A. Firm Information
Three Sixty Wealth Management, LLC (“360 Wealth” or the “Advisor”) is a registered investment advisor with the
U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company
(“LLC”) under the laws of the State of Illinois. 360 Wealth was founded in March 2011 and is owned and operated
by James Dischert (Founder). Since 2011, Three Sixty Wealth Management, LLC has been used as a doing
business as name for James Dischert for purposes of marketing while affiliated with other investment advisers
and the implementation of insurance related products. This Disclosure Brochure provides information regarding
the qualifications, business practices, and the advisory services provided by 360 Wealth.
B. Advisory Services Offered
360 Wealth offers investment advisory services to individuals, high net worth individuals, trusts, estates,
businesses, and retirement plans (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the 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. 360 Wealth’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.
Wealth Management Services
360 Wealth provides Clients with comprehensive wealth management services, which generally includes a broad
range of comprehensive financial planning and consulting services in connection with discretionary management
of investment portfolios. These services are described below:
Investment Management Services – 360 Wealth provides customized investment management services for its
Clients as a component of its wealth management service. This is achieved through continuous personal Client
contact and interaction while providing discretionary investment management and related advisory services. 360
Wealth works closely with each Client to identify their investment goals and objectives as well as risk tolerance
and financial situation in order to create a portfolio strategy. 360 Wealth will then construct an investment
portfolio, consisting of low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the
Client’s investment goals. The Advisor may also utilize individual stocks, or bonds to meet the needs of its
Clients. The Advisor may retain certain legacy investments based on portfolio fit and/or tax considerations.
360 Wealth’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate
positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. 360 Wealth 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.
360 Wealth evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. 360 Wealth may recommend, on occasion, redistributing investment allocations to diversify
the portfolio. 360 Wealth 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. 360 Wealth
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 the Client, generating cash to meet
Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
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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 360 Wealth accept or maintain custody of a Client’s funds or securities, except for the limited
authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at
the Custodian, pursuant to the terms of the advisory agreement, please see Item 12 – Brokerage Practices.
Financial Planning Services – 360 Wealth will provide a broad range of financial planning services to Clients as a
component of its wealth management services. Financial planning services are offered in several areas of a
Client’s
financial situation, depending on their goals and objectives. Financial planning services may encompass
one or more areas of need, including but not limited to; investment planning, retirement planning, personal
savings, education savings, insurance needs, and other areas of a Client’s financial situation.
Generally, such financial planning services involve preparing a formal financial plan or rendering a specific
financial consultation based on the Client’s financial goals and objectives. A financial plan developed for, 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, insurance needs and/or charitable giving
programs. The Advisor will provide ongoing oversight and monitoring of the recommendations and goals set forth
in the financial plan. Clients will have access to contact and/or meet with the Advisor throughout the year
depending on the needs of the Client. The Advisor will conduct a formal review at least annually to review the
financial plan and ongoing implementation with the Client. Please see Item 13 – Review of Accounts for
additional information.
360 Wealth may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique
situation. For certain financial planning engagements, the Advisor will provide a written summary of the 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 (6) months of contract
date, assuming all information and documents requested are provided promptly.
Financial planning recommendations pose a conflict between the interests of the Advisor and the interests of the
Client. For example, the Advisor has an incentive to recommend that Clients 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.
Use of Independent Managers
360 Wealth will recommend that Clients utilize one or more unaffiliated investment managers or investment
platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the
Client’s needs and objectives. The Advisor will perform initial and ongoing oversight and due diligence over each
Independent Manager to ensure the strategy remains aligned with Clients investment objectives and overall best
interests. The Advisor will also assist the Client in the development of the initial policy recommendations and
managing the ongoing Client relationship. The Client will be provided with the Independent Manager's Form ADV
Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures).
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Retirement Plan Advisory Services
360 Wealth provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the
company (the “Plan Sponsor”). 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:
• Investment Management Services (ERISA 3(38))
• Ongoing Investment Recommendation and Assistance
These services are provided by 360 Wealth 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 360 Wealth’s fiduciary status, the specific services to be
rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement.
C. Client Account Management
Prior to engaging 360 Wealth to provide investment advisory services, each Client is required to enter into one or
more 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 – 360 Wealth, in connection with the Client, will develop a strategy
that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – 360 Wealth 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 – 360 Wealth will develop a portfolio for the Client that is intended to meet the
stated goals and objectives of the Client.
• Investment Management and Supervision – 360 Wealth will provide investment management and
ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
360 Wealth does not manage or place Client assets into a wrap fee program. Investment management services
are provided directly by 360 Wealth.
E. Assets Under Management
As of December 31, 2023, 360 Wealth manages approximately $135,830,635 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.