Blue Water Wealth, Inc. is an Oregon corporation formed in 2012. The firm has been in business
as an investment advisor since the year of its formation and is registered as an investment advisor
with the SEC. It is 100% owned by Nancy L. Congdon and maintains offices in Portland, Oregon
and Seattle, Washington.
The information contained in this brochure describes our investment advisory services, practices,
and fees. Please refer to the description of each investment advisory service below for information
on how we tailor our services to the needs of our clients. As used throughout this firm brochure,
the words “we,” “our,” “firm,” “BWW,” “Blue Water Wealth,” and “us” refer to Blue Water Wealth,
Inc., and the words “you,” “your,” and “client” refer to you as either a client or prospective client of
our firm.
As a fiduciary, it is our duty to always act in your best interests. This is accomplished in part by
knowing our clients, their unique investment objectives, and overall financial circumstances. We
have established a service-oriented advisory practice with open lines of communication for many
different types of clients to help meet their financial goals, while remaining sensitive to our clients’
unique risk tolerances and time horizons. Working with clients to understand their investment
objectives while educating them about our process facilitates the kind of working relationship our
clients value. A description of our advisory services is as follows:
A. Types of Advisory Services
Financial Planning:
We provide a variety of financial planning services to individuals, families, and other clients
regarding the management of their financial resources based upon an analysis of the client’s
current financial situation, goals, and objectives. Generally, such financial planning services will
involve the preparation and delivery to the client of a written financial plan or other report based
on the client’s financial goals and objectives. This planning may encompass one or more of the
following financial topics, and others, depending on your unique financial situation, assets and
income, employment, tolerance for investment risk, time horizon for investments, investment
objectives, and other factors:
• retirement planning;
• goal funding analysis;
• protection planning;
• strategic asset allocation;
• retirement income planning;
• multi-generational planning;
• charitable/planned giving;
• estate/legacy planning; and
• estate settlement services
The written financial plans, reports, and summaries we provide to clients typically include general
recommendations for a course of activity or specific actions to be taken by the client with respect
to the covered financial topics. For example, recommendations may be made that the client begin
or revise certain investment programs, create or revise wills or trusts, obtain or revise insurance
coverage, commence or alter retirement savings, or establish education savings or charitable giving
programs. The client is provided with a written summary of their financial situation, our
observations, and financial planning recommendations.
Our financial planning services are available either in the form of comprehensive and holistic
financial planning or on a one-time project basis. For comprehensive financial planning
engagements, we will consult with you to obtain an understanding of your unique financial
circumstances, goals, and key areas of financial concern. We will then deliver an initial written
financial plan, report, or summary of observations and recommendations designed to address your
unique situation and needs and meet with you (in person, telephonically and/or by electronic
means) at least once annually thereafter to review your financial plan, report, or summary, track
progress towards your goals, and update our financial recommendations as necessary. We will also
remain reasonably available throughout the course of our relationship to assist you with ad-hoc
financial advice regarding common financial matters or concerns which touch upon the topics
covered in your written financial plan. Comprehensive and holistic financial planning services
automatically renew annually, unless terminated earlier by BWW or the client. In rare instances
where we determine that you have requested ad-hoc financial advice that falls outside the scope
of your financial plan (or which would otherwise entail substantial additional work for our firm),
we reserve the right to charge additional fees.
For one-time financial planning engagements, the client may select a discrete financial topic or
topics upon which they would like to receive our financial advice. One-time engagements are of
limited scope and do not include comprehensive financial planning or the provision of ongoing ad-
hoc financial planning advice. Depending on the number of financial topics selected and their
complexity, we will deliver our advice and recommendations in the form of a written financial plan
or a shorter written report, summary, or checklist reflecting our recommendations. Once the
written plan, report, summary, or checklist is delivered to you the engagement is concluded and
no further update or review of our financial planning advice is provided. We will only update and
review our one-time financial planning advice at your specific request, subject to your payment of
an additional fee and execution of a separate written agreement for these services.
Irrespective of whether you choose a comprehensive and holistic financial planning engagement
or a one-time financial planning engagement, all financial plans and reports are typically completed
and delivered to the client within six (6) months of the client signing a contract with us, assuming
that all the information and documents we request from the client is provided to us promptly.
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Financial planning is a non-discretionary service – you always retain the sole and absolute discretion
to accept or reject any of our financial planning recommendations, in whole or in part. You will be
solely responsible for the implementation of any accepted investment recommendations; for the
determination of the manner, timing, and service providers to be utilized in connection with the
same; and for the ongoing monitoring of your investments and accounts. At your specific request,
and only upon your execution a separate written agreement for investment management services
under our Coordinated Asset Management Program, we will assist you with the implementation
and ongoing monitoring of certain recommended investments. Additional fees will apply. Clients
are never obligated to engage BWW for these additional services and are always free to choose
their preferred service providers for investment implementation. Details regarding the nature of
our Coordinated Asset Management Program are below.
