WTFG offers a variety of advisory services, which include financial planning, consulting, and investment
management services. Prior to WTFG rendering any of the foregoing advisory services, clients are required
to enter into one or more written agreements with WTFG setting forth the relevant terms and conditions of
the advisory relationship (the “Advisory Agreement”).
WTFG filed for registration as an investment adviser in November 2017 and has been owned by Douglas
Wells, Ralph Trecaso and Christopher Walters. As of December 31, 2023, WTFG had $482,943,218 in
regulatory assets under management, all of which was managed on a discretionary basis.
While this brochure generally describes the business of WTFG, certain sections also discuss the activities
of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying
a similar status or performing similar functions), employees or any other person who provides investment
advice on WTFG’s behalf and is subject to the Firm’s supervision or control.
Financial Planning and Consulting Services
WTFG offers clients a broad range of financial planning and consulting services, which includes retirement
planning, education planning, trust and estate planning and life insurance needs. While each of these
services is available on a stand-alone basis, certain of them can also be rendered in conjunction with
investment portfolio management as part of a comprehensive wealth management engagement (described
in more detail below).
In performing these services, WTFG is not required to verify any information received from the client or
from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely
on such information. WTFG recommends certain clients engage the Firm for additional related services,
its Supervised Persons in their individual capacities as insurance agents or registered representatives of a
broker-dealer and/or other professionals to implement its recommendations. Clients are advised that a
conflict of interest exists for the Firm to recommend that clients engage WTFG or its affiliates to provide
(or continue to provide) additional services for compensation, including investment management services.
Clients retain absolute discretion over all decisions regarding implementation and are under no obligation
to act upon any of the recommendations made by WTFG under a financial planning or consulting
engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any
change in their financial situation or investment objectives for the purpose of reviewing, evaluating or
revising WTFG’s recommendations and/or services.
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Wealth Management Services
WTFG provides clients with wealth management services which includes financial planning and consulting
services as well as discretionary and/or non-discretionary management of investment portfolios.
WTFG primarily allocates client assets in accordance with their stated investment objectives among various
individual equity and debt securities, along with mutual funds, and exchange-traded funds (“ETFs”). For
certain larger client portfolios, the Firm may also allocate assets to independent investment managers
(“Independent Managers”).
Where appropriate, the Firm also provides advice about any type of legacy position or other investment
held in client portfolios (but clients should not assume that these assets are being continuously monitored
or otherwise advised on by the Firm unless specifically agreed upon). Clients can engage WTFG to manage
and/or advise on certain investment products that are not maintained at their primary custodian, such as
variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and
qualified tuition plans (i.e., 529 plans). In these situations, WTFG directs or recommends the allocation of
client assets among the various investment options available with the product. These assets are generally
maintained at the underwriting insurance company or the custodian designated by the product’s provider.
The Firm’s Supervised Persons can also recommend the purchase of these held away investments in their
capacity as registered representatives as further discuss in this Disclosure Brochure.
WTFG tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a
continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives.
WTFG consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time
horizon, liquidity constraints and other related factors relevant to the management of their portfolios.
Clients are advised to promptly notify WTFG if there are changes in their financial situation or if they wish
to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions
or mandates on the management of their accounts if WTFG determines, in its sole discretion, the conditions
would not materially impact the performance of a management strategy or prove overly burdensome to the
Firm’s management efforts.
Use of Independent Managers
As mentioned above, WTFG selects certain Independent Managers to actively manage a portion of its
clients’ assets. The specific terms and conditions under which a client engages an Independent Manager
may be set forth in a separate written agreement with the designated Independent Manager. That agreement
can be between the Firm and the Independent Manager (often called a subadvisor) or the client and the
Independent Manager (sometimes called a separate account manager). In addition to this brochure, clients
may also receive the written disclosure documents of the respective Independent Managers engaged to
manage their assets. The Independent Manager(s) fees may be included In the Firm's fees, but in certain
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circumstances the Independent Manager(s)' fees are in addition to the Firm's fees. The Firm has an incentive
to select an Independent Manager where the fees are separate from the Firm's. The Firm will ensure that
any recommendation to utilize an Independent Manager is in the best interest of the client regardless of the
fees.
WTFG evaluates a variety of information about Independent Managers, which includes the Independent
Managers’ 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. WTFG also takes into consideration each Independent
Manager’s management style, returns, reputation, financial strength, reporting, pricing and research
capabilities, among other factors.
WTFG continues to provide services relative to the discretionary or non-discretionary selection of the
Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being
managed by Independent Managers. WTFG seeks to ensure the Independent Managers’ strategies and
target allocations remain aligned with its clients’ investment objectives and overall best interests
Retirement Plan Consulting Services
WTFG provides various consulting services to qualified employee benefit plans and their fiduciaries. This
suite of institutional services is designed to assist plan sponsors in structuring, managing and optimizing
their corporate retirement plans. Each engagement is individually negotiated and customized, and includes
any or all of the following services:
• Plan Design and Strategy
• Plan Review and Evaluation
• Executive Planning & Benefits
• Investment Selection
• Plan Fee and Cost Analysis
• Plan Committee Consultation
• Fiduciary and Compliance
• Participant Education
As disclosed in the Advisory Agreement, certain of the foregoing services are provided by WTFG as a
fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In
accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of
WTFG’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the
Firm reasonably expects under the engagement.
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