Beto Financial Group, LLC, d/b/a BR Wealth Management, is an Idaho limited liability company
founded in 2011. The firm’s principal owner is Brian E. Randolph. We are registered as an
investment advisor with SEC and our principal offices are located in Boise, Idaho.
The information contained in this brochure describes our investment advisory services, practices,
and fees. Please refer to the description of each investment advisory service listed below for
information on how we tailor our services to the needs of our clients. As used throughout this firm
brochure, the words “BRWM,” “we,” “our,” “firm,” and “us” refer to BR Wealth Management,
and the words “you,” “your,” and “client” refer to you as either a client or prospective client of our
firm.
Prior to forming an investment advisor-client relationship, we may offer you a complimentary
general consultation to discuss the nature of our services and to determine the possibility of an
advisory relationship. Investment advisory services begin only after the prospective client and
BRWM formalize their relationship by the execution of a written advisory agreement.
We offer several investment advisory services to clients. Our investment advice is always custom
tailored according to each client’s unique investment profile.
When we provide portfolio management services, clients deposit their assets at an independent
qualified custodian (the “Custodian”) and grant us limited authority to buy and sell securities either
on a discretionary or non-discretionary basis. The full scope of our authority with respect to
management of the client’s account will be set forth in a written advisory agreement. We act as
your fiduciary, responsible for the management of your investment account(s) at the Custodian,
where assets are held in your name.
Portfolio management services are offered, either on a discretionary or non-discretionary basis.
Ø Where you engage us on a discretionary basis, you authorize our firm and our investment
advisor representatives to implement our investment recommendations directly within your
account held at the Custodian without obtaining your specific consent prior to each
transaction.
Ø Where you engage us on a non-discretionary basis, we will provide you with investment
recommendations which you are free to accept or reject, in whole or in part. We will only
implement our investment recommendations within your account held at the Custodian
upon your request and with your prior approval.
Clients always have the ability to impose reasonable restrictions on our management of their
account(s), including the ability to instruct us not to purchase certain specific securities, industry
sectors, and/or asset classes. We will attempt to honor the client’s investment restrictions in all
circumstances and will notify you if we are ever unable to do so for any reason.
A description of the individual investment advisory services offered by our firm is set forth below.
Portfolio Management. Our firm offers ongoing and continuous portfolio management services that
are uniquely tailored to your financial circumstances. Through periodic consultations with you, we
will gather information regarding your financial goals, investment objectives, tolerance for risk,
and the time horizon for investments. The information we typically request in this process will
include your current and expected income level, tax information, investment experience, current
and expected cash needs, current portfolio construction/asset allocation, and risk tolerance level,
among other items. We will analyze these factors and document your investment objectives,
restrictions, and suitability information which will guide our management of your account(s). We
will then recommend an initial investment strategy and portfolio intended to align with your unique
financial situation and goals.
We do not recommend one particular type of investment or asset class over any other. We primarily
advise our clients regarding investments in stocks, bonds, mutual funds, ETFs, U.S. government
and municipal securities, cash and cash equivalents, and variable products (life insurance and
annuities). Depending on the client’s financial circumstances, we may also provide advice
regarding other instruments, including, without limitation, U.S. government and municipal
securities, money market accounts, and other public and private investments. We may also provide
advice regarding investments held in your portfolio at the inception of our advisory relationship
and/or other investment types not listed above, at your request.
Depending on your asset level, investment needs, and other factors, we may implement our
investment strategy through the use of certain model portfolios designed by our firm, or third-party
money managers (collectively “Model Portfolios”).
The Model Portfolios and investment strategies we utilize have generally been designed to meet a
particular investment objective for investors with varying degrees of risk tolerance, ranging from a
more aggressively allocated portfolio to a more conservative approach. Factors that we take into
consideration when determining whether any particular Model Portfolio or investment strategy is
appropriate for your account include, without limitation, the Model Portfolio or investment
strategy’s investment goal, underlying holdings, and your financial needs, investment goals, risk
tolerance, and investment objectives.
As part of building your portfolio, we may also recommend that certain third-party money
managers or sub-advisors (collectively, “TPMMs”) be engaged to manage all or a portion of your
account (each such sub-account, a “Separately Managed Account” or “SMA”). The TPMMs we
recommend may contract with us directly to provide sub-advisory services to your account and/or
may be accessible to us via the investment platform of your Custodian. In other instances, we may
recommend that you directly contract with a TPMM. In all cases, you will be provided with the
Form ADV Part 2A (or equivalent disclosures) for any recommended TPMMs at or prior to the
time of your engagement of their services. You may further be required to execute a separate
advisory agreement and/or trading authorization in favor of such TPMMs at the time of their
engagement granting them discretionary authority to trade your SMA.
