A. Firm Information
Gold Medal Waters, Inc. (“GMW” or the “Advisor”) is a registered investment advisor with the U.S. Securities and
Exchange Commission. GMW is organized as a corporation under the laws of Colorado. GMW was founded in
2004 and is owned and operated by Matthew J. Kelley, CFP® (President and Chief Compliance Officer). This
Disclosure Brochure provides information regarding the qualifications, business practices, and advisory services
provided by GMW.
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. GMW’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more
information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading.
B. Advisory Services Offered
GMW offers investment advisory services to individuals, high net worth individuals, retirement plans, charitable
organizations and corporations or other businesses (each referred to as a “Client”).
Wealth Management Services
GMW may provide Clients with wealth management services, which generally include a broad range of
comprehensive financial planning and consulting services in connection with discretionary and non-discretionary
management of investment portfolios pursuant to the terms of the agreement. Services included in a wealth
management engagement are described below.
Investment Management Services - GMW provides customized investment advisory solutions for its Clients. This
is achieved through continuous personal Client contact and interaction while providing discretionary and non-
discretionary investment management and related advisory services. GMW works closely with each Client to
identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a
portfolio strategy. GMW will then construct a portfolio consisting of mutual funds offered primarily by Dimensional
Fund Advisors LP (“DFA”), or utilize the services of an unaffiliated investment manager to achieve the Client’s
investment goals. In certain instances, the Advisor may also utilize mutual funds from the Vanguard Group, Inc. or
any other family of mutual funds to help the Client meet their needs and objectives. The Advisor may retain certain
legacy investments based on portfolio fit and/or tax considerations.
GMW’s investment strategy is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions
that have been held less than one year to meet the objectives of the Client or due to market conditions. GMW will
construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk
tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types
of investments to be held in their respective portfolio, subject to acceptance by the Advisor. DFA funds are
exclusively made available through a registered investment advisor, therefore a Client may not invest in these
funds in their independent capacity.
GMW evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. GMW may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. The Advisor may recommend employing cash positions as a possible hedge against market movement.
GMW may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or
losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting
of the position[s] in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any
risk deemed unacceptable for the Client’s risk tolerance.
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Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the
assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account
to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or
increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a
retirement account to an account managed by the Advisor.
At no time will GMW accept or maintain custody of a Client’s funds or securities, except for the limited authority as
outlined in Item 15 - Custody. All Client assets will be managed within their designated account[s] at the Custodian,
pursuant to the Client investment advisory agreement. For additional information,
please see Item 12 – Brokerage
Practices.
Use of Independent Managers - GMW will recommend that Clients utilize one or more unaffiliated investment
managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment
portfolio, based on the Client’s needs and objectives. The Advisor will perform initial and ongoing oversight and
due diligence over each Independent Manager to ensure the strategy remains aligned with Clients investment
objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy
recommendations and managing the ongoing Client relationship. The Client will be provided with the Independent
Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures).
Financial Planning Services - Generally, such financial planning services involve preparing a formal financial plan
or rendering a specific financial consultation based on the Client’s financial goals and objectives. Clients may also
engage the Advisor for ongoing financial planning as a separate service, pursuant to a written agreement. This
planning may encompass one or more areas of need, including but not limited to, asset allocation planning, risk
analysis, education planning, cash flow planning, expense planning, emergency fund planning, student loan
planning, disability insurance planning, retirement fund planning, home purchase planning, life insurance planning,
net worth analysis, estate planning, retirement income planning, risk analysis, tax planning, investment planning,
business planning and other areas of a Client’s financial situation.
A financial plan developed for the Client will usually include general recommendations for a course of activity or
specific actions to be taken by the Client. For example, recommendations may be made that the Client start or
revise their investment programs, commence or alter retirement savings, establish education savings and
charitable giving programs.
GMW may also refer Clients to an accountant, attorney or another specialist, as appropriate for their unique
situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s
financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may
not provide a written summary. Plans are typically completed within six months of contract date, assuming all
information and documents requested are provided promptly.
Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing
relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the
Client is under no obligation to implement the transaction through the Advisor.
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Retirement Plan Advisory Services
GMW provides advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan
Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its
fiduciary obligations to the Plan. Each engagement is customized to the needs of the Plan and Plan Sponsor.
Services generally include:
● Plan Participant Enrollment and Education Tracking
● Investment Due Diligence and Oversight
● Ongoing Investment Recommendation and Assistance
● Vendor Analysis
● Investment Policy Statement (“IPS”) Design and Monitoring
● Performance Reporting
● ERISA 404(c) Assistance
● Benchmarking Services
These services may be provided by GMW in their capacity as a fiduciary under the Employee Retirement Income
Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is
provided with a written description of GMW’s fiduciary status, the specific services to be rendered and all direct
and indirect compensation the Advisor reasonably expects under the engagement.
C. Client Account Management
Prior to engaging GMW to provide investment advisory services, each Client is required to enter into one or more
agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the
Client. These services may include:
● Establishing an Investment Strategy – GMW, in connection with the Client, will develop an investment
strategy for the Client that is targeted to achieve the Client’s objectives.
● Asset Allocation – GMW will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation and tolerance for risk for each Client.
● Portfolio Construction – GMW will develop a portfolio for the Client that is intended to meet the stated goals
and objectives of the Client.
● Investment Management and Supervision – GMW will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
GMW does not manage or place Client assets into a wrap fee program. Investment management services are
provided directly by GMW.
E. Assets Under Management
As of March 4, 2024, GMW manages $193,623,148 in Client assets, $185,722,195 of which are managed on a
discretionary basis and $7,900,953 on a non-discretionary basis. Clients may request more current information at
any time by contacting the Advisor.