A. Firm Information
West Michigan Advisors, LLC (herein “WMA” or the “Advisor”) is a registered investment advisor with the U.S.
Securities and Exchange Commission (“SEC”). WMA was organized as a limited liability company (“LLC”) under
the laws of the State of Michigan in December 2020. WMA is owned and operated by Kevin H. Clark (Managing
Partner), Aaron M. Clark (Partner), Thomas S. Bosch (Partner) and Symphony Grove LLC (Partner), a Michigan
Limited Liability Company owned by the KDC Revocable Trust.
This Disclosure Brochure provides information regarding the qualifications, business practices, and the
advisory services provided by WMA. For information regarding this Disclosure Brochure, please contact Lonny
Elfenbein, Chief Compliance Officer at (513) 977-8330
B. Advisory Services Offered
WMA offers investment advisory services designed to meet the needs of individuals, high net worth individuals,
trusts, estates, charitable organizations and businesses (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under applicable laws and regulations. As a fiduciary, the
Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. WMA’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more
information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading.
Investment Management Services
WMA provides customized investment advisory solutions for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary investment management and related
advisory services. WMA works with each Client to identify their investment goals and objectives as well as risk
tolerance and financial situation in order to create an investment strategy. WMA will construct Client portfolios
utilizing exchange-traded funds (“ETFs”), mutual funds, individual equities, and/or individual bonds. The Advisor
also includes alternative investment vehicles and other types of investments, as appropriate, to meet the needs
of its Clients. WMA will may retain the Client’s legacy investments based on portfolio fit, tax implications and/or
other factors.
WMA’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate
investments that have been held for less than one year to meet the objectives of the Client or due to market
conditions. WMA will construct, implement and monitor the portfolio to ensure it meets the goals, objectives,
circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place
reasonable restrictions on the types of investments to be held in their respective portfolio, subject to
acceptance by the Advisor.
WMA evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. WMA may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. WMA may recommend specific positions to increase sector or asset class weightings. The Advisor may
recommend employing cash positions as a possible hedge against market movement. WMA may recommend
selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or
sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s]
in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed
unacceptable for the Client’s risk tolerance.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over
the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based
account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a
new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll
over a retirement account to an account managed by the Advisor.
At no time will WMA accept or maintain custody of a Client’s funds or securities, except for the limited authority
as detailed in Item 15 – Custody. All Client assets will be managed within their designated brokerage account or
pension account, pursuant to the Client investment advisory agreement.
Use of Independent Managers - WMA may recommend that a Client utilize one or more unaffiliated investment
managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s
investment portfolio. In such instances, the Client may be required to authorize and enter into an advisory
agreement with the Independent Manager[s] that defines the terms in which the Independent Manager[s] will
provide
investment management and related services. The Advisor may also assist in the development of the
initial policy recommendations and managing the ongoing Client relationship. The Advisor will perform initial and
ongoing oversight and due diligence over the selected Independent Manager[s] to ensure the Independent
Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best
interests. The Client, prior to entering into an agreement with unaffiliated investment manager[s] or investment
platform[s], will be provided with the Independent Manager's Form ADV 2A (or a brochure that makes the
appropriate disclosures).
Financial Planning Services
WMA will typically provide a variety of financial planning services to Clients, pursuant to an agreement between
the Advisor and the Client or included in an overall wealth management engagement. The Advisor, at its sole
discretion, may waive its financial planning fee. Services are offered in several areas of a Client’s financial
situation, depending on their goals and objectives.
Generally, such financial planning services will involve preparing a financial plan or rendering a financial
consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one
or more areas of need, including, but not limited to investment planning, retirement planning, estate planning,
personal savings, education savings, insurance needs, and other areas of a Client’s financial situation.
A financial plan developed for or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs.
WMA may also refer Clients to an accountant, attorney or other specialist, as appropriate for their unique
situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s
financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may
not provide a written summary. Plans or consultations are typically completed within six months of contract date,
assuming all information and documents requested are provided promptly.
Financial planning and consulting recommendations poses a potential conflict between the interests of the
Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Client
engage the Advisor for investment management services or to increase the level of investment assets with the
Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to
implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If
the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to
implement the transaction through the Advisor.
Retirement Plan Advisory Services
WMA provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the
company (the “Plan Sponsors”) The Advisor’s retirement plan advisory services are designed to assist the Plan
Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized
to the needs of the Plan and Plan Sponsor. Services generally include:
• Plan Participant Enrollment and Education Tracking
• Ongoing Investment Recommendation and Assistance
• Ongoing Investment Management (ERISA 3(38))
• Ongoing Investment Recommendations (ERISA 3(21))
These services are provided by WMA serving in the capacity as a fiduciary under the Employee Retirement
Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan
Sponsor is provided with a written description of WMA’s fiduciary status, the specific services to be rendered and
all direct and indirect compensation the Advisor reasonably expects under the agreement.
C. Client Account Management
Prior to engaging WMA to provide investment advisory services, each Client is required to enter into one or more
advisory agreements with the Advisor that define the terms, conditions, authority and responsibilities of the
Advisor and the Client. These services may include:
Establishing an Investment Strategy – WMA, in connection with the Client, will develop a strategy that
seeks to achieve the Client’s investment goals and objectives.
Asset Allocation – WMA will develop a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation and tolerance for risk for each Client.
Portfolio Construction – WMA will develop a portfolio for the Client that is intended to meet the
stated goals and objectives of the Client.
Investment Management and Supervision – WMA will provide investment management and
ongoing oversight of the Client’s portfolio.
D. Wrap Fee Programs
WMA does not manage or place Client assets into a wrap fee program.
E. Assets Under Management
As of December 31, 2022, WMA manages $494,777,070 in Client assets, all of which are managed on a
discretionary basis. Clients may request more current information at any time by contacting the Advisor.