A. Bush Investment Group, LLC, doing business as Bush Wealth Management (the
“Registrant”), is a limited liability company formed in August 2004 in the state of Georgia.
The Registrant became registered as an Investment Adviser Firm in July 2019. The
Registrant is principally owned by Stacy Bush, the firm’s Managing Member. Courtney
Gooding and Kent Patrick became minority Members effective June 30, 2021.
B.
INVESTMENT MANAGEMENT SERVICES
The Registrant provides discretionary investment advisory services on a fee basis. The
Registrant’s annual investment advisory fee is based upon a percentage (%) of the market
value of the assets placed under the Registrant’s management.
Registrant shall monitor, on a continuous basis, the investments in the accounts over which
it has discretionary authority. Furthermore, it shall have the authority without prior
consultation with the client to buy, sell, trade and allocate the investments within the
account(s) consistent with the client’s investment objectives. The client may, at any time,
impose reasonable restrictions, in writing, on the Registrant’s services.
Registrant generally recommends that investment management accounts be maintained at
Charles Schwab, as further described below in Item 12. However, Registrant also offers
discretionary investment management services for clients with assets held away at other
qualified custodians, or “Held-Away Accounts.” For those clients who have elected to use
this service, they must also enter into a separate user agreement with Pontera Solutions Inc.
(“Pontera”), a third-party order management system software provider. Once the client has
established an online Pontera account and linked their Outside Account to Pontera,
Registrant is able to use Pontera’s system to view and manage the Outside Accounts.
Registrant does not have access to any client passwords as a result of this arrangement, nor
the ability to withdraw or direct the disposition of securities or funds to any person other
than the client.
Registrant also offers asset management services for fee-based fixed indexed annuity
insurance products. Registrant will directly manage these annuity insurance products by
reallocating buckets or sub-accounts within the annuities in accordance with the client’s
suitability profile. Clients who have elected to use this service must also enter into a
separate agreement with the product sponsor designating Registrant to manage the
accounts. Annuity products serviced by Registrant are charged an asset-based management
fee. Registrant does not receive any commissions on these products.
RETIREMENT PLAN CONSULTING SERVICES
The Registrant provides pension consulting services, in the capacity of a 3(21) and 3(38)
advisor, pursuant to which it assists sponsors of self-directed retirement plans with the
selection and/or monitoring of investment alternatives (generally open-end mutual funds)
from which plan participants shall choose in self-directing the investments for their
individual plan retirement accounts. In addition, to the extent requested by the plan
sponsor, the Registrant may also provide participant education designed to assist
participants in identifying the appropriate investment strategy for their retirement plan
accounts. The terms and conditions of the engagement shall generally be set forth in a
Retirement Plan Services Agreement between the Registrant and the plan sponsor.
FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
The Registrant provides financial planning and/or consulting services (including
investment and non-investment related matters, including estate planning, insurance
planning, etc.) on a stand-alone separate fee basis. Registrant’s planning and consulting
fees are negotiable, but generally range from $1,000 to $15,000 on a fixed fee basis, and
from $200 to $400 on an hourly rate basis, depending upon the level and scope of the
service(s) required and the professional(s) rendering the service(s).
Prior to engaging the Registrant to provide planning or consulting services, clients are
generally required to enter into a Financial Planning and Consulting Agreement with
Registrant setting forth the terms and conditions of the engagement (including
termination), describing the scope of the services to be provided, and the portion of the fee
that is due from the client prior to Registrant commencing services. If requested by the
client, Registrant may recommend the services of other professionals, including certain of
the Registrant’s supervised persons in their separate individual capacities as licensed
insurance agents, for implementation purposes. The client is under no obligation to engage
the services of any such recommended professionals.
The client retains absolute discretion over all such implementation decisions and is free to
accept or reject any recommendation from the Registrant and/or its supervised persons. It
remains the client’s responsibility to promptly notify the Registrant if there is ever any
change in their financial situation or investment objectives for the purpose of reviewing,
evaluating or revising Registrant’s previous recommendations and/or services.
MISCELLANEOUS
Limitations of Financial Planning and Non-Investment Consulting/Implementation
Services. As indicated above, to the extent requested by a client, Registrant may provide
financial planning and related consulting services regarding non-investment related
matters, such as estate planning, tax planning, insurance, etc. for a separate and additional
fee per the terms and conditions of a Financial Planning and Consulting Agreement.
