Description of Firm Bridgewealth Advisory Group, LLC ("Bridgewealth", "Firm" or "Company") manages assets for 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.
Our firm sponsors and offers a wrap fee program, which allows clients to pay a single fee for investment advisory services and associated custodial transaction costs. Transaction fees are paid by our firm via individual transaction charges and not by you. Because our firm absorbs these client transaction fees, an incentive exists for us to limit trading activities in client accounts. We do not offer a non-wrap account where clients pay the custodial transaction costs.
Depending on your account or portfolio trading activity, you may pay more or less by using our wrap fee services than you would pay if using a non-wrap account.
Regulatory Assets Under Management As of December 31, 2023, we provide continuous management services for $530,126,567 in client assets on a discretionary basis.
A. Our Wrap Advisory Services Comprehensive Portfolio Management Wrap Program ("Wrap Fee Program") We offer discretionary portfolio management services through our Wrap Fee Program. Our investment advice is tailored to meet our clients' needs and investment objectives.
As part of our portfolio management services, in addition to other types of investments (see disclosures below in this section), we will invest your assets according to one or more model portfolios developed by our firm. These models are designed for investors with varying degrees of risk tolerance ranging from a more aggressive investment strategy to a more conservative investment approach. Financial Planning Clients participating in the Wrap Comprehensive Portfolio Management Program also receive financial planning. Based upon an analysis of current situation, goals, and objectives, financial planning services will typically involve preparing a financial plan or rendering a financial consultation for clients based on the client's financial goals and objectives. This planning or consulting may encompass investment planning, retirement planning, estate planning, charitable planning, education planning, corporate and personal tax planning, cost segregation study, corporate structure, real estate analysis, mortgage/debt analysis, insurance analysis, lines of credit evaluation, or business and personal financial planning.
Written financial plans or financial consultations rendered to clients usually include general recommendations for a course of activity or specific actions to be taken by the clients. Implementation of the recommendations will be at the discretion of the client. Our firm provides clients with a summary of their financial situation, and observations for financial planning engagements. Financial consultations are not typically accompanied by a written summary of observations and recommendations, as the process is less formal than the planning service. Assuming that all the 4 information and documents requested from the client are provided promptly, plans or consultations are typically completed within 6 months of the client signing a contract with our firm. Clients are under no obligation to use our firm, or its representatives, for the implementation of any part of the financial plan.
Program Fee Our annual fee for the Wrap Fee Program does not exceed 1.75% ("Program" or "Advisory" Fee) depending upon the market value of your assets under our management and the type and complexity of the asset management services provided. Assets in each of your advisory accounts are included in the fee assessment unless specifically identified in writing for exclusion. Our annual Program Fee is billed and payable, quarterly in arrears, based on the balance at end of billing period. The specific fee we agree on is outlined in your Portfolio Management Agreement.
Program fees are calculated based on the exact number of days in the quarter. For example a client with a fee of 1% and an account value of $500,000 will pay fees for the second quarter (91 days) based on the following calculation: ((500,000 X 1%) / 365) * 91 = $1246.58.
The fees charged are calculated as described above, and are not charged on the basis of a share of capital gains upon, or capital appreciation of, the funds, or any portion of the funds of an advisory Client (15 U.S.C.§80b-5(a)(1)). Our fees are negotiable at our discretion. Fees are based on such things as the overall complexity of your financial situation and your financial planning, as well as the account value and number of accounts. A portion of the fee received is paid to your financial professional. The cost for financial planning is included in the Program Fee you pay to us on a quarterly basis.
B. Wrap Programs May Cost you More Participation in a wrap program may cost you more or less than purchasing the services separately and paying transaction/trading costs in addition to an Program Fee. C. Other Costs Not Included in Your Program Fee The Program Fee includes the costs of brokerage commissions for transactions executed through the Qualified Custodian (or a broker-dealer designated by the Qualified Custodian), and charges relating to the settlement, clearance, or custody of securities in the Account. The Program Fee does not include mark-ups and mark-downs, dealer spreads or other costs associated with the purchase or sale of securities, interest, taxes, or other costs, such as national securities exchange fees, charges for transactions not executed through the Qualified Custodian, costs associated with exchanging currencies, wire transfer fees, or other fees required by law or imposed by third parties. The Account will be responsible for these additional fees and expenses.
In addition to our Program Fees above, clients also pay charges imposed directly by a mutual fund, index fund, or ETF as disclosed in the fund's prospectus. These are typically fund management fees, initial or deferred sales charges, mutual fund sales loads, 12b-1 fees, surrender charges, and other fund expenses. In addition, the custodian may charge

mark-ups and mark-downs, spreads paid to market makers, fees for trades executed away from custodian, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. Our firm does not receive a portion of these fees. You will also pay annual account fees for some accounts such as IRAs or retirement accounts.