As part of our financial planning services, we may recommend that you engage certain third-party
professionals, for example, attorneys, accountants, and insurance agents. We do not provide any
legal, tax, or accounting advice. Clients may elect to engage any recommended third-party
professionals at their own discretion and risk. We are not liable for the acts, errors or omissions of
any recommended third-party service providers and do not receive any referral fees in connection
with the recommendation of third-party service providers to clients.
Coordinated Asset Management Program:
We offer ongoing discretionary portfolio management services under our Coordinated Asset
Management Program (“CAMP” or the “Program”). CAMP is separate and distinct from our offering
of financial planning services. In this Program, we provide you with investment strategy selection,
portfolio design, investment implementation, and ongoing and regular supervision of your
investment account(s), all of which services are provided in a manner that is consistent with your
unique investment profile. All services under the Program are provided pursuant to a written
advisory agreement (a “CAMP Agreement”) that you will enter with our firm.
You will be required to grant us ongoing and continuous discretionary authority to execute our
investment recommendations within your account without obtaining your approval prior to each
specific transaction. Stated plainly, this means that you authorize us to purchase and sell securities
and instruments in your account(s), arrange for delivery and payment in connection with the
foregoing, and act on your behalf in all other matters necessary or incidental to the management
of your investment account, including monitoring of your assets, all without seeking your approval
for each specific transaction. This authority further includes our ability to hire and fire third party
money managers (“TPMMs”) to manage all or a portion of your assets, and to allocate and
reallocate your assets among the selected TPMMs as we believe to be in your best interests. We
will only exercise our discretionary authority over your account in strict accordance with your
individual needs, stated goals, and investment objectives.
We will consult with you and gather information regarding your financial goals, investment
objectives, risk tolerance, and the time horizon for investments. The information we typically
request during this process will include your current and expected income level, tax information,
investment experience, current portfolio construction/asset allocation, and expected
expenses/liquidity needs, among other items. Based on our analysis of these factors, we will
develop, design, and implement an investment strategy and portfolio within your account held at
an independent qualified custodian (“Custodian”). CAMP client portfolios focus on Sustainable,
Responsible & Impact (“SRI”) investing and typically include a customized selection of individual
stocks, bonds, mutual funds, exchange traded funds (“ETFs”), cash and cash equivalents, and/or
other public and private securities or investments, as appropriate, based on the client’s unique
investment profile and needs.
As referenced above, where appropriate, we may also recommend that certain TPMMs be
engaged for the direct management of all or a portion of your CAMP account. The TPMMs we
recommend may contract with us directly to provide sub-advisory services to your account or may
be accessible to us via the investment platform of your Custodian. In other instances, we may
recommend that a client directly contract with a TPMM. In all cases, you will be provided with the
Form ADV Part 2A (or equivalent disclosures) for any recommended TPMMs at or prior to the
time of the engagement of their services for your account. You may further be required to execute
a separate advisory agreement and/or trading authorization in favor of such TPMMs at the time
of their engagement.
Where TPMMs are engaged to manage your account, we will continue to serve as your primary
advisor, and will act in a co-advisory capacity with respect to any assets managed by the TPMMs.
We will remain responsible for the ongoing monitoring of your TPMM accounts and the
determination of the suitability of the TPMM’s overall investment program. The TPMM shall be
responsible for discretionary portfolio management and all trading decisions and functions related
to the allocated assets. We will implement adjustments to your TPMM allocations and hire and
fire TPMMs as we believe to be appropriate and in your best interests.
Each client’s individual investment strategy is tailored to their specific needs and may include some
or all of the previously mentioned securities or TPMM managed accounts. Each portfolio will be
initially designed to meet a particular investment goal, which we determine to be suitable to the
client’s financial circumstances. Once the appropriate investment strategy and portfolio has been
determined for the client, we will regularly monitor the progress of your account and formally
review it at least annually, rebalancing and/or reallocating your account as necessary, based upon
your individual needs, stated goals, and investment objectives.
B. Tailoring of Advisory Services; Investment Restrictions
Our financial planning and CAMP services are tailored to the unique financial circumstances of
each client. Each client has the opportunity to request reasonable restrictions or limitations on the
types of investments to be held in their portfolio. All such requests must be submitted to BWW in
writing. Restrictions of certain investments may not be possible due to the level of difficulty this
would entail in managing the client’s account. Accordingly, we reserve the right to accept or reject
any client requested investment restriction or limitation that we believe would frustrate our
management of the client’s account.
C. Participation in Wrap Fee Programs
We do not sponsor, recommend, or participate in any wrap fee program(s).
D. Assets under Management
As of December 31, 2023, our firm provided ongoing investment management services to
$317,073,465 of client assets on a discretionary basis and $0 of client assets on a non-
discretionary basis.
Separate and in addition to the foregoing amounts, as of December 31, 2023, we also advised on
$662,270,914 of additional client assets consisting of 401(k) plan assets and other client assets on
which we provide periodic financial planning and investment consulting advice.