Confluence History
Confluence Wealth Services, Inc. d/b/a Confluence Financial Partners (“Confluence”) was
established in 2021 and is principally owned by Confluence Financial Partners, Inc. (the “holding
company”). The owners of the holding company are Gregory J. Weimer, James A. Wilding, and
Gregory J. Weimer II. As a wealth management firm, Confluence is on a mission to help people
plan for a brighter future by focusing on what matters most. The firm builds long-lasting, trusted
relationships with clients by going all in, dedicating the team’s resources, energy, and passion
into delivering value to every client. Confluence has been providing comprehensive financial
planning and wealth management services to individuals, professionals, business owners,
corporate executives, retirement plans and businesses since 2013.
As a registered investment adviser subject to Section 206 of the Advisers Act, Confluence acts as
a Fiduciary related to the conduct of its investment advisory services. As such, Confluence has
an obligation to act in the best interest of its clients guided by the core fiduciary duties of loyalty
and care. The firm works together to define clients’ unique financial, life, and legacy goals, then
crafts a comprehensive plan carefully designed to achieve them. To support this, Confluence is
focused on building a team of associates who share an uncommon passion, commitment,
willingness to collaborate, and belief that improvement is always possible.
Confluence Financial Partners is here to help clients maximize their lives and legacies through
thoughtful financial planning, intelligent investing, continual improvement, and exceptional
service. It’s believed that this has drawn clients to engage with Confluence for the advice and
services that are provided, including investment advisory and wealth planning services described
in more detail below.
Advisory Services
Wealth Management
Confluence provides discretionary and non-discretionary wealth management services to a broad
range of clients. Wealth management services primarily include investing client assets in
proprietary investment strategies advised by the Adviser. Confluence determines the investment
objectives and risk tolerance for each wealth management client during the account opening
process and reassesses periodically thereafter. Once the client’s risk tolerance, time horizon and
investment objective are established, Confluence will recommend a proprietary investment
strategy/ies or individually design a portfolio of investments which include one or a combination
of stocks, bonds, mutual funds, ETFs, options, allocation models, and other securities and/or
contracts relating to the same, including investing assets in short-term money market
instruments.
We encourage clients to inform us in the event of any significant life changes, such as setting a
retirement date, having a child, etc., so that we can perform an assessment to determine the
proper investment strategy from that point forward. Typically, we review accounts internally and
no less than annually with our clients, which should be sufficient given our long-term strategic
approach to money management. Each client will have the opportunity to place reasonable
restrictions on the types of investments to be held in their respective portfolio, subject to the
acceptance by Confluence.
Confluence’s investment strategies are primarily long-term focused, but we may buy, sell, or
reallocate positions that have been held less than one year to meet the objectives of a particular
strategy or due to market conditions.
Retirement Plan Services
Confluence provides retirement plan consulting services to sponsors of qualified retirement plans
as defined by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). The
services provided by Confluence vary from client to client and will be tailored to the specific needs
of the plan sponsor. Although not intended to be all inclusive, the retirement plan services
provided may include plan design consulting, fiduciary best practices assessment, basic
compliance reviews, investment policy development, fund menu design, fund manager search
and selection, fund replacements, asset allocation modeling, investment monitoring and review,
plan committee meetings, provider fee and service reviews, provider management, provider
search and selection, transition services to a new provider, Section 404(c) consulting, education
program strategy, and employee meetings.
Financial Plan Reviews
Confluence provides Financial Plan Reviews that encompass a review of the major aspects of
each client’s financial situation, focusing on retirement planning, an insurance review, and an
investment review. Following
the initial meeting with the client, the Wealth Manager defines
the scope of services that will be necessary to perform the client’s Financial Review.
Third-Party Money Managers
Confluence offers asset management services involving unaffiliated third-party money
managers (collectively hereinafter, “Third-Party Managers” or “TPMs”). Through these services,
Confluence can provide access to third-party money managers that can manage a portion or all
of the client’s assets.
Managed Stock Program
Confluence offers internally managed stock portfolios that are overseen by the firm’s
Investment Advisory Committee. The strategies are actively managed through quantitative
analysis of historical fundamental factors, with a focus on large-cap and mid-cap securities
domiciled in the United Sates. The strategies do not have a material cash allocation. The firm
requires a $100,000 account minimum.
IRA Rollovers
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.
Investors considering rolling over assets from a qualified employer-sponsored retirement plan
(“Employer Plan”) to an Individual Retirement Account (“IRA”) should review and consider the
advantages and disadvantages of an IRA rollover from their Employer Plan. A plan participant
leaving an employer typically has four options (and can engage in a combination of these
options):
(1) Leave the money in the former employer’s plan, if permitted;
(2) Rollover the assets to a new employer’s plan (if available and rollovers are permitted);
(3) Rollover Employer Plan assets to an IRA; or,
(4) Cash out the Employer Plan assets and pay the required taxes on the distribution.
At a minimum, Investors should consider fees and expenses, investment options, services,
penalty-free withdrawals, protection from creditors and legal judgments, required minimum
distributions, and employer stock. Confluence encourages you to discuss your options and review
the above listed considerations with an accountant, third-party administrator, investment adviser
to your Employer Plan (if available), or legal counsel, to the extent you consider necessary.
By recommending that you rollover your Employer Plan assets to an IRA advised by Confluence,
we will earn fees as a result. In contrast, leaving assets in your Employer Plan or rolling the assets
to a plan sponsored by your new employer likely results in little or no compensation to
Confluence, with the exception of circumstances in which Confluence is the investment advisor
to the plan that you are enrolled in, or if you hire Confluence to provide advice on your individual
Employer Plan assets. Confluence has an economic incentive to encourage investors to rollover
Employer Plan assets into an IRA managed by Confluence. Investors can face increased fees when
they move retirement assets from an Employer Plan to a Rollover IRA account. Even if there are
no costs associated with the IRA rollover itself, there will be costs associated with account
administration, investment management, or both. In addition to the fees charged by Confluence,
the underlying investment (mutual fund, ETF, annuity, or other investment) can also include fees.
Custodial and trading fees also apply. Investing in an IRA with Confluence will typically be more
expensive than an Employer Plan.
As of December 2023, Confluence had approximately $2.9 billion in discretionary regulatory
assets under management and $175 million of non-discretionary assets under management.