We believe that many, if not all, of the “money concerns” and investment/product focuses and worries clients tend to
stem from a lack of confidence and understanding of their true financial picture now and going forward. –We aim to bring
clarity and confidence to this issue in the form of a concrete, regularly reviewed and updated financial plan that focuses
on the path to their desired way of life.
We will interview and consult with each client to determine the client’s personal financial situation and objectives and to
analyze the client’s financial documentation. As applicable, we then review the client’s assets and liabilities, investment
portfolio, retirement plan, education plan, risk management plan, risk tolerance, and estate plan, as well as other areas
relevant to the client’s financial health. We will then build a model for the client that covers some or all of the above. This
usually leads to a series of recommendations for action to improve the client’s plan to give them more chance of meeting
their objectives.
Our clients are based across the US and therefore we provide our services on a remote basis – via email, telephone, web
meetings etc. and are available to work with the client throughout the year to implement the plan. We do occasionally
travel to meet clients, but this is not part of the formal service proposition.
The client is ultimately responsible for communicating changes in circumstances to PFW so that we can provide the most
accurate advice and counsel possible. We are available year-round to assist with the implementation of the plan and to
answer any client questions, but the client is ultimately responsible for the implementation or rejection of our
recommendations. Clients are never obligated or required to implement our recommendations.
Services Limited to Specific Types of Investments
PFW generally limits its investment advice to mutual funds and ETFs. PFW may use other securities as well, to help diversify
a portfolio when applicable.
International Pension Schemes
Many of the clients in the market we serve (British expatriates living throughout the USA) have various legacy pensions in
the UK. One of the key services we provide is consultancy and administration support in understanding the options clients
have as US residents and the different implications of a transfer. Of the solutions available to them to transfer their UK
pensions, we support and provide advice on:
Qualifying Recognised Overseas Pension Scheme (QROPS)
A Qualifying Recognised Overseas Pension Scheme, or QROPS is an overseas pension scheme that meets certain
requirements set by Her Majesty's Revenue and Customs (HMRC). A QROPS must have a beneficial owner and trustees,
and it can receive transfers of British pension benefits. Due to a change in the tax treatment of QROPS in the UK, PFW
does not participate in the transfer of UK pensions into QROPS. However, PFW will continue to service existing QROPS
arrangements. Additional investments cannot be added to existing QROPS.
Self-Invested Personal Pension (SIPP)
A Self-Invested Personal Pension (SIPP) is the name given to the type of UK government-approved personal pension
scheme, which allows individuals to make their own investment decisions from the full range of investments approved by
HMRC. If in the best interest of the client, PFW will recommend that clients transfer their UK pension assets to a SIPP.
PFW does not maintain custody of pension assets. All pension assets are administered by a regulated pension trustee
(authorized by the relevant financial services regulator where the pension plan is held) and subject to the terms and
conditions of a separate agreement between Client and the pension trustee. Current QROPS trustees are STM Malta Trust
and Company Management Limited (“STM”) and Trireme Pension Services (Malta) Limited (“Trireme”). Current SIPP
trustees are London & Colonial (“L&C”), (L&C are part of the STM Group), iPensions Limited, Novia Global Ltd (“Novia
SIPP”), MES Pensions (“MES SIPP”) and Morningstar Retirement Solutions Ltd (“Morningstar SIPP”). QROPS and SIPP assets
are held in custody by the Client’s selected custodian and subject to the terms and conditions of a separate agreement
between the Client’s trustee and the custodian.
Other QROPS and SIPP providers may be available through other investment advisers under different arrangements,
including but not limited to applicable fees and charges, and residency requirements.
Clients are strongly encouraged to review their agreements with their pension trustees and any and all other disclosure
materials provided by the pension trustees and the custodian for a full understanding of the services provided and any
associated costs therein. Pension plan statements and other reports are generally sent directly to Clients on at least an
annual basis. Clients are encouraged to review such material carefully for a complete understanding of the services offered
and the costs associated with the management of such pension plans. PFW encourages questions regarding services, fees,
and other associated issues be addressed with Firm personnel directly.
Tax and Accounting Matters
PFW does not provide any tax advice including, without limitation, in relation to any US tax reporting requirements and/or
other tax implications arising in relation to Clients’ pension transfers. Although from time to time we may inform Clients of
tax developments, we recommend that Clients seek their own tax advice, including in relation to procedures under tax
treaties between the United States and the UK (or other applicable jurisdiction) for the avoidance of double taxation on
their UK/EU pension arrangements.
PFW can introduce Clients to completely unaffiliated tax advisers who have experience in US/UK matters. Clients are under
absolutely no obligation to use a tax adviser that we introduce. PFW receives no financial remuneration from any tax
adviser we recommend to clients. PFW can work with Client’s chosen tax adviser, should that be preferred.
PFW has entered into a partnership with Optimise Accountants, a UK-based cross-border tax and accounting firm. This
partnership allows us to offer a comprehensive, integrated range of tax and accounting services tailored to the client’s
needs. The partnership has been established to fulfill the commitment to our clients’ financial needs, that include proper
tax and accounting services and consultation. Clients and Optimise will enter into a separate agreement and payment for
services outside of the services and fees paid to PFW. Clients are not required to engage Optimise for these services and
may find similar services at a lower cost.
