Description of the Advisory Firm
Benchmark Financial Wealth Advisors LLC (herein after “BFWA LLC”) is an independent investment advisory firm
registered with the Securities and Exchange Commission ("SEC") under the Investment Advisers Act of 1940, as
amended. BFWA LLC was organized as a limited liability company under the laws of the State of Florida on February
10, 2017, and has offices in Boca Raton, Sunrise, and Jupiter, Florida. BFWA LLC’s registration with the SEC became
active on July 7, 2017, and is the successor business to Benchmark Financial Group LLC., formed in 2005 and
Benchmark Financial Group, Inc. incorporated in January 1999. The principal owners are Benchmark Financial Group,
Inc, (BFGI) Benchmark Financial Group LLC. (BFGL), and DB Benchmark, LLC. Additional ownership includes minority
owner: Philip Piedt through his holding company MP Holdings Group, LLC. Roger Kalina is the Chief Compliance Officer
and indirectly owns BFWA LLC through BFGI and BFGL. For additional information on the ownership structure of BFWA
LLC please see
https://adviserinfo.sec.gov/ or Investor.gov/CRS (CRD #287966)
Types of Advisory Services
BFWA LLC provides the following services to its clients based on each client's individual needs and circumstances. Most
clients engage BFWA LLC to manage their financial life and provide ongoing wealth guidance and asset management
services. Services for clients may vary based on their personal needs.
Advice is provided through consultations with the client and generally will include the following where applicable to the
relationship: determination of financial goals and objectives, identification of financial concerns, cash flow
management, insurance review, asset management, education funding, retirement and income distribution planning,
estate planning and employer sponsored retirement plan design and implementation. Client relationships vary in scope
and length of service.
WEALTH GUIDANCE/FINANCIAL PLANNING
BFWA LLC provides wealth guidance services for clients with varying needs based on the clients’ current financial status
and determination of financial objectives. All aspects of the client’s financial affairs are reviewed. Realistic and
measurable goals are set and strategies to achieve client’s goals are defined.
The initial consultation, which will be by telephone or in person, is free of charge and used to determine if our services
will be beneficial to the client. Clients can hire BFWA LLC to provide wealth guidance services on a one- time basis or
continually until canceled. A one-time engagement is typically concluded upon the delivery of advice, unless stated
contrary in our agreement with the client.
ASSET MANAGEMENT
Investment advice is an integral part of overall financial planning. BFWA LLC will manage Client’s investment portfolios
on a discretionary or a non-discretionary basis, as part of our ongoing wealth guidance services. We provide investment
strategy, asset allocation, security selection, portfolio monitoring and periodic rebalancing. Prior to the rendering of any
of the foregoing advisory services, clients are required to enter into one or more written agreements with BFWA LLC
setting forth the relevant terms and conditions of the advisory relationship Each client will have an Investment Policy
Statement for their accounts and/or household. Additionally, the client is provided with regular meetings, telephone
consultations, emails, and information regarding market and economic conditions, and internet access to investment
accounts.
Prior to rendering service, BFWA LLC reviews the client’ financial situation, personal goals, investment objectives, risk
tolerance, concerns, and current investment portfolio (if applicable) and makes recommendations to clients regarding
their portfolios. BFWA LLC primarily allocates client assets among various independent investment managers,
independent managers, mutual funds, fixed income securities, real estate funds (including REITs), insurance products
including annuities, equities, hedge funds, private equity funds, ETFs (including ETFs in the gold and precious metal
sectors), commodities, non-U.S. securities, venture capital funds and private placements BFWA LLC will offer certain
Structured Products through Omnibus accounts at participating broker-dealers that will maintain custody of such assets
for the clients. BFWA LLC can use other securities as well to help diversify a portfolio when applicable.
In some circumstances we will provide guidance, education, and limited recommendations on digital/crypto assets. We
will not have any direct trading or access to the client's digital/crypto assets, wallets, or digital/crypto platforms.