We will continue to serve as your primary advisor with respect to any SMAs, serving in a co-
advisory capacity responsible for the ongoing monitoring of such account(s) and the determination
of the suitability of the TPMM’s overall investment program. The TPMM shall typically be
responsible for all investment selection and trading functions related to your SMA(s). We will
recommend adjustments to your TPMM engagements and allocations when we believe such
changes are in your best interests.
Following implementation of your initial investment portfolio, we will monitor the performance of
your account (including any SMAs) on an ongoing basis and implement and/or recommend changes
as needed or appropriate, in consideration of current economic conditions, our market opinions and
assumptions, and your individual financial circumstances and goals. It is your ongoing
responsibility to advise us in writing of any material changes to your financial circumstances
through our engagement.
At our discretion, portfolio management clients may also receive certain financial planning and
consulting services in the form described below on a complimentary or discounted basis.
Financial Planning and Consulting Services. Our firm offers financial planning and consulting
services to clients which may address, without limitation, some, or all of the following topics:
• financial, budgeting and cash
management
• risk management, insurance
planning, and analysis
• financial planning relating to
divorce and marriage
• estate planning
• taxation issues and tax planning;
• retirement planning
• investment planning/asset
allocation/portfolio design;
• educational funding
• investment goal setting
Our financial planning and consulting services are offered on an annual retainer basis or on a one-
time consulting basis.
• Annual Retainer Engagements: If you elect this service, we will consult with you and
review your pertinent financial documents and information (e.g., bank and brokerage
statements, insurance documents, estate and trust documents, tax documents, etc.) with the
goal of identifying areas of financial concern and determining an appropriate set of
financial goals and objectives over various time horizons. We will analyze the data and
information
you share with us and present you with a comprehensive written financial plan.
The financial plan will include a summary of your financial situation, our general
observations regarding the same, and a set of specific actions and investment
recommendations designed and intended to assist you in achieving your short term and
long-term financial goals. For example, recommendations may be made that you begin or
revise certain investment programs or accounts; create or revise wills or trusts; obtain or
revise insurance coverage; commence or alter retirement savings; or establish education
savings or charitable giving programs, among others.
We will meet with you at least once annually to review the financial plan following its initial
delivery, track your progress towards your financial goals, and to update the financial plan as
necessary and appropriate. We will also provide you with ongoing advice and support throughout
our engagement with respect to common issues affecting your financial life which touch upon the
topics addressed within your financial plan (collectively, “Ancillary Advice”).
• One-time Financial Planning/Topical Consulting Engagements: If you elect this service,
you may select a discrete financial topic or topics upon which you would like to receive
our financial advice. One-time financial planning and consulting services are narrower in
scope than annual retainer services, and do not include comprehensive financial planning.
We will deliver our recommendations in the form of a written financial report or checklist
at the conclusion of the engagement, after which time, no further update or review of the
financial report or checklist or other advice is provided (unless specifically requested by
the client and agreed to in writing by BRWM) and the engagement is concluded.
Unlike our offering of portfolio management services, we will not actively monitor or supervise
your investment accounts but will only review your holdings and provide our investment
recommendations periodically (i.e., at the time of our periodic consultations). You will be solely
responsible to monitor and supervise your investments between our consultations.
Financial planning and consulting services are non-discretionary in nature. The client retains the
sole discretion to accept or reject any of BRWM’s recommendations, in whole or in part, and to
determine the service providers to be utilized for their implementation. Upon request, we may assist
the client with implementation of our financial recommendations - additional fees may apply.
Clients are never obligated to use our firm to implement any recommendations. Clients are never
charged more than $1,200 six (6) or more months in advance for these services.
As part of this service, we may recommend the use of certain third-party professionals (e.g.,
attorneys, tax advisors, accountants) to assist you in implementing the advice and recommendations
we provide. We do not receive compensation or referral fees of any kind in connection with these
recommendations. You are never obligated to engage any recommended third-party professional(s)
and elect to do so at your sole discretion and risk. You will independently contract with such service
providers and their fees are not included within the advisory fees paid to BRWM. We do not provide
legal or tax advice of any kind.
