A. The Pillar Wealth Management Program (the “Program”) is an investment advisory
program sponsored by Pillar Wealth Advisors, an independent registered investment
adviser which has been in business since December 2011. For some client engagements,
Pillar Wealth Advisors may operate under the dba name of DGK Financial Advisors
Group.
While this brochure generally describes the business of Pillar Wealth Advisors as it relates
to clients receiving services through the Program, certain sections also describe the
activities of the Firm’s Supervised Persons, which refer to all officers, partners, directors
(or other person occupying a similar status or performing similar functions), employees, or
other persons who provide investment advice on Pillar Wealth Advisors’ behalf and are
subject to the Firm’s supervision.
In addition to the Program, the Firm also offers financial planning, consulting and
investment management services under different arrangements than those described herein.
Information about these services is contained in Pillar Wealth Advisors’ Disclosure
Brochure, which appears as Part 2A of Form ADV.
PILLAR WEALTH MANAGEMENT PROGRAM
The Program is offered as a wrap fee program, which provides clients with the ability to
trade in certain investment products without incurring separate brokerage commissions or
transaction charges in most circumstances. A wrap fee program is considered any
arrangement under which clients receive investment advisory services (which may include
portfolio management or advice concerning the selection of other investment advisers) and
the execution of client transactions for a specified fee or fees not based upon transactions
in their accounts.
Prior to receiving services through the Program, clients are required to enter into a written
agreement with Pillar Wealth Advisors setting forth the relevant terms and conditions of
the advisory relationship (the “Agreement”). Clients must also open a new securities
brokerage account and complete a new account agreement with Charles Schwab & Co.,
Inc. (“Schwab”) or another broker-dealer Pillar Wealth Advisors approves under the
Program (collectively “Financial Institutions”).
At the onset of the Program, clients complete an investor profile describing their individual
investment objectives, liquidity and cash flow needs, time horizon and risk tolerance, as
well as any other factors pertinent to their specific financial situations. After an analysis of
the relevant information, Pillar Wealth Advisors assists its clients in developing an
appropriate strategy for managing their assets. Depending on the engagement, the Firm
may also provide certain financial planning or consulting services, which include any or
all of the following functions, depending on the client engagement:
• Business Planning
• Cash Flow Forecasting
• Asset Allocation
• Retirement Planning
• Education Funding
• Estate Planning
• Financial Statement & Portfolio Reports
• General Analysis & Planning
• Insurance Needs Analysis
• Retirement Plan Analysis
Clients’ investment portfolios are generally managed on a discretionary or non-
discretionary basis by either Pillar Wealth Advisors’ investment adviser representatives or
an independent investment manager (collectively “Independent Managers”), as
recommended or selected by Pillar Wealth Advisors. Pillar Wealth Advisors and/or the
Independent Managers generally allocate clients’ assets among the various investment
products available under the Program, as described further below.
Investment management services are offered through the Program on a fee basis, meaning
that clients pay a single annualized fee based upon assets under management. The Firm
also offers advisory services outside of the Program under different fee arrangements than
those discussed below. In addition, certain of Pillar Wealth Advisors’ Supervised Persons
may also offer insurance products and securities brokerage services under separate
commission-based arrangements.
Asset Based Fees
Pillar Wealth Advisors provides investment management services for an annual fee based
on the amount of assets under the Firm’s management. This fee varies between 25 and 200
basis points (0.25% – 2.00%).
This fee is charged monthly in advance and is derived from the market value of the assets
being managed on the last day of the prior billing period, including the value of any accrued
interest, dividends, and other earnings and income. Please Note: Fees charged by certain
Independent Managers may be subject to different billing schedules and/or arrangements
than those utilized by Pillar Wealth Advisors. Clients are encouraged to carefully review
the Independent Manager’s disclosure brochure and the client’s separate agreement with
the Independent Manager (if applicable) for further details on such Independent Manager’s
billing practices.
In the event assets are deposited into or withdrawn from an account after the inception of
a billing period, the fee payable with respect to those assets is prorated to reflect the change
in portfolio value. For the initial period of service, the fee is calculated on a pro rata basis.
In the event the agreement is terminated, the fee for the final billing period is prorated
through the effective date of the termination and the remaining balance is refunded to the
client, as appropriate. Terminations are subject to the termination provisions contained in
the client agreement with Pillar Wealth Advisors, including a thirty day advance written
notice requirement where applicable. Clients are advised to consult their Pillar Wealth
Advisors agreement for specific termination provisions.
Please Note: Fees shall vary depending upon various objective and subjective factors,
including but not limited to: the amount of assets to be managed; account composition; the
scope and complexity of the engagement; the anticipated number of meetings and servicing
needs; related accounts; future earning capacity; anticipated future additional assets; the
professional(s) rendering the service(s); and negotiations with the client. As a result of
these factors, similarly situated clients could pay different fees, and the services to be
provided by Pillar Wealth Advisors to any particular client could be available from other
advisers at lower fees.
Conflict of Interest: Because Pillar Wealth
Advisors pays wrap program transaction fees
and/or commissions to the account custodian/broker-dealer, it has an economic incentive
to minimize the number of trades in client accounts.