BWFA does manage Mutual Funds and ETFs that hold digital/crypto assets. These assets are held by qualified
unaffiliated custodians and traded on traditional exchanges.
Please refer to Item 8 Methods of Analysis, Investment Strategies & Risk of Loss for more information.
USE OF INDEPENDENT MANAGERS
As mentioned above, when appropriate and in accordance with the Investment Plan for a client, BFWA LLC shall
recommend the use of one or more Independent Managers (Manager). Having access to various Managers, and a wide
variety of manager styles, offers clients the opportunity to utilize more than one Manager, if necessary, to meet the
needs and investment objectives of the client. BFWA LLC will usually select or recommend the Manager(s) it deems most
appropriate for the client. Factors that BFWA LLC considers in recommending/selecting Managers generally include the
client’s stated investment objective(s), management style, performance, risk level, reputation, financial strength,
reporting, pricing, and research.
The Manager(s) will generally be granted discretionary trading authority to provide investment supervisory services for
the portfolio.
Under certain circumstances, BFWA LLC retains the authority to terminate the Manager’s relationship or to add new
Managers without specific client consent. In other cases, the client will ultimately select one or more Managers
recommended by BFWA LLC. Fees paid to such Manager(s) are separate from and in addition to the fee assessed by
BFWA LLC.
BFWA LLC evaluates various information about how the independent managers choose to manage client portfolios,
which may include the public disclosure documents, materials supplied by the independent managers
themselves, and
other third-party analyses it believes are reputable. To the extent possible, the firm seeks to assess the independent
managers’ investment strategies, past performance, and risk results in relation to its clients’ individual portfolio
allocations and risk exposure. BFWA LLC also takes into consideration each independent manager’s management style,
returns, reputation, financial strength, reporting, pricing, and research capabilities, among other factors.
On an ongoing basis, BFWA LLC monitors the performance of those accounts being managed by
independent managers.
BFWA LLC seeks to ensure the
independent managers’ strategies and target allocations remain aligned with its clients’
investment objectives and overall best interests.
The specific terms and conditions under which a client engages an independent manger
are set forth in a separate
written agreement between the designated independent manager
and either BFWA LLC or the client. In addition to this
brochure, clients will also receive written disclosure documents of the independent managers
engaged to manage their
assets. BFWA LLC does not receive compensation from any such independent manager.
On an ongoing basis, BFWA LLC monitors the performance of those accounts being managed by independent mangers
BFWA LLC seeks to ensure the independent manger’s strategies and target allocations remain aligned with its clients’
investment objectives and overall best interests.
WEALTH GOVERNANCE SERVICES
BFWA LLC acts as the individual or families “personal chief financial officer”. In addition to our standard wealth
guidance services, at times we will interview and outsource a portion, or all, of the investment management to
independent professional asset managers, who are not affiliated with BFWA LLC. We will assist the client in selecting
managers, monitor the managers on an ongoing basis, and have scheduled meetings with client and investment
managers. Clients are solely responsible for executing any documents required by the investment manager and for
continuously maintaining any subsequent documentation required after the initial investment is made. The manager
will be responsible for the execution of trades. This holistic view of Client’s Assets (Reported assets include those over
which the client does not grant BFWA LLC investment discretion. Such assets are included for informational purposes
only.)
As a convenience to our clients, in addition to reporting on clients’ financial assets, at a client’s request, the client’s
Consolidated Report may also include certain non-financial assets (e.g., real assets). In such instances, we rely on the
client to provide current and accurate price or other valuation information for those assets to be included in the client’s
consolidated account report. We do not independently verify, and expressly disclaim responsibility for, the accuracy of
any non-financial asset values (including any portfolio performance including those values) clients provide to us to
include in their reporting.
Services:
• Document Management and Archiving: Maintain copies of all family document inventory including entity
organization documents, tax documents, a summary of major assets by ownership, key contacts, investment
documents and financial reports, and correspondence.
• Family Governance: Family meeting governance system.
• Education: Provide access to group and individual education programs for family members encompassing a wide
variety of topics, including next-generation education.