Estate Planning
Our firm offers basic estate planning services to our clients that consists of education on estate planning topics and the
collection of general information necessary to complete a new estate plan or update a current estate plan. The
estate
planning solution is best suited for expatriate families with relatively straightforward situations, and/or as a stopgap for
an expatriate before they commit the time and resources to a more comprehensive estate plan. If we determine that your
situation is more complex, we can recommend other solutions with UK/US estate planning attorneys to address your
estate planning needs. Clients are not required to utilize a third-party service that we may recommend, and they may
receive similar services from other professionals at a similar or lower cost.
Our firm utilizes the services of Estate Guru, a third-party estate planning service for clients who have the need for estate
planning review, creation or updates.
Please note that this is a separate service that comes at a fee separate and in addition to any advisory/financial planning
fees. The fee associated with the service will be in addition to the fees that clients may already pay and is disclosed in Item
5, and within the PFW Estate Planning Disclosure Document that clients receive before engaging in this service.
Written Acknowledgement of Fiduciary Status
When we provide investment advice to you regarding your retirement plan account or individual retirement account, we
are fiduciaries within the meaning of Title 1 of the Employee Retirement Income Act (ERISA) and 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: (1) Meet a professional standard of care when making investment
recommendations (give prudent advice); (2) Never put our financial interests ahead of yours when making
recommendations (give loyal advice); (3) Avoid misleading statements about conflicts of interest, fees, and investments; (4)
Follow policies and procedures designed to ensure that we give advice that is in your best interest; (5) Charge no more than
a level fee that is reasonable for our services; and (6) Give you basic information about conflicts of interest.
PFW offers the same investment strategies to all of its clients. However, specific client investment strategies and their
implementation are dependent upon the client Investment Policy Statement. Clients may not impose restrictions in
investing in certain securities or types of securities in accordance with their values or beliefs.
A wrap fee program is an investment program where the investor pays one stated fee that includes management fees,
transaction costs, fund expenses, and other administrative fees. PFW participates in a wrap fee program for assets
custodied at Betterment, a third-party sub-adviser. Betterment for Advisors offers its investment sub-advisory services for
traditional securities portfolios through a wrap fee program that includes custody and trading services provided by its
affiliate, Betterment Securities.
Betterment for Advisors is a digital wealth management platform generally serving independent investment advisory
firms and advisors (such advisors, “you” or “Advisor”). Betterment LLC (“Betterment”), a registered investment advisor,
serves as sub-advisor to Advisor’s clients (“Clients”). MTG LLC, dba Betterment Securities (“Betterment Securities”), a
registered broker-dealer and member of FINRA and SIPC, serves as broker-dealer and custodian. See Appendix A to this
brochure for more information.
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$987,008 $113,426,513 31 December 2022
C. Client Tailored Services and Client Imposed Restrictions
E. Assets Under Management
D. Wrap Fee Programs
9
PFW’s fees vary depending upon the services you receive. PFW charges the following types of fees: Fixed fees and portfolio
management fees. Portfolio management fees are a percentage of the assets that you have directed us to manage. (See
Fee Schedule below.) Fixed fees are either financial planning fees, and or account setup fees, (See Fixed Fees below.)
Lower fees for comparable services may be available from other sources.
PFW charges upfront flat setup fees (“setup fees”) and portfolio management fees (“management fees”) at the annual
rates shown below, which are expressed as a percentage of Client assets under management.
US-Based Non-US Based
TradePMR &
Betterment4
Sub-Advised
Funds on
Morningstar1,2
SIPPs on Novia
Global, MES &
Morningstar2
Novia QROPS &
Legacy QROPS on
RL360 or Utmost
Setup Fee
(see section on
Account Setup
Fees on the
following pages)
None
£2,000
For Defined Contribution Pension and
SIPP Transfers:
£3,500 + £1,000 per additional pension
For Defined Benefit Pension Transfers:
£8,500 + £1,000 per additional pension
Ongoing Fee Flat Per Annum of 1.25% p.a.3
1Ongoing fee for Morningstar Accounts is the sum of the PFW fee (0.75%) and the sub-adviser fee (0.50%). Sub-advisers include LGT
Vestra US and Dunhill Financial.
2Members of the same household may be eligible for reduced set up fees rather than individual pricing shown.
3The ongoing fee is negotiable at the sole discretion of the Adviser.
4Betterment accounts are subject to a wrap fee of 0.20%. Please see Appendix A to this brochure for more information.
Billing Procedures
US-Based Non-US Based
TradePMR &
Betterment
Morningstar
(GIAs, ISAs, SIPPs)
Novia Global,
MES &
Morningstar
Wealth
RL360 or Utmost
Billing
Cycles
Billed monthly in
arrears
Billed monthly in
arrears
Billed monthly in
arrears
Trustee invoiced
biannually (i.e. every
6 months) in advance
Fee
Payments
Directly debited
from the Account by
PFW
Directly debited
from the Account
by custodian
Directly debited
from the Account
by custodian
Directly debited from
the account by the
trustee
Fee
Calculation
Average of daily
balance in account
throughout the
billing period
Daily values of
account, totaled for
the billing period
Value of the
account as of the
last day of the
billing period
Value of the account
statement
downloaded during
the first five business
days of the billing
period4
4 PFW will download valuation statements for Legacy QROPS directly from the custodian during the first 5 business days of the billing period
(and will submit an invoice for our fee to the QROPS trustee shortly thereafter). Unit prices may reflect an earlier date than the valuation
statement date.
A. Fee Schedule