The Firm’s Agreement and the separate agreement with any Financial Institutions generally
authorize Pillar Wealth Advisors and/or the Independent Managers to debit its clients’
accounts for the amount of the Program fee and to directly remit that fee to Pillar Wealth
Advisors or the Independent Managers. Any Financial Institutions that serve as qualified
custodian for Pillar Wealth Advisors’ client accounts have agreed to send statements to
clients not less than quarterly indicating all amounts disbursed from the account, including
the amount of Program fees paid directly to Pillar Wealth Advisors.
Clients may make additions to and withdrawals from their account at any time, subject to
Pillar Wealth Advisors’ right to terminate an account. Additions may be in cash or
securities provided that the Firm reserves the right to liquidate any transferred securities or
decline to accept particular securities into a client’s account. Clients may withdraw account
assets on notice to Pillar Wealth Advisors, subject to the usual and customary securities
settlement procedures. However, Pillar Wealth Advisors designs its portfolios as long-term
investments and the withdrawal of assets may impair the achievement of a client’s
investment objectives. Pillar Wealth Advisors consults with its clients about the options
and implications of transferring securities as necessary. Clients are advised that when
transferred securities are liquidated, they may be subject to transaction fees, fees assessed
at the mutual fund level (i.e. contingent deferred sales charge) and/or tax ramifications.
A portion of the fees paid to Pillar Wealth Advisors and/or any engaged Independent
Manager(s) is used to cover the securities brokerage commissions and transactional costs
attributed to the management of its clients’ portfolios. In the event Independent Manager(s)
are engaged to manage a client account, the fee paid to such Independent Manager(s) is
separate from and in addition to Pillar Wealth Advisors’ fee set forth herein.
B. The number of transactions made in clients’ accounts, as well as the commissions charged
for each transaction, determines the relative cost of the Program versus paying for
execution on a per transaction basis and paying a separate fee for advisory services. In
arrangements wherein the Firm pays for such transaction fees (as opposed to engaged
Independent Manager(s) paying such fees), the Firm has an incentive to engage in fewer
transactions, or transactions that cost less to the Firm.
Clients who wish to engage Pillar Wealth Advisors for investment management services
must be willing to accept that these services are only provided on a wrap fee basis. Except
in very rare instances, Pillar Wealth Advisors does not provide its investment management
on a non-wrap fee basis. Clients are also advised that transaction costs paid by Pillar Wealth
Advisors in wrap fee engagements can be materially impacted by changes to the transaction
fee practices of the wrap fee program broker-dealer/custodian. A reduction in transaction
costs incurred results in Pillar Wealth Advisors retaining a greater portion of the total wrap
fee paid by the client. These transaction fee practices are established and maintained at the
sole discretion of the broker-dealer/custodian. Clients are encouraged to review the wrap
fee program broker-dealer/custodian’s commission and transaction fee pricing guide, as
well as the volume of trading activity and asset types traded in their wrap fee program
account(s), to guide their evaluation of the value of the wrap fee services provided by Pillar
Wealth Advisors.
Please Note: Participation in the Program may cost more or less than purchasing such
services separately. The Program fee charged by Pillar Wealth Advisors for participation
in the Program may be higher or lower than those charged by other sponsors of comparable
wrap fee programs.
C. In addition to the Program fee, Clients incur certain charges imposed by third parties in
addition to the Program fee. These additional charges may include fees charged by engaged
Independent Manager(s), mark-ups and mark-downs for fixed-income transactions,
charges imposed directly by a mutual fund or exchange-traded fund (“ETF”) in the account,
as disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses),
fees and expenses associated with alternative investments, margin costs, reporting charges,
fees and commission for assets not held with Schwab (such as 401(k) or 529 plan assets),
fees for trades executed away from Schwab, deferred sales charges, odd-lot differentials,
transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage
accounts and securities transactions.
D. Pillar Wealth Advisors has no internal arrangements in place whereby persons
recommending the Program are entitled to receive additional compensation as a result of
clients’ participation.
MISCELLANEOUS
Client Responsibilities: In performing any of its services, Pillar Wealth Advisors shall not
be required to verify any information received from the client or from the client’s other
professionals, and is expressly authorized to rely thereon. Furthermore, unless the client
indicates to the contrary, Pillar Wealth Advisors shall assume that there are no restrictions
on its services, other than to manage the account in accordance with the client’s designated
investment objective. Moreover, it remains each client’s responsibility to promptly
notify Pillar Wealth Advisors if there is ever any change in his/her/its financial
situation or investment objectives for the purpose of reviewing/evaluating/revising
Pillar Wealth Advisors’ previous recommendations and/or services.
Please Note: Investment Performance: As a condition to participating in the Program,
the participant must accept that past performance may not be indicative of future results,
and understand that the future performance of any specific investment or investment
strategy (including the investments and/or investment strategies purchased and/or
undertaken by Pillar Wealth Advisors) may not: (1) achieve their intended objective; (2)
be profitable; or, (3) equal historical performance level(s) or any other performance
level(s).