• Consolidated Financial Reporting
• Consolidated Net Worth Report
• Consolidated Asset Summary Report
• Consolidated Real Estate Inventory
• Cash Flow Summary
Fees for this service will be documented in the client’s agreement and deducted directly from the account or related
account maintained at the custodian, paid by the client via check, credit card, or bank account. Please contact us with any
questions concerning the fee calculation and deduction method.
EMPLOYER SPONSORED RETIREMENT PLAN SERVICES
BFWA LLC offers (1) Discretionary Investment Management Services, (2) Non-Discretionary Investment Advisory
Services and/or (3) Retirement Plan Consulting Services to employer-sponsored retirement plans and their
participants. Depending on the type of the Plan and the specific arrangement with the plan’s sponsor (Sponsor), we
may provide one or more of these services. Prior to being engaged by the Sponsor, we will provide a copy of this Form
ADV Part 2A along with a copy of our Privacy Policy and Retirement Plan Consulting Agreement (Agreement) that
contains the information required under Sec. 408(b)(2) of the Employee Retirement Income Security Act ("ERISA") as
applicable.
For participant-directed plans, the Agreement authorizes BFWA LLC to deliver one or more of the following
investment-related services as a “fiduciary” under ERISA (as applicable):
• Development and/or review of Investment Policy Statement (IPS)
• Advice concerning or management of Designated Investment Alternatives (DIAs)
• Advice concerning or management of Qualified Default Investment Alternative (QDIA)
• General Participant investment advice. In addition, participants may also hire us for comprehensive personalized
advisory services.
For trustee-directed plans, the Agreement authorizes BFWA LLC to deliver one or more of the following
investment-related services as a fiduciary under ERISA (as applicable):
• Development and/or review of Investment Policy Statement (IPS)
• Advice concerning or management of the plan’s trust account.
To the extent the plan is subject to Title I of ERISA, non-discretionary advice concerning selection of i) DIAs, ii) QDIA, iii)
trust accounts, and iv) participant accounts will be provided as a fiduciary as defined under ERISA Sec. 3(21)(A)(ii).
Discretionary management of i) DIAs, ii) QDIA, and iii) trust accounts will be provided as an investment manager as
defined under ERISA Sec. 3(38) and as a fiduciary as defined under ERISA Sec. 3(21)(A)(i).
Non-discretionary advisory services are designed to allow the Sponsor (or, if applicable, participants) to retain full
discretionary authority or control over plan investments. BFWA LLC will solely be making recommendations, however it
is up to the Sponsor or participant to determine whether to implement the recommendations.
Discretionary management services are designed to allow Sponsor to delegate responsibility for managing, acquiring,
and disposing of plan assets. If the plan is subject to Title I of ERISA, Sec. 402(c)(3) allows Sponsor to delegate
responsibility for selecting, monitoring, and replacing Plan assets to an "investment manager" that meets the
requirements of Section 3(38) of ERISA.
Section 405(d)(1) of ERISA provides that if an investment manager is properly appointed, then "no trustee shall be liable
for the acts or omissions of such investment manager or managers or be under an obligation to invest or otherwise
manage any asset of the plan which is subject to the management of such investment manager." BFWA LLC is registered
as an investment adviser under the Investment Advisers Act of 1940 (the "Act") and acknowledges its fiduciary status to
the ERISA-covered plans in the Agreement. BFWA LLC is, therefore, qualified to serve as an investment manager under
Section 3(38) of ERISA.
For brokerage account plans, the Agreement may also authorize BFWA LLC to provide “execution only” services to
facilitate transactions on behalf of, and at the sole request by, Sponsor (or, if applicable, participants) in a purely
administrative capacity. If BFWA LLC has not agreed to provide investment advice or discretion in the Agreement, it will
not be serving in a fiduciary capacity as that term is defined under ERISA.
The Agreement further authorizes BFWA LLC to provide one or more of the following consulting services designed to
assist the plan sponsor in meeting its fiduciary duties to administer the plan:
• Assist plan sponsor in reviewing objectives and options available through the plan.