Registrant does not serve as an attorney or accountant, and no portion of its services should
be construed as legal or accounting services. Accordingly, Registrant does not prepare
estate planning documents or tax returns. To the extent requested by a client, Registrant
may recommend the services of other professionals for certain non-investment
implementation purpose (i.e. attorneys, accountants, insurance agents, etc.), including
certain of the Registrant’s supervised persons in their separate individual capacities as
licensed insurance agents. The client is under no obligation to engage the services of any
such recommended professional. The client retains absolute discretion over all such
implementation decisions and is free to accept or reject any recommendation from
Registrant and/or its supervised persons. At all times, the engaged licensed professional(s)
(i.e. attorney, accountant, insurance agent, etc.), and not Registrant, shall be responsible
for the quality and competency of the services provided.
Conflict of Interest: The recommendation by Registrant’s supervised persons that a client
purchase an insurance commission product through the Registrant, presents a conflict of
interest, as the receipt of commissions provides an incentive to recommend investment or
insurance products based on commissions to be received, rather than on a particular client’s
need. Registrant addresses this conflict of interest by requiring all supervised persons who
are licensed to offer insurance products to clients to assure that the issuing insurer reviews
the potential sale of any products for the purpose of determining adherence to applicable
insurance suitability standards, requiring all supervised persons to seek prior approval of
any outside employment activity so that it may ensure that any conflicts of interest in such
activities are properly disclosed and fully disclosing to a client when a particular
transaction will result in the receipt of commissions or other associated fees. No client is
under any obligation to purchase any insurance commission products through the
Registrant. Clients are reminded that they may purchase insurance products recommended
by Registrant or its supervised persons through other, non-affiliated insurance agencies.
Registrant’s Chief Compliance Officer, Courtney Gooding, remains available to address
any questions that a client or prospective client may have regarding the above conflict of
interest.
Retirement Plan Rollovers – No Obligation/Conflict of Interest: When the Registrant
provides investment advice to clients regarding their 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 Registrant makes money creates some
conflicts with our client’s interests, so we operate under a special rule that requires
Registrant to act in the client’s best interest and not put our interest ahead of the client.
Registrant may recommend that a client roll over their retirement assets into an account to
be managed by Registrant. A client or prospective client leaving an employer typically has
four options regarding an existing retirement plan (and may engage in a combination of
these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll
over
the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii)
roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value
(which could, depending upon the client’s age, result in adverse tax consequences). If the
Registrant recommends that a client roll over their retirement assets into an account to
be managed by the Registrant, such a recommendation creates a conflict of interest if the
Registrant will earn an advisory fee on the rolled over assets. Registrant addresses this
conflict of interest by ensuring any such recommendations are in the client’s best interest.
No client is under any obligation to roll over retirement assets to an account managed by
Registrant.
Use of Mutual and Exchange Traded Funds: Most mutual funds and exchange traded
funds are available directly to the public. Thus, a prospective client can obtain many of the
funds that may be utilized by Registrant independent of engaging Registrant as an
investment advisor. However, if a prospective client determines to do so, he/she will not
receive Registrant’s initial and ongoing investment advisory services.
In addition to Registrant’s investment advisory fee described below, and transaction and/or
custodial fees discussed below, clients will also incur, relative to all mutual fund and
exchange traded fund purchases, charges imposed at the fund level (e.g. management fees
and other fund expenses).
Use of DFA Mutual Funds: Certain mutual funds, such as those issued by Dimensional
Fund Advisors (“DFA”), are generally only available through selected registered
investment advisers. Registrant may allocate client investment assets to DFA mutual funds.
Therefore, upon the termination of Registrant’s services to a client, restrictions regarding
transferability and/or additional purchases of, or reallocation among DFA funds will apply.
Independent Managers. Registrant may allocate a portion of a client’s investment assets
among unaffiliated independent investment managers (“Independent Manager(s)”) in
accordance with the client’s designated investment objective(s). In such situations, the
Independent Manager(s) will have day-to-day responsibility for the active discretionary
management of the allocated assets. Registrant will continue to render investment
supervisory services to the client relative to the ongoing monitoring and review of account
performance, asset allocation, and client investment objectives. The Registrant generally
considers the following factors when recommending Independent Manager(s): the client’s
designated investment objective(s), management style, performance, reputation, financial
strength, reporting, pricing, and research. Unless otherwise agreed by client in a separate
written agreement, any fees paid to the designated Independent Manager(s) are included in
the Registrant’s annual Advisory Fee and will be paid by the Registrant. Registrant’s
Advisory Fee is set forth in the fee schedule at Item 5 below.