Betterment Advisory Services. We may recommend that certain Clients implement their
investment portfolios through Betterment for Advisors, a division of Betterment LLC (herein
“Betterment” or the “Investment Platform”). Betterment for Advisors is what is often termed a
“robo-advisor”, an online wealth management service that provides automated, algorithm-based
portfolio management advice. Robo-advisors use technology to deliver similar services as
traditional advisors, but generally only offer portfolio management and do not get involved in a
Client’s personal situation, such as taxes and retirement or estate planning. We chose to affiliate
with Betterment for Advisors due to the Investment Platform’s customized portfolio allocations,
automated rebalancing, and competitive fees. We utilize Betterment for Advisors as a complement
to its comprehensive financial planning services to provide cost effective investing coupled with
personalized financial planning.
To establish accounts with Betterment for Advisors, the Client will also enter into one or more
agreements with Betterment that provides the authority for discretionary investment management
by the Investment Platform. We will have the discretionary authority to instruct Betterment for
Advisors with respect to portfolio construction, asset allocation and other investment decisions,
subject to the limitations described herein. Betterment for Advisors will implement the portfolio
and be responsible for the discretionary trading of the ETFs in the Client’s portfolio, including the
purchase and sale of investments and the automatic rebalancing back to targets.
We remain the Client’s primary advisor and relationship contact and will select or construct a
portfolio of ETFs and/or cash equivalents from the universe of investments included on the
Investment Platform.
The Advisor will only receive its investment advisory fees as detailed in Item 5 below and does not
share in any fees earned by Betterment for Advisors.
Pension Consulting Services. We offer pension consulting services to employee benefit plans and
their fiduciaries based upon the needs of the plan and the services requested by the plan sponsor or
named fiduciary. In general, these services may include an existing plan review, formulation of the
investment policy statement, asset allocation advice, vendor selection advice, non-discretionary
portfolio management services, investment performance monitoring/benchmarking services, on-
going consulting, communication, and participant education services/seminars. We may also assist
the plan sponsor in providing participant enrollment meetings.
Pontera Services: Pontera (formerly FeeX) is the third-party service provider whereby Advisor
provides an additional service for accounts not directly held with our recommended custodian, but
where Advisor does have discretion and leverages an Order Management System to implement
asset allocation or rebalancing strategies on behalf of the Client. These are primarily 401(k)
accounts, 403(b) accounts, variable annuities, and other assets not held with the recommended
custodian. Our Firm regularly reviews the current holdings and available investment options in
these accounts, monitors the account, rebalances, and implements our Firm’s strategies, as
necessary. Our Firm is engaged with Pontera, an unaffiliated entity, to offer this service to our
Clients.
NOTE: Certain plans/clients that we may provide services to are regulated under the Employee
Retirement Income Securities Act of 1974 (“ERISA”). We will provide pension consulting services
to the plan sponsor and/or fiduciaries as described above for the fees set forth in Item 5 of this
brochure. The consulting services we provide are advisory in nature. In providing services to any
plan and its underlying participants, our status is that of an investment advisor registered under the
Investment Advisers Act of 1940. We are not subject to any disqualifications under Section 411 of
ERISA. In performing fiduciary services, we are acting as a fiduciary of the plan as defined in
Section 3(21) under ERISA, only. In all cases, our status as a fiduciary under ERISA is clearly
disclosed in a written advisory agreement. If there is any discrepancy between the disclosures in
this paragraph and the agreement, the agreement shall govern.
No Wrap Fee Program; Types of Investments Recommended. We do not offer, sponsor, or
participate in a wrap fee program.
If appropriate for your portfolio, we may recommend use of the Betterment Wrap Program as
disclosed above. Please note that this Wrap Fee Program is sponsored by Betterment, not our Firm.
Betterment charges a single wrap fee for all services Betterment. The services included for the
wrap fee include all the services provided by Betterment and Betterment Securities through the
Betterment platform, including advisory services, custody of assets, execution, and clearing.
Betterment collects wrap fees directly from the client accounts pursuant to the terms of the sub-
advisory agreement between Betterment and each Client.
Please see Item 8 of this brochure or a description of the investment strategies we typically
implement in client accounts.
As of December 31, 2023, we manage a total of $259,017,418 in client assets under management.
We manage $217,083,570 on a discretionary basis and $41,933,848 in client assets on a non-
discretionary basis. We also have $35,143,373 in Assets Under Advisement.