• Recommend participant education and communication policies under ERISA 404(c) Service Provider
Support (participant-directed plans only).
• Assist fiduciaries with a process to select, monitor and replace service providers.
• Assist with preparation and review of Requests for Proposals and/or Information.
• Coordinate and assist with covered service provider replacement and conversion.
• Assist the plan committee with monitoring investment performance.
• Facilitate group enrollment meetings and coordinate investment education, as that term is defined in
applicable Department of Labor regulations or official guidance (participant-directed plans only)
From time to time, BFWA LLC may establish a direct client relationship with one or more plan participants
or beneficiaries. Such client relationships develop in various ways, including, without limitation:
• as a result of a decision by the plan participant or beneficiary to purchase services from us not involving the
use of plan assets.
• as part of an individual or family financial plan for which any specific recommendations concerning the
allocation of assets or investment recommendations relating to assets held outside of a plan; or
• through an Individual Retirement Account rollover (IRA Rollover).
In providing these optional services, BFWA LLC may offer employers and employees information on other financial and
retirement products or services. If BFWA LLC is providing Employer-Sponsored Retirement Plan Services it may, when
requested by a participant or beneficiary, arrange to provide services to that participant or beneficiary through a
separate agreement.
When a participant requests assistance with an IRA Rollover from his/her plan to an account advised or managed by
BFWA LLC, we will have a conflict of interest given that our fees are reasonably expected to be higher than those we
would otherwise receive if he/she remained invested in the employer-sponsored plan. For participants invested in plans
which we do not advise, we also have a conflict of interest given that we may not earn any compensation if they remain
invested in their current plan. We will disclose relevant information about the applicable fees charged by us prior to
opening an IRA account. Any decision to affect the rollover or about what to do with the rollover assets remain that of
the plan participant or beneficiary alone.
FIDELITY INSTITUTIONAL WEALTH ADVISORS (FIWA)
Through our relationship with Fidelity Institutional Custody and Clearing, access is provided to Fidelity Institutional
Wealth Advisors, a third-party federally registered investment adviser. The platform itself is referred to as FMAX
(Fidelity Managed Account Exchange). FIWA evaluates independent money managers across multiple asset classes.
Using qualitative and quantitative screens, FIWA develops and provides BFWA LLC with a list of vetted and approved
independent managers.
In addition, FIWA also negotiates lower investment minimums and fees with these independent managers for BFWA
LLC clients. BFWA LLC also takes into consideration each independent managers’ management style, returns,
reputation, financial strength, reporting, pricing, and research capabilities, among other factors.
On an ongoing basis, BFWA LLC monitors the performance of those accounts being managed by independent
Managers. BFWA LLC seeks to ensure the independent Managers’ strategies and target allocations remain aligned
with its clients’ investment objectives and overall best interests.
BFWA LLC works with FIWA using two different investment platforms. The first is the FMAX Unified Managed Account
(UMA) platform. The FMAX UMA platform is an integrated investment platform in which a client’s assets can be
invested in a single custodian across multiple asset classes. On the UMA platform, FMAX provides a list of approved
Managers (i.e., sub-advisors), whose portfolios are implemented by the Managers. After portfolio implementation, the
Managers are responsible for the ongoing trading, tax loss harvesting and rebalancing of client accounts.
The UMA platform has several fee components, BFWA LLC’s investment management fee (which is described in more
detail under
Item 5. Fee Schedule), the fees for the various independent money managers, FMAX platform fee and an
annual minimum account fee. The typical managed account minimum investment ranges from$10,000 for equities and
$250,000 for fixed income. The fees for the independent money managers range from managers range from 25 basis
points (0.25%) to 181 basis points (1.81%). The FMAX fee is a sliding fee calculated based on assets undermanagement
ranging from 22 basis points (0.22%) on the first $250,000 invested on the UMA platform to 12 basis points (0.12%) for
investable assets in excess of $5,000,000. The minimum annual account fee is $65 annually. Currently clients do not
incur custody fees for accounts custodied with Fidelity.
