Description of Firm
FinDec Wealth Services, Inc. is a registered investment adviser primarily based in Stockton, CA. We
are organized as a corporation under the laws of the State of California. Financial Decisions, Inc. was
established in 1983 by Frederick M. Lee and Nancy E. Lee, providing investment advisory services
and was reorganized as FinDec Wealth Services, Inc. in 2020. We are primarily owned by FinDec Co.
We are indirectly owned by Michael E. Lee and Kevin E. Mahoney.
The following paragraphs describe our services and fees. Refer to the description of each investment
advisory service listed below for information on how we tailor our advisory services to your individual
needs. As used in this brochure, the words "we," "our," "us" and "FinDec" refer to FinDec Wealth
Services, Inc. and the words "you," "your," and "client" refer to you as either a client or prospective
client of our firm.
Portfolio Management Services
We provide discretionary and non-discretionary portfolio management services tailored to meet your
needs and investment objectives. If you retain our firm for portfolio management services, we will meet
with you to determine your investment objectives, risk tolerance, and other relevant information (the
"suitability information") at the beginning of our advisory relationship. We will use the suitability
information we gather to develop a strategy that enables our firm to give you continuous investment
advice. As part of our portfolio management services, we may customize an investment portfolio for
you in accordance with your risk tolerance and investing objectives or we may also invest some or all
of your assets according to one or more risk-based model portfolios developed by our firm. Once we
construct an investment portfolio for you, or select a model portfolio, we will monitor your portfolio\'s
performance on an ongoing basis, and will rebalance the portfolio as required by changes in market
conditions and your financial circumstances.
We also offer Liquidity Management for decumulation strategies implemented for clients in generating
retirement cash flow from their investment accounts. This service enables clients to better manage
their cash flow needs for retirement purposes.
If you participate in our discretionary portfolio management services, we require you to grant our firm
discretionary authority to manage your account. Discretionary authorization will allow us to determine
the specific securities, and the amount of securities, to be purchased or sold for your account without
your approval prior to each transaction. Discretionary authority is typically granted by the investment
advisory agreement you sign with our firm and the appropriate trading authorization forms.
You may limit our discretionary authority (for example, limiting the types of securities that can be
purchased or sold for your account) by providing our firm with your restrictions and guidelines in
writing.
We may also offer non-discretionary portfolio management services. 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.
Also, as part of our portfolio management services, in addition to other types of investments (see
disclosures below in this section), we may invest your assets according to one or more risk-based
portfolios developed and managed by our firm. These portfolios are designed for investors with varying
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degrees of risk tolerance ranging from a more aggressive investment strategy to a more conservative
investment approach. Clients whose assets are invested in these types of portfolios may not set
restrictions on the specific holdings or allocations within the portfolio, nor the types of securities that
can be purchased in these portfolios. Nonetheless, clients may impose restrictions on investing in
certain securities or types of securities in their account. In such cases, this may prevent a client from
investing in certain portfolios that are managed by our firm.
Portfolio Management Services - Investment Advisory Services for Pension and Retirement
Plans
We will provide discretionary investment management services or non-discretionary investment
advisory services to the fiduciaries of pension and retirement plans at the direction of the responsible
plan fiduciary.
Discretionary Investment Management Services
We will provide the following discretionary investment management services, acting as a fiduciary
of the Plan as defined under Section 3(38) of the Employee Retirement Income Security Act
(ERISA):
1. Provide ongoing and continuous discretionary investment management with respect to
the asset classes and designated investment alternatives (DIAs) available under the
plan in accordance with the plan's investment policies and objectives;
2. Select a broad range of investment options consistent with ERISA 404c and the
regulations thereunder;
3. Develop an Investment Policy Statement (IPS). The IPS establishes the investment
policies and objectives for the plan.
4. As part of our services, we have developed risk-based model portfolios that we actively
manage as DIAs and make available for plan participants to allocate some or all of their
account balance.
5. Monitor investment options by preparing periodic investment reports that document
investment performance, consistency of fund management and conformance to the
guidelines set forth in the IPS and determine whether to maintain or remove and
replace DIAs;
6. Meet with client on a periodic basis to discuss the reports and the investment decisions;
7. For plans with participant directed investment options, the plan sponsor may elect to
have a qualified default investment alternative (QDIA) for plan participants who fail to
make an investment election. Upon election, we will select and monitor the DIA(s) to
serve as the QDIA.
Non-discretionary Investment Adviser Services
We will provide the following fiduciary services acting as a fiduciary of the Plan as defined under
Section 3(21) of the Employee Retirement Income Security Act (ERISA):
1. Provide non-discretionary investment advice to the responsible plan fiduciary about
asset classes and DIAs available for the plan in accordance with the plan's investment
policies and objectives. The responsible plan fiduciary will have the final decision-
making authority regarding the initial selection, retention, removal, and additions of
DIAs.
2. Assist the responsible plan fiduciary with the selection of a broad arrangement of
investment options consistent with ERISA section 404(c ) and the regulations
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thereunder.
3. Assist in the development of an IPS. The responsible plan fiduciary will have the
responsibility for establishing and maintaining the IPS.
4. Assist in monitoring DIAs by preparing periodic investment reports that document
investment performance, consistency of fund management and conformance to the IPS
guidelines and make recommendations to maintain or remove and replace DIAs.
5. Meet with the responsible plan fiduciary periodically to discuss the reports and the
investment recommendation.
6. Educate the responsible plan fiduciary on their duties to the plan and provide
recommendations on how to meet those responsibilities, including the use of an
investment committee.
