Introduction
FWG Investments is a registered investment adviser with its principal place of business in Lexington,
Kentucky. Donald Bentley and Jeffrey Sheppard each now own exactly 50% of FWG Investments, LLC.
Donald Bentley owns his stake in the firm through a limited liability company as does Jeffrey
Sheppard. The transaction closing date was March 4, 2022.
The investment advisory services of FWG Investments are provided to you through an appropriately
licensed and qualified individual who is an investment adviser representative of FWG Investments
(referred to as your investment adviser representative throughout this brochure).
Description of Advisory Services
The following are descriptions of the primary advisory services of FWG Investments. Please
understand that a written agreement, which details the exact terms of the service, must be signed by
you and FWG Investments before we can provide you with the services described below.
Financial Planning Services
FWG Investments offers financial planning services as part of their traditional investment advisory
services, which typically address the following topics:
• Investment Planning,
• Retirement Planning,
• Insurance Planning,
• Tax Planning,
• Education Planning,
• Portfolio Reviews,
• Asset Allocation, and
• Real Estate Planning.
When providing financial planning services, the role of your investment adviser representative is to
find ways to help you understand your overall financial situation and help you set financial
objectives.
Asset Management Services sub-advised by AE Wealth Management
FWG Investments has entered into a sub-advisory agreement with AE Wealth Management, LLC (“AE
Wealth Management”), an SEC registered investment advisor, to provide investment advisory
services to clients. The Program provides clients with the opportunity to establish mutual fund
portfolios, separate account portfolios and managed account portfolios developed by both FWG
Investments and by third party investment managers.
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The primary investment management service we provide is a discretionary asset management
program. Clients participating in this program are generally placed in a model overseen by a
financial professional at our firm and sub-advised by a third-party investment adviser. Under this
program, FWG Investments and any sub-advisers we hire to manage the assets in your account are
authorized to buy and sell investments in the account without asking you in advance. We will
monitor the portfolio's performance on an ongoing and continuous basis, unless otherwise agreed,
and will make adjustments and reallocations as necessary due to changes in market conditions and
your unique circumstances.
Clients have the ability to impose reasonable restrictions and guidelines on investing in certain
securities, types of securities or industry sectors. We expect all such restrictions to be timely
communicated to us. Client restrictions and guidelines could negatively affect investment
performance. Clients must inform us of any changes to their financial circumstances, investment
objectives or risk tolerance, or of any modifications or restrictions that are imposed on the
management of the client's account. In this manner, our firm can better serve clients' needs.
Services provided as sponsor of the Program include technology platforms to support data
reconciliation, performance reporting, fee calculation and billing, research, client database
maintenance, quarterly performance evaluations, models, trading platforms, and other functions
related to the administrative tasks of managing client accounts.
FWG Investments assists clients with the establishment of one or more individual accounts at
National Financial Services through the Fidelity Institutional Wealth Program (collectively referred
to as Fidelity). Clients must appoint FWG Investments and AE Wealth Management, as a sub-adviser,
as their investment advisors of record on the account. The qualified custodian maintains physical
custody of all funds and securities of the account, and you retain all rights of ownership (e.g., right to
withdraw securities or cash, exercise or delegate proxy voting and receive transaction
confirmations) of the account.
Clients will receive continuous investment advice based on your needs and circumstances. Utilizing
tools provided by AE Wealth Management, FWG Investments will determine the suitability of the
asset allocation and investment options for each client. FWG Investments will then assist clients in
allocating their assets among different investment options in the Program and recommend strategies
developed by FWG Investments or by the sub-adviser.
Your accounts may be comprised of equity-based investments determined and selected by FWG
Investments using our standard growth and dividend income strategies. Accounts not being
managed using our own equity-based investment strategies will be managed using one or more
strategies developed by AE Wealth.
Clients will grant FWG Investments discretionary authority with respect to investment and advisory
services provided to Program clients. Additionally, each client will grant AE Wealth Management full
discretionary authority to (i) invest and reinvest the assets in the Program and (ii) retain Model
Managers with respect to all or a part of account assets. This means AE Wealth Management will
have trading authority on your account, which is necessary to trade the recommended investments.
FWG Investments will also direct AE Wealth Management to trade accounts managed using FWG
Investments’ own strategies.
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Although we review the performance of Model Managers, we are only able to select the investment
managers approved by AE Wealth Management. Therefore, we have a conflict of interest because we
do not recommend Model Managers to you if the investment manager is not available through AE
Wealth Management.