Client assets on the UMA platform are invested by the
independent managers and rebalances between managers are affected by FIWA on a discretionary basis.
In addition to the UMA platform, BFWA LLC works with FIWA through the FMAX separately managed account platform
(SMA), in which client assets are invested in multiple accounts, each managed by an individual money manager that is
responsible for performing their own trading on the account. The SMA platform has several fee components, BFWA
LLC’s investment management fee (which is described in more detail under
Item 5. Fee Schedule), the fees for the
various independent money managers, FMAX platform fee and an annual minimum account fee. The typical managed
account minimum investment ranges from $10,000 for equities and $250,000 for fixed income.
The fees for the independent managers range from 25 basis points (0.25%) to 181 basis points (1.81%). The FMAX fee is
a sliding fee calculated based on assets undermanagement ranging from 22 basis points (0.22%) on the first $250,000
invested on the UMA platform to 12 basis points (0.12%) for investable assets in excess of $5,000,000. The minimum
annual account fee is $65 annually. Currently clients do not incur custody fees for accounts custodied with Fidelity.
ORION PORTFOLIO SOLUTIONS, LLC (OPS)
Through our relationship with Orion Portfolio Solutions, LLC, a third-party federally registered investment adviser. OPS
evaluates independent money managers across multiple asset classes. Using qualitative and quantitative screens, OPS
develops and provides BFWA LLC with a list of vetted and approved independent managers. In addition, OPS also
negotiates lower investment minimums and fees with these independent managers for BFWA LLC clients. BFWA LLC
also takes into consideration each independent managers’ management style, returns, reputation, financial strength,
reporting, pricing, and research capabilities, among other factors.
On an ongoing basis, BFWA LLC monitors the performance of those accounts being managed by independent
managers. BFWA LLC seeks to ensure the independent managers’ strategies and target allocations remain aligned
with its clients’ investment objectives and overall best interests.
BFWA LLC works with OPS using two different investment platforms. The first is the OPS Unified Managed Account
(UMA) platform. The OPS UMA platform is an integrated investment platform in which a client’s assets can be invested
in a single custodian across multiple asset classes. On the UMA platform, OPS provides a list of approved independent
managers (i.e., sub-advisors), whose portfolios are implemented by the independent managers. After portfolio
implementation, the independent managers are responsible for the ongoing trading, tax loss harvesting and
rebalancing of client accounts.
The UMA platform has several fee components, including BFWA LLC’s investment management fee (which is described
in more detail under
Item 5. Fee Schedule) the fees for the various independent Managers, OPS platform fee and a
maintenance fee. The typical managed account minimum investment ranges from $50,000 for equities and $250,000
for fixed income. The fees for the independent Managers range from 0 basis points (for OPS own strategies) to 65 basis
points (0.65%). The OPS fee is a sliding fee calculated based on assets undermanagement ranging from 50 basis points
(0.50%) on the first $50,000 invested on the UMA platform to 13 basis points (0.13%) for investable assets in excess of
$5,000,000. The maintenance fee is $25 annually per independent manager, which is waived for households over
$400,000 in value. Currently clients do not incur custody fees for accounts custodied with Fidelity or Schwab. Client
assets on the UMA platform are invested by the independent Managers and rebalances between managers are
affected by BFWA LLC on a discretionary basis.
In addition to the UMA platform, BFWA LLC works with OPS through a separately managed account platform (SMA), in
which client assets are invested in multiple accounts, each managed by an individual money manager that is
responsible for performing their own trading on the account. The fees include BFWA LLC’s investment management
fee (which is described in more detail under
Item 5. Fee Schedule) the fees for the various independent managers, OPS
platform fee and a maintenance fee. The typical managed account minimum investment ranges from $50,000 for
equities and $250,000 for fixed income. The fees for the independent managers range from 0 basis points (for OPS own
strategies) to 65 basis points (0.65%). The OPS fee is a sliding fee calculated based on assets undermanagement
ranging from 50 basis points (0.50%) on the first $50,000 invested on the UMA platform to 13 basis points (0.13%) for
investable assets in excess of $5,000,000. There currently is no maintenance fee charged annually per account.
