Description of Firm
Scissortail Wealth Management, LLC (“Scissortail”, the/our “firm”, or the “Advisor”) is a registered
investment adviser based in Tulsa, Oklahoma with a branch office in Oklahoma City. We are
organized as a limited liability company ("LLC") under the laws of the State of Oklahoma. We have
been providing investment advisory services since November 9, 2018. We are owned by Richard Leo
Howard, Jr. and Todd C. Welsh.
As used in this brochure, the words "we," "our," and "us" refer to Scissortail Wealth Management,
LLC and the words "you," "your," and "client" refer to you as either a client or prospective client of our
firm. Also, you may see the term Associated Person in this brochure. Our Associated Persons are our
firm's officers, employees, and all individuals providing investment advice on behalf of our firm.
We offer portfolio management services through a wrap-fee program ("Program") as described in this
wrap fee program brochure to prospective and existing clients. We are the sponsor and investment
adviser for the Program. A wrap-fee program is a type of investment program that provides clients with
asset management and brokerage services for one all-inclusive fee. If you participate in our wrap fee
program, you will pay our firm a single fee, which includes money management fees, certain
transaction costs, and custodial and administrative costs. You are not charged separate fees for the
respective components of the total services. We receive a portion of the wrap fee for our services. The
overall cost you will incur if you participate in our wrap fee program may be higher or lower than you
might incur by separately purchasing the types of securities available in the Program.
Prior to becoming a client under the Program, you will be required to enter into a separate written
agreement with us that sets forth the terms and conditions of the engagement and describes the scope
of the services to be provided, and the fees to be paid.
Client Investment Process
We provide discretionary and non-discretionary portfolio management services in accordance with
your individual investment objectives. If you participate in our discretionary portfolio management
services, we require you to grant our firm discretionary authority to manage your account. Subject to a
grant of discretionary authorization, we have the authority and responsibility to formulate investment
strategies on your behalf. Discretionary authorization will allow us to determine the specific securities,
and the amount of securities, to be purchased or sold for your account without obtaining your approval
prior to each transaction. We will also have discretion over the broker or dealer to be used for
securities transactions, and over the commission rates to be paid. Discretionary authority is typically
granted by the investment advisory agreement you sign with our firm and/or through trading
authorization forms. You may limit our discretionary authority (for example, limiting the types of
securities that can be purchased for your account) by providing our firm with your restrictions and
guidelines in writing.
This Program allows you to choose an investment option that employs a model portfolio developed by
our firm that is diversified among investment styles and/or asset classes. We will use the information
we gather to develop a strategy that enables our firm to customize an investment portfolio for you in
accordance with your risk tolerance and investment objectives. Once we construct an investment
portfolio for you, or select a model portfolio, we will monitor your portfolio's performance and re-
balance your investments as required by changes in market conditions and in your financial
circumstances.
If you enter into non-discretionary arrangements with our firm, we must obtain your approval prior to
executing any transactions on behalf of your account. You have an unrestricted right to decline to
implement any advice provided by our firm on a non-discretionary basis.
Assets for program accounts are held at Raymond James & Associates, Inc. as custodian. Level Four
Financial, LLC acts as executing broker/dealer for transactions placed in Program accounts, and
provides other administrative services as described throughout this Brochure. To compare the cost of
the wrap fee program with non-wrap fee portfolio management services, you should consider the
frequency of trading activity associated with our investment strategies and the brokerage commissions
charged by Level Four Financial, LLC and the advisory fees charged by investment advisers.
Changes in Your Financial Circumstances
In providing the contracted services, we are not required to verify any information we receive from you
or from your other professionals (e.g., attorney, accountant, etc.) and we are expressly authorized to
rely on the information you provide. Furthermore, unless you indicate to the contrary, we shall assume
that there are no restrictions on our services, other than to manage your account in accordance with
your designated investment objectives. It is responsibility to promptly notify us if there are ever any
changes in your financial situation or investment objectives for the purpose of
reviewing/evaluating/revising our previous recommendations and/or services.
Rollover Recommendations
As part of our investment advisory services to you, we may recommend that you withdraw the assets
from your employer's retirement plan and roll the assets over to an individual retirement account
("IRA") that we will manage on your behalf. If you elect to roll the assets to an IRA that is subject to
our management, we will charge you an asset-based fee as set forth in the agreement you executed
with our firm. This practice presents a conflict of interest because persons providing investment
advice on our behalf have an incentive to recommend a rollover to you for the purpose of generating
fee-based compensation rather than solely based on your needs. You are under no obligation,
contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are
under no obligation to have the assets in an IRA managed by our firm.
Many employers permit former employees to keep their retirement assets in their company plan. Also,
current employees can sometimes move assets out of their company plan before they retire or
change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following
options are available, you should consider the costs and benefits of: 1)) Leaving the funds in your
employer's (former employer's) plan; 2) moving the funds to a new employer's retirement plan; 3)
cashing out and taking a taxable distribution from the plan; and/or 4) rolling the funds into an IRA
rollover account. Each of these options has advantages and disadvantages and before making a
change we encourage you to speak with your CPA and/or tax attorney. Our recommendations may
include any of them, depending on what we feel is in your best interest.
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice
to you regarding your retirement plan account or individual retirement account, we are also 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. As a fiduciary, we are
required to document the reason(s) for why the recommendation we made is in your best interest.
The Program Fee
We charge an annual "wrap-fee" for participation in the Program depending upon the market value of
your assets under our management. You are not charged separate fees for the different components
of the services provided by the Program. Our firm pays all trade expenses of trades placed on your
behalf. Our Program fee includes the fee we pay to any portfolio manager for their management of
your account and our Custodians transaction or execution costs. Assets in each of your account(s) are
included in the fee assessment unless specifically identified in writing for exclusion. In special
circumstances, and in our sole discretion, we may negotiate a lesser management fee based upon
certain criteria (i.e., anticipated future earning capacity, dollar amount of assets to be managed,
related accounts, account composition, pre-existing client relationship, account retention, etc.).
