A. Bannerman Wealth Management Group LLC (the “Adviser,” “we,” “us,” or “our”) is an investment
adviser founded in 2009, registered with the U.S. Securities and Exchange Commission (“SEC”),
and solely owned by the Joshua K. Bannerman Revocable Trust. Joshua K Bannerman is the
sole Trustee of the Joshua K. Bannerman Revocable Trust.
B. Adviser offers the following types of advisory services:
i.Discretionary Investment Management. Adviser provides ongoing discretionary
investment management services to its clients based upon each client’s current financial
condition, goals, risk tolerance, income, liquidity requirements, investment time horizon,
and other information that is relevant to the management of clients’ account(s). This
information will then be used to make investment decisions that reflect clients’ individual
needs and objectives on an initial and ongoing basis. Adviser’s investment decisions will
allocate portions of clients’ account(s) to various asset classes classified according to
historical and projected risks and rates of return. Adviser will retain the discretion to buy,
sell, or otherwise transact in securities and other investments in a client’s accounts
without first receiving the client’s specific approval for each transaction. Such
discretionary authority is granted by a client in his or her investment management
agreement with Adviser. Clients may impose restrictions on investing in certain securities
or types of securities so long as such restrictions may reasonably be implemented by
Adviser.
Clients who invest less than $500,000 with us are generally directed to our automated
investment program (the “WealthBuilder Program”), which usually differs in services and
scope to the investment management services we provide to our other clients with a
larger amount of assets under management.
Through the WealthBuilder Program, clients will invest in a range of investment strategies
we have constructed and manage, each consisting of a portfolio of exchange-traded
funds and mutual funds (“Funds”) and a cash allocation. The client may instruct us to
exclude up to three Funds from their portfolio. The client’s portfolio is held in a brokerage
account opened by the client at Charles Schwab & Co., Inc. (“CS&Co.”). We use the
Institutional Intelligent Portfolios® platform (“Platform”), offered by Schwab Performance
Technologies (“SPT”), a software provider to independent investment advisers and an
affiliate of CS&Co., to operate the Program. We are independent of and not owned by,
affiliated with, or sponsored or supervised by SPT, CS&Co., or their affiliates (together,
“Schwab”). We, and not Schwab, are the client’s investment adviser and primary point of
contact with respect to the Program. We are solely responsible, and Schwab is not
responsible, for determining the appropriateness of the Program for the client, choosing a
suitable investment strategy and portfolio for the client’s investment needs and goals, and
managing that portfolio on an ongoing basis. We have contracted with SPT to provide us
with the Platform, which consists of technology and related trading and account
management services for the Program. The Platform enables us to make the Program
available to clients online and includes a system that automates certain key parts of our
investment process (the “System”).
Based on information the client provides to us, we will recommend a portfolio via the
System. The client may then indicate an interest in a portfolio that is one level less or
more conservative or aggressive than the recommended portfolio, but we then make the
final decision and select a portfolio based on all the information we have about the client.
The System also includes an automated investment engine through which we manage
the client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss
harvesting (if the client is eligible and elects).
We charge clients a fee for our services as described below under Item 5 Fees and
Compensation. Our fees are not set or supervised by Schwab. Clients do not pay
brokerage commissions or any other fees to CS&Co. as part of the WealthBuilder
Program. Schwab does receive other revenues, including (i) the profit earned by Charles
Schwab Bank, SSB, a Schwab affiliate, on the allocation to the Schwab Intelligent
Portfolios Sweep Program as described in the Schwab Intelligent Portfolios Sweep
Program Disclosure Statement; (ii) investment advisory and/or administrative service fees
(or unitary fees) received by Charles Schwab Investment Management, Inc., a Schwab
affiliate, from Schwab ETFs™ Schwab Funds® and Laudus Funds® that we select to buy
and hold in the client’s brokerage account; (iii) fees received by Schwab from mutual
funds in the Schwab Mutual Fund Marketplace® (including certain Schwab Funds and
Laudus Funds) in the client’s brokerage account for services Schwab provides; and (iv)
remuneration Schwab receives from the market centers where it routes ETF trade orders
for execution.
ii.Comprehensive Financial Planning. Adviser provides comprehensive financial planning
services on a standalone basis. This service involves working one-on-one with a planner
over an extended period of time. By paying a monthly fee, clients get continuous access
to a planner who will work with them to design their plan. The planner will monitor the
plan, recommend any changes and ensure the plan is up to date. At the start of the
engagement, a client will be taken through establishing their goals and values around
money. Clients will be required to provide information to help complete the following
areas of analysis: net worth, cash flow, insurance, credit scores/reports, employee
benefit, retirement planning, insurance, investments, college planning and estate
planning. Once the client’s information is reviewed, their plan will be built and analyzed,
and then the findings, analysis and potential changes to their current situation will be
reviewed with the client. Clients receiving this service will receive a written or an
electronic report, providing the client with a detailed financial plan designed to achieve his
or her stated financial goals and objectives. If a follow up meeting is required, we will
meet at the client's convenience. The plan and the client’s financial situation and goals
will be monitored throughout the year and follow-up phone calls and emails will be made
to the client to confirm that any agreed-upon action steps have been carried out. On an
annual basis there will be a full review of this plan to ensure its accuracy and ongoing
appropriateness. Any needed updates will be implemented at that time.