Upon account opening, you will receive a list of fees from PAS. You should retain this list for future reference.
5 D. Compensation is Shared with your Financial Professional Your financial professional will receive a portion of the fee you pay to us. As a client, you should be aware that the wrap fee charged by our firm may be higher (or lower) than those charged by others in the industry, and that it may be possible to obtain the same or similar services from other firms at lower (or higher) rates. A client may be able to obtain some or all of the types of services available through our firm's wrap fee program on an individual basis through other firms and, depending on the circumstances, the aggregate of any separately paid fees may be lower or higher than the annual fees shown above. This presents a conflict of interest as your financial professional may earn more than if a non-wrap account option was presented.
Termination of Advisory Agreements Subject to the terms of any Wrap Fee Program Agreement ("Agreement"), the Agreement may be terminated by the Client or us upon written notice to the other. If the Agreement is terminated after the effective date, any prepaid, but unearned Advisory Fees for the final calendar period of the Agreement shall be prorated based on the number of days the Agreement was in effect during such calendar period. The prepaid, unearned portion of the Advisory Fees, if any, shall be refunded to Client within 30 days. Any earned but unpaid Advisory Fees owed to Bridgewealth will become immediately due and payable upon termination of the Agreement.
After an Agreement has been terminated, Client will be charged commissions, sales charges, and transaction, clearance, settlement, and custodial charges, at prevailing rates, by the Custodian and any executing or carrying broker-dealer. Client will be responsible for monitoring all transactions and assets, and Bridgewealth has no obligation to monitor or make recommendations with respect to any account or assets.
Types of Investments Managed accounts are invested in a portfolio allocated among various asset classes as appropriate for your financial situation. The investment types include mutual funds, money market funds, closed-end funds, exchange-traded funds ("ETFs"), common and preferred stocks, real estate investment trusts ("REITs"), business development companies, non-traded closed end funds, and direct obligations issued or guaranteed by the U.S. Treasury, government agencies, or government sponsored entities. If appropriate, "sweep" arrangements are used where cash balances are transferred into money market funds. money market deposit accounts, or bank accounts for cash management purposes, which may be advised by or maintained with the account's qualified custodian ("Custodian") or an affiliate of the Custodian. Not all investment types are appropriate for all clients and selections are made based on the client's individual risk tolerance, investment objectives, investment experience and their financial situation and goals.
In addition, we sometimes offer interval funds as a suitable investment for some clients. These funds impose liquidity restrictions and offer periodic repurchase options to their shareholders of three, six or twelve months. Investment Discretion For clients in our Wrap Fee Program, Bridgewealth must be provided with investment discretion on behalf of the client, pursuant to an executed advisory agreement and any documentation required by the selected Custodian. By granting investment discretion, our firm is authorized to execute securities transactions, determine which securities, and the amount of those securities, that will be bought and sold. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm, a power of attorney, or trading authorization forms from the Custodian.
6 Custodian for Wrap Accounts We recommend the brokerage and custodial services of Pershing Advisor Solutions LLC ("PAS" or "Custodian"). Per SEC regulations, your assets must be maintained in an account at a "qualified custodian," generally a broker-dealer or bank. PAS meets these requirements to serve as a qualified custodian. In recognition of the value of the services the Custodian provides, you may pay higher account costs than those available elsewhere. Our selection of PAS is based on many factors, including the level of services provided, the custodian's financial stability, and the cost of services provided by the custodian to our clients, which includes the yield on cash sweep choices, commissions, custody fees and other fees or expenses.
While you are free to choose any broker-dealer or other service provider as your custodian, we recommend that you establish an account with PAS. We may not be able to manage your investments if you select another custodian. PAS provides benefits to our firm, including but not limited to market information and administrative services that help our firm manage client accounts. We believe that PAS provides quality execution services for our clients at competitive prices but do not rely on price as the sole factor for our consideration in evaluating best execution. We also consider the quality of the brokerage services provided by PAS, including the value of the firm's reputation, execution capabilities, commission rates, and responsiveness to our clients and our firm. In recognition of the value of the services provided by PAS, you may pay higher commissions and/or trading costs than those that may be available elsewhere.
Account Reviews We send quarterly reports to some clients. Verbal reports to clients take place on at least an annual basis when our wrap account clients are contacted. In addition, clients have the ability to sign into their client portal on Black Diamond to view reports provided by Bridgewealth.
We strongly suggest meeting in-person, on the telephone, or via electronic means at least once a year to review your accounts together, learn if your financial situation has changed, and to determine if changes need made to your current holdings. We realize that some clients prefer to meet less frequently.