7. Provide non-discretionary investment advice to the responsible plan sponsor on the
selection of a QDIA, and, upon the decision to have a QDIA, assist the plan sponsor in
selecting the DIA(s) to serve as the QDIA.
Other Services for Pension and Retirement Plans
Upon request and authorization by the responsible plan fiduciary we will provide non-discretionary
fiduciary investment advice to plan participants regarding selection of DIAs available to the plan.
Financial Planning Services
We offer financial planning services which typically involve providing a variety of advisory services to
clients regarding
the management of their financial resources based upon an analysis of their
individual goals and needs. These services can range from broad-based financial planning to
consultative or single subject planning, including retirement planning.
An investment adviser representative will first conduct a complimentary initial consultation with you.
During or after the initial consultation, if you decide to engage us for financial planning services, we will
conduct additional meetings with you to gather information about your financial circumstances and
objectives. We may also use financial planning software to determine your current financial position
and to define and quantify your long-term goals and objectives. Once we specify those long-term
objectives (both financial and non-financial), we will develop shorter-term, targeted objectives. Once
we review and analyze the information you provide to our firm and the data derived from our financial
planning software, we will deliver a written plan to you, designed to help you achieve your stated
financial goals and objectives.
Financial plans are based on your financial situation at the time we present the plan to you, and on the
financial information you provide to us. Clients are advised that certain assumptions may be made with
respect to interest and inflation rates and the use of past trends and performance of the market and
economy. Past performance is in no way an indication of future performance. We cannot offer any
guarantees or promises that your financial goals and objectives will be met. You must promptly notify
our firm if your financial situation, goals, objectives, or needs change.
You are under no obligation to act on our financial planning recommendations. Should you choose to
act on any of our recommendations, you are not obligated to implement the financial plan through any
of our other investment advisory or affiliated services. Moreover, you may act on our recommendations
by placing securities transactions with any brokerage firm.
Selection of Other Advisers
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We have previously offered the services where we may recommend that you use the services of a third
party money manager ("TPMM") to manage all, or a portion of, your investment portfolio. This service
is no longer being offered and is only available to existing clients who previously contracted for these
services. We will continue to monitor the TPMM(s)' performance to ensure its management and
investment style remains aligned with your investment goals and objectives for those clients who have
previously elected this service.
Pension Consulting Services
We offer pension consulting services to Qualified and non-Qualified Retirement Plans, including
Pension Plans, 401(k) and 403(b) Plans, Profit Sharing Plans, Simple IRA Plans, SEPs, Defined
Benefit Plans, Deferred Compensation Plans, Pooled Employer Plans, and other employee benefit
plans and their fiduciaries based upon the needs of the plan and the services requested by the plan
sponsor or named fiduciary. The services we offer are designed to assist retirement plan sponsors,
trustees and/or plan committees in meeting their plan management and fiduciary obligations under the
Employee Retirement Income Security Act or other applicable law.
In general, these services may include an existing plan review and analysis, plan-level advice
regarding fund selection and investment options, investment performance monitoring, and/or ongoing
consulting. Additional services may include:
•Creation or Review of Investment Policy Statements;
•Creation of Portfolio Diversification Models;
•Investment and Portfolio monitoring and Performance Reporting;
•Reviews of Third Party Advisers; and,
•Reviews of Plan Menu of Investments.
We offer these services in a fiduciary capacity as an ERISA 3(38) discretionary investment manager or
as an ERISA 3(21) non-discretionary investment adviser, to assist the plan sponsor in meeting their
fiduciary obligations.
The ultimate decision to act on behalf of the plan shall remain with the plan sponsor or other named
fiduciary.
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We may also provide additional types of pension consulting services to plans on an individually
negotiated basis. All services, whether discussed above or customized for the plan based upon
requirements from the plan fiduciaries (which may include additional plan-level or participant-level
services) shall be detailed in a written agreement and be consistent with the parameters set forth in the
plan documents.
Either party to the pension consulting agreement may terminate the agreement upon written notice to
the other party in accordance with the terms of the agreement for services. The pension consulting
fees will be prorated for the quarter in which the termination notice is given and any unearned fees will
be refunded to the client.
Types of Investments
We primarily offer advice and portfolio management on No-load mutual funds, Corporate and Municipal
Bonds, Certificates of deposit, Collective Investment Trusts, and Exchange Traded Funds. Refer to the
Methods of Analysis, Investment Strategies and Risk of Loss below for additional disclosures on this
topic.
Additionally, we may advise you on various other types of investments based on your stated goals and
objectives. We may also provide advice on any type of investment held in your portfolio at the inception
of our advisory relationship.
Since our investment strategies and advice are based on each client's specific financial situation, the
investment advice we provide to you may be different or conflicting with the advice we give to other
clients regarding the same security or investment.
Retirement Account Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field
Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's
Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the
following acknowledgment to you.
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 and/or 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:
•Meet a professional standard of care when making investment recommendations (give prudent
advice);
•Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest.
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We benefit financially when you rollover your assets from a retirement account that we do not manage
to your participant account in a retirement plan that we do manage, or to an individual retirement
account for which we provide investment advice and portfolio management services. We may also
benefit financially when you rollover your assets held in a retirement plan that we manage to an
individual retirement account for which we provide investment advice and portfolio management
services. We benefit because the increase in our assets under management will, in turn, increase our
advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
Assets Under Management
As of December 31, 2022, we provide continuous management services for $765,567,458 in client
assets on a discretionary basis, and $14,458,087 in client assets on a non-discretionary basis. We also
manage $150,000 in client assets on a non-continuous basis.