Our annual portfolio management fee is billed and payable quarterly in advance and is based on the
account average daily balance.
If the portfolio management agreement is executed
at any time other than the first day of a calendar
quarter, our fees will apply on a pro rata basis, which means that the advisory fee is payable in
proportion to the number of days in the quarter for which you are a client. Our advisory fee is
negotiable, depending on individual client circumstances.
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.
At our discretion, we may combine the account values of family members living in the same household
to determine the applicable advisory fee. For example, we may combine account values for you and
your minor children, joint accounts with your spouse, and other types of related accounts. Combining
account values may increase the asset total, which may result in your paying a reduced advisory fee
based on the available breakpoints in our fee schedule stated above.
Withdrawal of Assets
You may withdraw account assets on notice to our firm, and subject to the usual and customary
securities settlement procedures. However, we design our portfolios as long-term investments and
asset withdrawals may impair the achievement of your specific investment objectives.
Payment of Fees
We will deduct our fee directly from your account through the qualified custodian holding your funds
and securities. We will deduct our advisory fee only when you have given our firm written authorization
permitting the fees to be paid directly from your account. Further, the qualified custodian will deliver an
account statement to you at least quarterly. These account statements will show all disbursements
from your account. You should review all statements for accuracy.
Termination of Advisory Relationship
You may terminate the wrap fee program agreement upon written notification our firm. You will incur a
pro rata charge for services rendered prior to the termination of the wrap fee program agreement,
which means you will incur advisory fees only in proportion to the number of days in the quarter for
which you are a client. If you have pre-paid advisory fees that we have not yet earned, you will receive
a prorated refund of those fees.
Upon termination of accounts held at our qualified custodian, Raymond James & Associates, Inc.,
they will deliver securities and funds held in the account per your instructions unless you request that
the account be liquidated. After the wrap fee program agreement has been terminated, transactions
are processed at the prevailing brokerage rates/fees. You become responsible for monitoring your
own assets and our firm has no further obligation to act upon or to provide advice with respect to
those assets.
Wrap Fee Program Disclosures
• The benefits under a wrap fee program depend, in part, upon the size of the Account, the
management fee charged, and the number of transactions likely to be generated in the
Account. For example, a wrap fee program may not be suitable for Accounts with little trading
activity. In order to evaluate whether a wrap fee program is suitable for you, you should
compare the Program Fee and any other costs of the Program with the amounts that would be
charged by other advisers, broker-dealers, and custodians, for advisory fees, brokerage and
other execution costs, and custodial services comparable to those provided under the Program.
• In considering the investment programs described in this brochure, you should be aware that
participating in a wrap fee program may cost more or less than the cost of purchasing advisory,
brokerage, and custodial services separately from other advisers or broker-dealers.
• Our firm and Associated Persons receive compensation as a result of your participation in the
Program. This compensation may be more than the amount our firm or the Associated Persons
would receive if you paid separately for investment advice, brokerage, and other services.
Accordingly, a conflict of interest exists because our firm and our Associated Persons have a
financial incentive to recommend the Program.
• Similar advisory services may be available from other registered investment advisers for lower
fees.
Additional Fees And Expenses
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.
The wrap program fees that you pay to our firm for portfolio management services are separate and
distinct from the fees and expenses charged by mutual funds or exchange traded funds (described in
each fund's prospectus) to their shareholders. These fees will generally include a management fee and
other fund expenses. To fully understand the total cost you will incur, you should review all the fees
charged by mutual funds, exchange traded funds, our firm, and others.
We may trade client accounts on margin. Each client must sign a separate margin agreement before
margin is extended to that client account. Fees for advice and execution on these securities are based
on the total asset value of the account, which includes the value of the securities purchased on margin.
While a negative amount may show on a client's statement for the margined security as the result of a
lower net market value, the amount of the fee is based on the absolute market value. This creates a
conflict of interest where we have an incentive to encourage the use of margin to create a higher
market value and therefore receive a higher fee. The use of margin may also result in interest charges
in addition to all other fees and expenses associated with the security involved.
Brokerage Practices
If you participate in the Program, you will be required to establish an account with Raymond James &
Associates, Inc, member FINRA/SIPC, an unaffiliated SEC-registered broker-dealer. If you do not
direct our firm to execute transactions through Raymond James, we reserve the right to not accept
your account. Not all advisers require their clients to direct brokerage. Since you are required to use
Raymond James, we may be unable to achieve the most favorable execution of your transactions. We
believe that Raymond James provides quality execution services based on several factors, including,
but not limited to, the ability to provide professional services, reputation, experience and financial
stability.
Research and Other Soft Dollar Benefits
We do not have any soft dollar arrangements.
Economic Benefits
As a registered investment adviser, we have access to the institutional platform of your account
custodian. As such, we will also have access to research products and services from your account
custodian and/or other brokerage firm. These products may include financial publications, information
about particular companies and industries, research software, and other products or services that
provide lawful and appropriate assistance to our firm in the performance of our investment decision-
making responsibilities. Such research products and services are provided to all investment advisers
that utilize the institutional services platforms of these firms, and are not considered to be paid for with
soft dollars. However, you should be aware that the commissions charged by a particular broker for a
particular transaction or set of transactions may be greater than the amounts another broker who did
not provide research services or products might charge.
Brokerage for Client Referrals
We do not receive client referrals from broker-dealers in exchange for cash or other
compensation, such as brokerage services or research.