Currently clients do not incur custody fees for accounts custodied with Fidelity or Schwab.
ALTERNATIVE INVESTMENTS
When appropriate, in addition to traditional investment vehicles, and in accordance with the client’s Investment Plan,
BFWA LLC may recommend to certain accredited investors real estate, private equity deals and other alternative
investments. These investments may be “Public” or Non-Public”.
An accredited investor, in the context of a natural person, includes anyone who:
• has earned income that exceeded $200,000 (or $300,000 together with a spouse) in each of the prior two
years, and reasonably expects the same for the current year, OR
• has a net worth over $1 million, either alone or together with a spouse (excluding the value of the person’s
primary residence).
• is a natural person with certain professional certifications in good standing such as the Series 7, Series 65 and
Series 82 licenses* (For information on Series Licenses please go to
https://www.finra.org/registration-
examsce/qualification-exams)
• Is a knowledgeable employee of a Private Fund.
For clients for whom such services are suitable, BFWA LLC will provide advice on real estate-related investments and
other private offerings. Services within the scope of such advice include:
• Research
• Due Diligence
• Product Review by the Investment Committee of BFWA LLC
• Client Risk and Suitability Analysis Services
• Investment Monitoring
• Reporting where applicable
There are several alternative investments utilized by BFWA LLC that BFWA LLC has independently vetted. The fees for
these investments vary by fund.
With respect to these investments, BFWA LLC considers a variety of third-party alternative investment platforms,
and/or direct investments with private hedge funds, private equity or debt funds, and other managers providing
structured solutions and alternative assets. We consider these third-parties alternative asset providers.
For some legacy clients prior to June 1st, 2022, BFWA LLC provided an introduction only to the alternative asset
provider. The client made the decision to invest in the alternative asset at their sole discretion. The client entered into
an agreement with the provider directly. BFWA LLC did not receive any compensation for the introduction by the
alternative asset provider.
Since June 1st, 2022, BFWA LLC has been conducting research on the providers and providing our client with
documented recommendations and research. The alternative asset provider research and recommendations are part
of the Wealth Guidance services.
When we conduct research on the platforms or alternative asset providers, we review to ensure the products are
subject to internal committee reviews by the alternative asset providers. Following onboarding, a regular dialogue and
review is maintained with each provider so long as the platform is used. The use of these platforms allows the clients
to have access to alternative investments at meaningfully lower dollar amounts, often starting at $100,000 minimum
investments, than the funds usually require. The management fees and carried interest vary at the fund level.
The reporting of investments from some of the alternative asset providers on the portfolio management platform may
lag as much as one quarter in arrears. For purposes of both quarterly billing and performance reporting, we use fund
valuations as reported by their respective managers, adjusted by subsequent contributions or withdrawals if the
reported valuation is prior to the reporting or billing date. In some cases, the alternative assets are fed into our
portfolio management system. In other cases, the alternative asset provider may provide us with retrieval only access
to view the client’s holdings or the client may provide us with copies of the statements from the alternative provider.
We will charge our fee based on the service being provided as outlined in the client agreement.
BFWA LLC makes recommendations from time to time to accredited investor clients involving other non-Publicly
traded alternative investments from entities or individuals that are also clients of BFWA LLC.
The recommendation poses a conflict of interest as it is in BFWA LLC’s best interest to assist these entities in funding
their investments. BFWA LLC shall disclose this to the clients that are receiving the recommendation, and those clients
are free not to participate or seek an investment outside the management, guidance, or advice of BFWA LLC. As stated
in Item 11 Code of Ethics, BFWEA LLC’s associated persons are allowed to invest in the same securities recommended
to clients. BFWA LLC is not paid a commission or fee for helping the operator fund the deal. BFWA LLC is only paid an
Investment Management, Wealth Guidance or Wealth Governance Fee by the accredited investor client. It is in BFWA
LLC’s best interest that the accredited investor client is invested in products we believe to be best suited for the client.
