A. FIRM DESCRIPTION
WT Wealth Management, LLC (“WTWM,” “our firm,” “we,” “us”) is organized as a Wyoming limited
liability company founded in 2013. WTWM is based in Scottsdale, Arizona and has been an SEC-
registered investment adviser since March 2018. WTWM’s current business activity consists of
providing wealth management services, wealth education services, and financial planning to its clients.
The direct owner of WTWM is WesternTrust, L.P., a Delaware limited partnership. John Heilner is the
Chief Investment Officer of WTWM. Jackson Rogers is the Chief Compliance Officer.
B. TYPES OF ADVISORY SERVICES
INVESTMENT ADVISORY SERVICES
WTWM provides discretionary portfolio management services to its clients, based on the specific
needs and objectives of such persons and the suitability of products and services. WTWM shall be
granted full discretion and authority to manage the client’s account. Accordingly, WTWM can perform
various functions without further approval from the client, such as the determination of securities to
be purchased or sold without permission from the client prior to each transaction.
Prior to engaging WTWM to provide any of the investment advisory services, WTWM requires a
written investment management agreement (“IMA”) signed by the client prior to the engagement of
services. The IMA outlines the services and fees the clients will incur pursuant to the IMA with
WTWM.
Upon request, WTWM will create an Investment Policy Statement for each client, which outlines the
client’s current situation (goals, objectives, and risk tolerance levels) and then constructs a plan to
aid in the selection of a portfolio that matches each client’s specific situation. Investment Advisory
Services include, but are not limited to, the following:
• Investment Strategy
• Asset Allocation
• Regular Portfolio Monitoring
• Personal Investment Policy
• Security Selection
As noted, WTWM’s asset management services are designed to offer portfolio construction and
ongoing management of accounts with defined investment strategies to meet the client’s personal
investment goals and objectives. WTWM evaluates each client's current investments regarding risk
tolerance levels and time horizon. Risk tolerance levels may be documented in the Investment Policy
Statement provided to our clients upon request. WTWM is responsible for providing ongoing re-
balancing and continuous monitoring of our clients’ securities holdings. WTWM generally limits its
money management to individual stocks, Exchange Traded Funds (“ETFs”), mutual funds, fixed
income securities, and Real Estate Investment Trusts (“REITs”). WTWM may use other securities
as well to help diversify a portfolio when applicable, and can service annuities, 529 plans, and other
non-custodial accounts.
WEALTH EDUCATION SERVICES
WTWM believes all investors should be encouraged to increase their knowledge, as education is a
key component in empowering our clients to avoid behavioral mistakes that hinder a successful
investing experience. We seek opportunities to teach principles that will enhance each client’s
accumulation, protection and enjoyment of wealth. WTWM believes in transparency and that clients
have the right to ask questions, challenge our beliefs, receive forthright responses, and enjoy honest
discussion about their investment portfolio. There is no fee involved when WTWM provides wealth
education services to its clients and a nominal fee of less than $100 per person per event for those
who are not clients.
In addition to one-on-one discussions with individual clients, WTWM may also conduct wealth
educational events and outings (such as seminars and workshops) on various financial topics for our
clients and the public. Participants can increase their knowledge during these educational events and
ask specific questions by interacting with financial professionals and experts who will instruct such
events.
Sample wealth education topics (whether addressed individually or in seminars and workshops)
might include, but are not limited to:
• Financial Plans
• Estate Planning
• Succession Planning
• Financial Risk
• Asset Allocation Models
• Modern Portfolio Theory
• Investment Strategies
• Real Estate Investing
• Insurance (all types)
• Medicare or Social Security Enrollment and Administration
• Navigating the Affordable Care Act (“Obamacare”) and other healthcare
topics
• Tax Planning and Filing
• Financial Negotiation Skills
PUBLICATIONS
WTWM publishes, on various financial, market or macroeconomic topics, a monthly market update; a
monthly white paper; and other articles or videos. These publications are posted to the
www.wtwealthmanagement.com website and to our social media sites where they are publicly
available at no cost to the reader. WTWM also periodically sends e-mails to its clients and contact
database in response to significant market or business events.
FINANCIAL PLANNING SERVICES
WTWM may provide additional advisory services in the form of financial planning services. These
services are provided on a non-discretionary basis. Financial planning services do not involve the
active management of client accounts, but instead focus on a client’s overall financial situation. If
clients wish to execute their financial plan through WTWM, they may separately engage the
Firm for asset management services, which are provided on a discretionary basis. Financial
planning can be described as helping individuals to determine and set their long-term financial goals
through investments, tax planning, asset allocation, risk management, retirement planning, and other
areas. The role of the financial planner is to find ways to help the client understand his/her overall
financial situation and help the client set financial objectives.
Should the client elect to act on any recommendation made by WTWM, the client is under no obligation
to affect the transaction through the Firm.
C. TAILORED RELATIONSHIPS
WTWM offers the same suite of services to all its clients. The management services and
recommendations offered by WTWM are based on the individual needs of our clients and the
suitability of products and services. Specific client financial plans and their implementation are
dependent upon the client’s Investment Policy Statement which outlines each client’s current
situation (income, objectives, and risk tolerance levels) and is used to construct a client-specific plan
to aid in the selection of a portfolio that matches restrictions, needs, and targets.
Clients may impose restrictions on investing in certain securities or types of securities in accordance
with their values and beliefs. WTWM will make every effort to comply with the wishes of the client
but cannot guarantee absolute adherence due to its use of indexed products, funds, and ETFs that are
controlled by third-party managers.
D. WRAP FEE PROGRAMS
WTWM does not participate in and is not a sponsor of wrap fee programs.
Wrap Fee Programs are arrangements between broker-dealers, investment advisers, banks and
other financial institutions, and affiliated and unaffiliated investment advisers through which the
clients of such firms receive discretionary investment advisory, execution, clearing, and custodial
services in a “bundled” form. In exchange for these “bundled” services, the clients pay an all-inclusive
(or “wrap”) fee determined as a percentage of the assets held in the wrap account.
E. ASSETS UNDER MANAGEMENT
When calculating regulatory assets under management, an Investment Adviser must include the
value of any advisory account over which it exercises continuous and regular advisory or
management services. As of December 31, 2023, WTWM managed $301,248,853 in client assets on a
discretionary basis and $9,856,497 on a non-discretionary basis.
F. SOLICITED OR SUB‐ADVISED SEPARATELY MANAGED ACCOUNTS (SMA)
WTWM provides investment management services to clients facilitated by independent investment
advisors contractually engaged by WTWM (collectively referred to as “Introducing Advisors”).
WTWM may also act as sub-advisor to an unaffiliated independent investment advisor. Under these
arrangements, each account is held at an unaffiliated brokerage firm or custodian, and is registered
to the person, persons, or other entity listed on that firm’s new account forms. All securities are
owned directly by the account’s registered owner or owners. WTWM directs the investment of the
securities on a discretionary basis in the account under a limited power of attorney granted to
WTWM by the client. WTWM is compensated by the investment management fee as detailed in the
contract with the client. The Introducing Advisor receives a fee disclosed in the contract with the
client and may provide continuing financial planning or other services for the client.