We will provide you with a copy of AE Wealth Management’s disclosure brochure which contains a
detailed description of AE Wealth Management
and the services they provide.
Administrative Services Provided by Orion Advisor Services, LLC
To help manage accounts through the AE Wealth Management, we utilize Orion Advisor Services,
LLC (referred to as “Orion”) technology platforms to support data reconciliation, performance
reporting, fee calculation and billing, client database maintenance, quarterly performance
evaluations, and other functions related to the administrative tasks of managing client accounts. Due
to this arrangement, Orion will have access to client accounts, but Orion will not serve as an
investment advisor to our clients. Orion receives a portion of the overall fee charged to our client
accounts.
Non-Managed (Courtesy) Account Services
Upon discretion and final approval by FWG Investments, some clients may be allowed to establish
one or more non-managed (also known as “courtesy”) accounts through Fidelity Investments and
appoint FWG Investments as the investment advisor to the account. While our Firm will be listed as
an investment advisor on a courtesy account; courtesy accounts do not receive ongoing supervision
and monitoring services like those provided to accounts through our Asset Management Services
described above. We do not make any investment recommendations and will not monitor specific
securities or general portfolios for these accounts. The primary purpose of this service is to include
non-managed accounts owned by the client in the performance reports provided by our firm to those
clients. Although we do not provide on-going management services or provide specific investment
recommendations for these accounts, non-managed accounts will be included in the performance
reports that are prepared and provided by FWG Investments.
Clients are solely responsible for initiating all purchase and sale decisions of general securities held
in non-managed accounts. Therefore, clients with courtesy accounts, and not FWG Investments or
any of our employees, will have the exclusive responsibility for the performance and monitoring of
all securities that are purchased for, or held, in the non-managed account.
FWG Investments does not currently charge a fee for this service. However, clients will be required
to enter into a written agreement with FWG Investments, and they will be provided with a copy of
this disclosure brochure prior to establishing a courtesy account.
Newsletters - FWG Investments occasionally prepares general, educational and informational
newsletters. Newsletters are always offered on an impersonal basis and do not focus on the needs of
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a specific individual. We do not charge a subscription or other fee for sending newsletters.
Types of Securities
FWG Investments provides investment advice on the following types of investments:
• Equity Securities (e.g., stocks)
• Exchange Traded Funds (ETFs)
• Fixed Income Securities (e.g., bonds)
• Options Contracts on Securities
• Mutual Funds
• Exchange-listed Securities
• Corporate Debt Securities
• Variable Life Insurance
Although we generally provide advice only on the products previously listed, we reserve the right to
offer advice on any investment product that may be suitable for each client’s specific circumstances,
needs, goals and objectives.
It is not our typical investment strategy to attempt to time the market, but we may increase cash
holdings modestly as deemed appropriate based on your risk tolerance and our expectations of
market behavior. We may modify our investment strategy to accommodate special situations such
as low basis stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles,
or special tax situations.
(Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more
information.)
Tailor Advisory Services to Individual Needs of Clients
FWG Investments advisory services are always provided based on your individual needs. This means,
for example, that when we provide asset management services, you are given the ability to impose
restrictions on the accounts we manage for you, including specific investment selections and sectors.
We work with you on a one-on-one basis through interviews and questionnaires to determine your
investment objectives and suitability information. Our financial planning services are always
provided based on your individual needs. When providing financial planning services, we work with
you on a one-on-one basis through interviews and questionnaires to determine your investment
objectives and suitability information.
We will not enter an investment adviser relationship with a prospective client whose investment
objectives may be considered incompatible with our investment philosophy or strategies or where
the prospective client seeks to impose unduly restrictive investment guidelines.
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Rollover Recommendations
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement
Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing
retirement accounts. The way we make money creates some conflicts with your interests, so
we operate under a special rule that requires us to act in your best interest and not put our
interest ahead of yours.
Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give
prudent advice).
• Never put our financial interests ahead of yours when making recommendations (give loyal
advice).
• Avoid misleading statements about conflicts of interest, fees, and investments.
• Follow policies and procedures designed to ensure that we give advice that is in your best
interest.
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
Client Assets Managed by FWG Investments
FWG Investments has a total of $205,904,853 in regulatory assets under management to report as
of December 31, 2023. All assets are managed on a discretionary basis.