory fee is waived for a directed
transaction or if our firm will not manage the asset as part of their portfolio.
Some of the directed trades our firm may accept include Environmental Social and Governance (ESG)
trades. Please see Environmental Social and Governance (ESG) in Item 8 below. The client may incur
additional fees associated with certain directed trades, such as higher transactional costs, expense
ratios, and commissions. These other types of fees and expenses are separate from any our advisory
fees charged by our firm or disclosed in Item 5 below. Further, our firm does not receive a portion of
these fees.
Participation in Wrap Fee Programs
Our firm does not offer or sponsor a wrap fee program.
Regulatory Assets Under Management
As of December 31, 2023, our firm manages $720,074,814 on a discretionary basis.