In addition to full disclosure, BFWA LLC has a fiduciary duty to exercise good faith and act solely in the best interest of
clients and maintains policies and procedures, including a Code of Ethics which requires the interests of clients be
placed ahead of other interests to address this conflict of interest.
ALTERNATIVE INVESTMENT PRICING
Alternative Investments are generally not publicly traded and therefore do not have a daily indication of their fair
market value. It is our policy to use the most recent value provided by either the qualified custodian or issuer, or
operator for reporting and billing purposes. In some cases where no updated valuations are provided, we will use the
investment cost as the valuation until an updated valuation is received. If there is any reason to believe the value may
be lower, it may be necessary to estimate value based on information received until an actual valuation is received.
Most client’s fees are calculated as stated in Item 5 – Fees and Compensation. Where the client is charged a fee based
on a percentage of their assets under advisement, the portion of the fee attributed to the value of the Alternative
Investment may be higher or lower than it would have been had an actual fair market been available and used. BFWA
LLC will adjust the fee upon receipt of the actual value.
Services Limited to Specific Types of Investments
BFWA LLC generally limits its investment advice to equities, mutual funds, fixed income securities, real estate funds
(including REITs), insurance products including annuities, equities, hedge funds, private equity funds, ETFs (including
ETFs in the gold and precious metal sectors, inverse and leveraged ETFs) commodities, non-U.S. securities, venture
capital funds and private placements. BFWA LLC can use other securities as well to help diversify a portfolio when
applicable.
OUTSOURCING OF CERTAIN INVESTMENT OPERATIONS
BFWA LLC works with various third-party service providers, including, among others, Orion, to help support the
operational needs of managing and servicing Client accounts. Authority provided to the outsourced service providers
could include but is not limited to placing transactions with broker-dealers at the direction of BFWA LLC, opening
accounts with Client’s account custodian, and facilitating operational requests on the Client’s behalf based on
instructions provided by associated persons of BFWA LLC. When providing these services, the third- party service
provider acts as an agent of BFWA LLC.
HELD AWAY ASSETS
BFWA LLC provides additional services for accounts where it is not possible for the firm to enact trades through the
usual custodians. BFWA LLC provides services for held-away assets. That is, assets in accounts with a financial institution
or third party other than the primary custodians we work with. BFWA LLC will work with clients who have given us
discretionary authority to place trades in these held away accounts by using an order management system to help
implement tax-efficient asset location and opportunistic rebalancing strategies for the client wherever their assets are
held.
These services may be provided through a third-party platform to help facilitate held away assets such as those in a
defined contribution plan participant account. We are not affiliated with the platform and receive no compensation for
the use of the platform. Once the client has authorized, BFWA LLC can review current allocations and rebalance based
on the client's objectives and risk tolerances.
The fees related to this service are listed in Item 5 - Fees and Compensation and in the client agreement. The client
can expect the same review level as we discuss in Item 13 Review of Accounts in this disclosure.
INSURANCE
BFWA LLC offers guidance on insurance products and can advise certain clients to include insurance as part of their
portfolio and/or offer to place an insurance policy for clients. While BFWA LLC is affiliated with an insurance agency,
Benchmark Financial Insurance Advisors LLC, it does not own, nor is it affiliated with any insurance company or
insurance provider. Additionally, certain employees of BFWA LLC are also licensed as insurance agents. Further, some
insurance product recommendations are not subject to the same fiduciary standard as investment advisors are subject.
Unaffiliated Insurance Activities
To offer our advisory clients additional insurance solutions and research, we have entered into an unaffiliated
membership relationship with DPL Financial Partners, LLC (DPL). DPL is a third-party provider of a platform of insurance
consultancy services to Financial Advisory firms. The DPL platform will allow BWFA to perform insurance-related
research for our advisory clients.