We provide financial planning services on topics such as retirement planning, risk
management, college savings, cash flow, debt management, work benefits, and estate
incapacity planning. Financial planning is a comprehensive evaluation of a client’s current
and future financial state by using currently known variables to predict future cash flows,
asset values and withdrawal plans. The key defining aspect of financial planning is that
through the financial planning process, all questions, information and analysis will be
considered as they impact and are impacted by the entire financial and life situation of
the client. In general, the financial plan will address any or all of the following areas of
concern. The client and Adviser will work together to select the specific areas to cover.
These areas may include, but are not limited to, the following:
●Business Planning: We provide consulting services for clients who currently
operate their own business, are considering starting a business, or are planning
for an exit from their current business. Under this type of engagement, we work
with you to assess your current situation, identify your objectives, and develop a
plan aimed at achieving your goals.
●Cash Flow and Debt Management: We will conduct a review of your income and
expenses to determine your current surplus or deficit along with advice on
prioritizing how any surplus should be used or how to reduce expenses if they
exceed your income. Advice may also be provided on which debts to pay off first
based on factors such as the interest rate of the debt and any income tax
ramifications. We may also recommend what we believe to be an appropriate
cash reserve that should be considered for emergencies and other financial
goals, along with a review of accounts (such as money market funds) for such
reserves, plus strategies to save desired amounts.
●College Savings: Includes projecting the amount that will be needed to achieve
college or other post-secondary education funding goals, along with advice on
ways for you to save the desired amount. Recommendations as to savings
strategies are included, and, if needed, we will review your financial picture as it
relates to eligibility for financial aid or the best way to contribute to grandchildren
(if appropriate).
●Employee Benefits Optimization: We will provide review and analysis as to
whether you, as an employee, are taking the maximum advantage possible of
your employee benefits. If you are a business owner, we will consider and/or
recommend the various benefit programs that can be structured to meet both
business and personal retirement goals.
●Estate Planning: This usually includes an analysis of your exposure to estate
taxes and your current estate plan, which may include whether you have a will,
powers of attorney, trusts and other related documents. Our advice also typically
includes ways for you to minimize or avoid future estate taxes by implementing
appropriate estate planning strategies such as the use of applicable trusts. We
always recommend that you consult with a qualified attorney when you initiate,
update, or complete estate planning activities. We may provide you with contact
information for attorneys who specialize in estate planning when you wish to hire
an attorney for such purposes. From time-to-time, we will participate in meetings
or phone calls between you and your attorney with your approval or request.
●Financial Goals: We will help clients identify financial goals and develop a plan to
reach them. We will identify what you plan to accomplish, what resources you will
need to make it happen, how much time you will need to reach the goal, and how
much you should budget for your goal.
●Insurance: Review of existing policies to ensure proper coverage
for life, health,
disability, long-term care, liability, home and automobile.
●Investment Analysis: This may involve developing an asset allocation strategy to
meet clients’ financial goals and risk tolerance, providing information on
investment vehicles and strategies, reviewing employee stock options, as well
assisting you in establishing your own investment account at a selected
broker/dealer or custodian. The strategies and types of investments we may
recommend are further discussed in Item 8 of this brochure.
●Retirement Planning: Our retirement planning services typically include
projections of your likelihood of achieving your financial goals, typically focusing
on financial independence as the primary objective. For situations where
projections show less than the desired results, we may make recommendations,
including those that may impact the original projections by adjusting certain
variables (i.e., working longer, saving more, spending less, taking more risk with
investments). If you are near retirement or already retired, advice may be given
on appropriate distribution strategies to minimize the likelihood of running out of
money or having to adversely alter spending during your retirement years.
●Risk Management: A risk management review includes an analysis of your
exposure to major risks that could have a significant adverse impact on your
financial picture, such as premature death, disability, property and casualty
losses, or the need for long‐term care planning. Advice may be provided on ways
to minimize such risks and about weighing the costs of purchasing insurance
versus the benefits of doing so and, likewise, the potential cost of not purchasing
insurance (“self‐insuring”).
●Tax Planning Strategies: Advice may include ways to minimize current and future
income taxes as a part of your overall financial planning picture. For example, we
may make recommendations on which type of account(s) or specific investments
should be owned based in part on their “tax efficiency,” with consideration that
there is always a possibility of future changes to federal, state or local tax laws
and rates that may impact your situation. We recommend that you consult with a
qualified tax professional before initiating any tax planning strategy, and we may
provide you with contact information for accountants or attorneys who specialize
in this area if you wish to hire someone for such purposes. We will participate in
meetings or phone calls between you and your tax professional with your
approval.