Orion Advisor Services – Reporting – Excluded Assets. In conjunction with the services
provided by Orion, the Registrant may also provide periodic reporting services, which can
incorporate all of the client’s investment assets including those investment assets that are
not part of the assets managed by the Registrant (the “Excluded Assets”). The Registrant’s
service relative to the Excluded Assets is limited to reporting services only, and does not
include investment implementation.
Because the Registrant does not have trading authority for the Excluded Assets, to the
extent applicable to the nature of the Excluded Assets (assets over which the client
maintains trading authority vs. trading authority designated to another investment
professional), the client (and/or the other investment professional), and not the Registrant,
shall be exclusively responsible for directly implementing any recommendations relative
to the Excluded Assets. The client and/or their other advisors that maintain trading
authority, and not the Registrant, shall be exclusively responsible for the investment
performance of the Excluded Assets. Without limiting the above, the Registrant shall not
be responsible for any implementation error (timing, trading, etc.) relative to the Excluded
Assets. In the event the client desires that the Registrant provide investment management
services with respect to the Excluded Assets, the client may engage the Registrant to do so
pursuant to the terms and conditions of an Investment Advisory Agreement between the
Registrant and the client.
eMoney Advisor Platform. Registrant provides its clients with access to an online
platform hosted by “eMoney Advisor” (“eMoney”) upon request. The eMoney platform
allows a client to view their complete asset allocation, including those assets that Registrant
does not manage (the “Excluded Assets”). Registrant does not provide investment
management, monitoring, or implementation services for the Excluded Assets. Unless
otherwise specifically agreed to, in writing, Registrant’s service relative to the Excluded
Assets is limited to reporting only. Therefore, Registrant shall not be responsible for the
investment performance of the Excluded Assets. Rather, the client and/or their advisor(s)
that maintain management authority for the Excluded Assets, and not Registrant, shall be
exclusively responsible for such investment performance. Without limiting the above, the
Registrant shall not be responsible for any implementation error (timing, trading, etc.)
relative to the Excluded Assets. The client may choose to engage Registrant to manage
some or all of the Excluded Assets pursuant to the terms and conditions of an Investment
Advisory Agreement between Registrant and the client. The eMoney platform also
provides access to other types of information and applications including financial planning
concepts and functionality, which should not, in any manner whatsoever, be construed as
services, advice, or recommendations provided by Registrant. Finally, Registrant shall not
be held responsible for any adverse results a client may experience if the client engages in
financial planning or other functions available on the eMoney platform without
Registrant’s assistance or oversight.
Portfolio Activity. Registrant has a fiduciary duty to provide investment advisory services
consistent with the client’s best interest. As part of its investment advisory services,
Registrant will review client portfolios on an ongoing basis to determine if any changes are
necessary based upon various factors, including, but not limited to, investment
performance, fund manager tenure, style drift, account additions/withdrawals, and/or a
change in the client’s investment objective. Based upon these factors, there may be
extended periods of time when Registrant determines that changes to a client’s portfolio
are neither necessary nor prudent. Of course, as indicated below, there can be no assurance
that investment decisions made by Registrant will be profitable or equal any specific
performance level(s). Clients nonetheless remain subject to the fees described in Item 5
below during periods of account inactivity.
Cash Positions. The Registrant may maintain cash and cash equivalent positions (such as
money market funds) for defensive and liquidity purposes. Unless otherwise agreed in
writing, all cash and cash equivalent positions will be included as part of assets under
management for purposes of calculating the Registrant’s investment advisory fee.
Client Obligations. In performing its services, Registrant shall not be required to verify
any information received from the client or from the client’s other professionals, and is
expressly authorized to rely thereon. Moreover, each client is advised that it remains their
responsibility to promptly notify the Registrant if there is ever any change in their financial
situation or investment objectives for the purpose of reviewing, evaluating or revising
Registrant’s previous recommendations and/or services.
Disclosure Statement. A copy of the Registrant’s written Brochure as set forth on Part 2
of Form ADV shall be provided to each client prior to, or contemporaneously with, the
execution of the Investment Advisory Agreement, Retirement Plan Services Agreement or
Financial Planning and Consulting Agreement.
C. The Registrant shall provide investment advisory services specific to the needs of each
client. Prior to providing investment advisory services, an investment adviser
representative will ascertain each client’s investment objective(s). Thereafter, the
Registrant shall allocate and/or recommend that the client allocate investment assets
consistent with the designated investment objective(s). The client may, at any time, impose
reasonable restrictions, in writing, on the Registrant’s services.
D. The Registrant does not participate in a wrap fee program.
E. As of December 31, 2023, the Registrant had $180,305,473 in assets under management,
of which $180,284,507 is managed on a discretionary basis and $20,966 is managed on a
non-discretionary basis.