DPL is also a resource to its members regarding insurance products owned by our clients or that our clients are
considering purchasing. DPL provides members access to product marketing support regarding fee-based products that
insurers have agreed to offer to our clients through DPL’s platform. For providing platform services to us, DPL will
receive an annual membership fee from us and a service fee from the insurers that offer their fee-based products
through the platform. These service fees are based on insurance premiums received by the insurers. DPL is a licensed
insurance provider in Florida.
BFWA LLC provides ongoing management and investment advisory services to the clients of DPL, a limited liability
company licensed to sell and service Life Insurance Annuity and Long-Term care policies. DPL shall pay a fee to BWFA
based on the total aggregate fees received by DPL. BFWA LLC and DPL have entered into an agreement to provide these
services on a non-discretionary consultancy basis.
DPL provides Securities offered through The Leaders Group, Inc. Member FINRA / SIPC 26 W. Dry Creek Circle, Suite
800, Littleton, CO 80120 • 303-797-9080. DPL Financial Partners is not affiliated with The Leaders Group, Inc.
For more information about DPL Financial Partners, please go to
https://www.dplfp.com/
The Leaders Group the Leaders Group offers brokerage accounts held at Fidelity-NFS; Mutual Fund and College Savings
funds held directly at multiple fund complexes, Variable and Indexed Annuities and Variable Life
insurance issued by various carriers.
Johnstone Brokerage Services, LLC (JBS) is registered with the Securities and Exchange Commission (SEC) as a securities
broker-dealer and is a member of the Financial Industry Regulatory Authority (FINRA). JBS has an insurance networking
arrangement with DPL Financial Partners (DPL), wherein DPL consults with JBS clients and their IIAs to identify lower
cost or greater benefit alternatives to client existing investments. JBS receives and pays commissions or compensation
directly and indirectly to and from DPL’s recommendations and referrals.
Clients are never obligated or required to purchase insurance products from any of our non-affiliated insurance
relationships or companies and can choose any independent insurance agent or insurance company to purchase
insurance products.
BUSINESS INTRODUCTORY SERVICES
BFWA LLC provides extensive industry connections for expediting the introduction and connection process between
clients and potential business partners and trusted service providers. We typically serve as an intermediary to facilitate
and manage confidential connections between clients for specific business purposes. Business Introductory Services are
provided as part of the relationship with our clients. BFWA LLC does not charge a fee, receive a commission or any
other monetary compensation for these introductory services.
Client Tailored Services and Client Imposed Restrictions
BFWA LLC will tailor a program for each individual client. This will include an interview session to get to know the
client’s specific needs and requirements as well as a strategy that will be executed by BFWA LLC on behalf of the client.
As applicable, BFWA LLC will use model allocations together with a specific set of recommendations for each client
based on their personal restrictions, needs, and targets. Clients can impose restrictions in investing in certain securities
or types of securities in accordance with their values or beliefs. However, if the restrictions prevent BFWA LLC from
properly servicing the client’s account, or if the restrictions would require BFWA LLC to deviate from its standard suite
of services, BFWA LLC reserves the right to end the relationship. BFWA LLC does not participate in a wrap fee program.
Assets Under Management
BFWA LLC has the following assets under management:
Discretionary Non-discretionary Amounts: Date Calculated:
$ 549,017,841 $0 12/31/2023
AUM shall mean assets that are the following:
• Custodied at:
• Fidelity Investments
• Charles Schwab
• Nationwide Advisory
• Held Away at:
• Pontera
• PPS Advisors, Inc
Assets Under Advisement
BFWA LLC has the following assets under advisement which are the Held Away assets not at the primary custodians:
Assets Under Advisement Date Calculated:
$ 205,744,388 12/31/2023
AUA shall mean assets under advisement that are the following:
• Qualified Group Retirement Plans, not custodied at Fidelity Investments or Charles Schwab
• 529 Plans, not custodied at Fidelity Investments or Charles Schwab
• Non-Advisory Annuities