We offer the same suite of services to all of our clients. However, specific client financial
plans and their implementation are dependent upon the client Investment Policy
Statement which outlines each client’s current situation (income, tax levels, and risk
tolerance levels) and is used to construct a client specific plan to aid in the selection of a
portfolio that matches restrictions, needs, and targets.
When rendering financial planning services, a conflict exists between Adviser’s interests
and the interests of its clients; clients are under no obligation to act upon Adviser’s
financial planning recommendations. If a client elects to act on any of the
recommendations made by Adviser, the client is under no obligation to effect the
transaction through Adviser or any of its personnel.
iii.Pension Consulting Services. To the extent Adviser is retained by a pension or profit
sharing plan (a “Plan”), Adviser shall review the Plan’s investment objectives, risk
tolerance, and goals, and shall work in partnership with applicable third-parties (such as
the Plan’s recordkeeper, third-party administrator, and/or discretionary investment
manager) to establish an appropriate investment policy statement and deploy applicable
investment options into the Plan’s account. Adviser shall periodically review the
investment options available to the Plan and, if applicable, will make recommendations to
assist the Plan with respect to the selection of the Plan’s qualified default investment
alternative (“QDIA”). Adviser will provide reports, information and recommendations, on a
reasonably requested basis, to assist the Plan in monitoring the selected investments. If
elected by the Plan, Adviser may also provide various services related to the Plan’s
governance, the education of Plan participants, and the review of other service providers
to the Plan. In connection with Plans subject to the Employee Retirement Income
Security Act of 1974 (“ERISA”) and applicable provisions of the Internal Revenue Code of
1986, as amended (the “Code”) Adviser acknowledges that it is a fiduciary under ERISA
and the Code, shall render prudent investment advice that is in Plan’s best interest, shall
avoid making misleading statements, and shall receive no more than reasonable
compensation.
C. Adviser does not participate in any wrap fee programs.
D. 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 (“ERISA”) and/or the Internal Revenue Code (the “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:
i.Meet a professional standard of care when making investment recommendations (give
prudent advice);
ii.Never put our financial interests ahead of yours when making recommendations (give
loyal advice);
iii.Avoid misleading statements about conflicts of interest, fees, and investments;
iv.Follow policies and procedures designed to ensure that we give advice that is in your
best interest;
v.Charge no more than is reasonable for our services; and
vi.Give you basic information about conflicts of interest.
E. IRA Rollover Considerations. 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 our agreement. 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 us.
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:
i.Leaving the funds in your employer's (former employer's) plan.
ii.Moving the funds to a new employer’s retirement plan.
iii.Cashing out and taking a taxable distribution from the plan.
iv.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.
If you are considering rolling over your retirement funds to an IRA for us to manage here are a
few points to consider before you do so:
1) Determine whether the investment options in your employer's retirement plan address
your needs or whether you might want to consider other types of investments.
a) Employer retirement plans generally have a more limited investment menu than
IRAs.
b) Employer retirement plans may have unique investment options not available to
the public such as employer securities, or previously closed funds.
2) Your current plan may have lower fees than our fees.
a) If you are interested in investing only in mutual funds, you should understand the
cost structure of the share classes available in your employer's retirement plan
and how the costs of those share classes compare with those available in an
IRA.
b) You should understand the various products and services you might take
advantage of at an IRA provider and the potential costs of those products and
services.
3) Our strategy may have higher risk than the option(s) provided to you in your plan.
4) Your current plan may also offer financial advice.
5) If you keep your assets titled in a 401k or retirement account, you could potentially delay
your required minimum distribution beyond age 70.5.
6) Your 401k may offer more liability protection than a rollover IRA; each state may vary.
Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA
assets have been generally protected from creditors in bankruptcies. However, there can
be some exceptions to the general rules so you should consult with an attorney if you are
concerned about protecting your retirement plan assets from creditors.
7) You may be able to take out a loan on your 401k, but not from an IRA.
8) IRA assets can be accessed any time; however, distributions are subject to ordinary
income tax and may also be subject to a 10% early distribution penalty unless they
qualify for an exception such as disability, higher education expenses or the purchase of
a home.
9) If you own company stock in your plan, you may be able to liquidate those shares at a
lower capital gains tax rate.
10) Your plan may allow you to hire us as the manager and keep the assets titled in the plan
name.
It is important that you understand the differences between these types of accounts and to decide
whether a rollover is best for you. Prior to proceeding, if you have questions contact your
investment adviser representative, or call our main number as listed on the cover page of this
brochure.
F. Adviser manages the following amount of discretionary and non-discretionary client assets
calculated as of December 31, 2023:
i.Discretionary:$110,829,105
ii.Non-Discretionary:$0
iii.Total:$110,829,105