A. Firm Information
Dillow Wealth Management LLC (“Dillow Wealth Management” or the “Advisor”) is a registered investment advisor
with the U.S. Securities and Exchange Commission. The Advisor is organized as a Limited Liability Company (LLC)
under the laws of the State of Illinois. Dillow Wealth Management was founded in March 2021 and is owned and
operated by Timothy L. Dillow, Christopher L. Hughes, and John A. Staab. This Disclosure Brochure provides
information regarding the qualifications, business practices, and the advisory services provided by Dillow Wealth
Management.
B. Advisory Services Offered
Dillow Wealth Management 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. Dillow Wealth Management'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
Dillow Wealth Management provides customized wealth management services for its Clients. This is achieved
through continuous personal Client contact and interaction while providing a broad range of comprehensive
financial planning in connection with discretionary and/or non-discretionary investment management of Client
portfolios. These services are described below.
Investment Management Services
Dillow Wealth Management provides customized investment advisory solutions for its Clients. This is achieved
through continuous personal Client contact and interaction while providing discretionary and non-discretionary
investment management and related advisory services. Dillow Wealth Management 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. Dillow Wealth Management 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 Independent managers, individual stocks, bonds or options contracts to meet the needs of
its Clients. The Advisor may also recommend structured performance and income notes for certain clients. The
Advisor may retain certain types of investments based on a Client’s legacy investments based on portfolio fit and/or
tax considerations.
Dillow Wealth Management’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. Dillow Wealth Management 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.
Dillow Wealth Management evaluates and selects investments for inclusion in Client portfolios only after applying
its internal due diligence process. Dillow Wealth Management may recommend, on occasion, redistributing
investment allocations to diversify the portfolio. Dillow Wealth Management 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.
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Dillow Wealth Management 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.
Under certain circumstances, Dillow Wealth Management may accept or maintain custody of Client’s funds or
securities. Please see Item 15 – Custody for more information.
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.
Use of Independent Managers – Dillow Wealth Management 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).
Sub-Advisory Services – Through its investment management services, Dillow Wealth Management may also provide
investment sub-advisory services to other registered investment advisors (“Third-Party RIAs”) or pooled investment
vehicles.
Pooled Investment Vehicles: Dillow Wealth Management serves as a sub-advisor to a pooled investment
vehicle (a “Private Fund”). In such instances, Dillow Wealth Management is responsible for sub-advisory
services to the fund.
These services are detailed in the offering
documents for the Private Fund, which include as applicable,
operating agreements, private placement memorandum, and/or term sheets, subscription agreements,
separate disclosure documents, and all amendments thereto (“Offering Documents”).
The Advisor sub-advises the Private Fund based on the investment objectives, policies and guidelines as
set forth in the respective Offering Documents and not in accordance with the individual needs or
objectives of any particular investor therein. Each prospective investor interested in investing in a Private
Fund is required to complete a subscription agreement in which the prospective investor attests as to
whether or not such prospective investor meets the qualifications to invest in the Private Fund and further
acknowledges and accepts the various risk factors associated with such an investment. A conflict of
interest exists as the Advisor has a financial incentive to place Client assets into the Private Fund. In order
to mitigate this conflict, the Advisor will offset advisory fees for any Clients invested into the Private Fund.
For more detailed information on investment objectives, policies and guidelines, please refer to the
Private Fund’s Offering Documents.
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Third Party RIAs: Dillow Wealth Management can be engaged by other investment advisers, including
those that Dillow Wealth Management recommends as an Independent Manager, to provide its services to
that investment adviser’s clients. This can include any of the Firm’s services listed above. In that
relationship, the client will continue to have an engagement with their primary investment adviser and
Dillow Wealth Management will be engaged by that investment adviser to provide services to the client.
Depending on the particular client and/or service, the client may have a direct relationship with Dillow
Wealth Management or Dillow Wealth Management may merely provide its services to the other
investment adviser.
Financial Planning Services
Dillow Wealth Management typically provides financial planning services as part of its overall wealth management
services. Dillow Wealth Management may also provide financial planning services on a standalone basis pursuant
to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation,
depending on their goals and objectives. 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. This
planning or consulting 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.
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.
Dillow Wealth Management 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 and consulting 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.
Retirement Plan Advisory Services
Dillow Wealth Management provides 3(21) 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. Each engagement is customized to the needs
of the Plan and Plan Sponsor. Services generally include:
• Plan Design and Strategy
• Plan Review and Evaluation
• Executive Planning & Benefits
• Investment Selection
• Plan Fee and Cost Analysis
• Plan Committee Consultation
• Fiduciary and Compliance
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• Participant Education
Certain of these services are provided by Dillow Wealth Management 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 Dillow Wealth Management 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 Dillow Wealth Management 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 – Dillow Wealth Management, in connection with the Client, will
develop a strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Dillow Wealth Management 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 – Dillow Wealth Management will develop a portfolio for the Client that is intended to
meet the stated goals and objectives of the Client.
• Investment Management and Supervision – Dillow Wealth Management will provide investment
management and ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Dillow Wealth Management does not manage or place Client assets into a wrap fee program. Investment
management services are provided directly by Dillow Wealth Management.
E. Assets Under Management
As of December 31, 2023, Dillow Wealth Management manages $168,600,000 in Client assets, $80,100,000 of
which are managed on a discretionary basis and $88,500,000 on a non-discretionary basis. Clients may request
more current information at any time by contacting the Advisor.