We offer a wrap fee program as described in this Wrap Fee Program Brochure. A wrap fee
program is generally considered any arrangement under which clients receive investment
advisory services and the execution of client transactions for a specified fee or fees not
based upon transactions in their accounts. All of the Firm’s investment management
clients will be offered the wrap fee program structure that includes, as a single fee, the
securities transaction costs for trading in Client accounts along with the investment
advisory fees earned by the Firm. Our Firm receives a portion of the wrap fee for the
services rendered. While traditional Wrap Fee Programs are often rigid, pre-packaged
investment programs, the Firm customizes its investment strategies individually for its
Clients. Prior to receiving services through the Program, clients are required to enter into
a written agreement with the Firm’s setting forth the relevant terms and conditions of the
investment advisory relationship (the “Agreement”).
OUR WRAP ADVISORY SERVICES
Our Firm provides investment advice to clients in need of retirement income planning.
Before we enter an Advisor-Client relationship, we may offer a complimentary general
consultation to discuss services available, give a prospective client time to review services
desired, and determine whether a relationship might benefit the client. Investment
advisory services begin only after we and the client formalize the relationship with a
properly executed agreement.
Our Firm offers four-step financial planning process called the Retirement Readiness
Review which includes the following:
Income Gap Analysis: The first step is an income gap analysis to determine if the
client is using income sources properly and in the most tax-efficient method to
support their lifestyle goals in retirement. We will also discover if the client has
adequate income to meet his/her future needs and the ever-increasing cost of
inflation. The client’s personal inflation rate may be different than government-
quoted inflation rates because of the ways in which he/she actually spends money.
Risk Analysis: The second step is a risk analysis to ensure the client’s investment
risk exposure is one he/she is comfortable with and is aligned with his/her
investment allocation strategies. It also reveals many of the true fees the client is
paying in his/her investments. A simple behavioral analytics tool will help him/her
OCTOBER 2023 | PAGE 5
determine what their risk comfort level is and help him/her avoid losses he/she is
not prepared to handle or not aware of.
Survivorship Analysis: The third step is to evaluate the economic impact of losing a
spouse. The income streams for the remaining spouse change and the tax rate will
increase for the surviving spouse. Our process will illustrate this to our clients so
we can help them make planning decisions to make sure the standard of living for
the remaining spouse is not compromised.
Tax Bucket Analysis: The fourth step is a complete look-forward review of his/her
current tax situation, and to address the use of taxable, tax deferred and tax-free
strategies, as well as a discovery of missed opportunities for offsetting gains and
losses or ROTH Conversion strategies. Our Retirement Readiness Review is
designed to help the client implement the correct strategy to lower or eliminate
certain taxes and find money falling through the cracks now and in the client’s
future.
Following the conclusion of the planning services, we may make recommendations
regarding implementation of the financial strategies discussed.
For accounts that engage in the Firm’s investment management services, we advise
advisory accounts on a discretionary basis. Once we have determined a profile and
investment plan with a client, we will execute the day-to-day transactions without seeking
prior client consent but within the expected investment guidelines discussed with the
client. Account supervision is guided by the client’s written profile and investment plan.
We primarily allocate client assets among various equities, Exchanged Traded Funds
(“ETFs”), cash, no-load or load-waived mutual funds in accordance with their stated
investment objectives. All of which are considered asset allocation categories for the
client’s investment strategy.
During personal discussions with clients, we determine the client’s objectives, time
horizons, risk tolerance, and liquidity needs. As appropriate, we also review a client’s prior
investment history, as well as family composition and background. Based on client needs,
we develop a client’s personal profile and investment plan. We then create and manage
the client’s investments based on that agreed upon financial plan. It is the client’s
obligation to notify us immediately if circumstances have changed with respect to their
goals. Once we have determined the types of investments to be included in a client’s
portfolio and have allocated the assets, we provide ongoing investment review and
management services.
OCTOBER 2023 | PAGE 6
When managing client accounts through the Firm ’s investment management services, we
most often manage a client’s Account in accordance with one or more investment models
developed either internally by the Firm’s Firm or developed externally by Model Managers.
When client Accounts are managed using models, investment selections are based on the
underlying model and we do not develop customized (or individualized) portfolio holdings.
Disclosure Regarding Rollover Recommendations
A client or prospect leaving an employer typically has four options regarding an existing
retirement plan (and may engage in a combination of these options): (i) leave the money
in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s
plan, if one is available and rollovers are permitted, (iii) rollover to an Individual Retirement
Account (“IRA”), or (iv) cash out the account value (which could, depending upon the
client’s age, result in adverse tax consequences). Our Firm may recommend an investor
roll over plan assets to an IRA for which the Firm provides investment advisory services.
As a result, the Firm and its representatives may earn an asset-based fee. In contrast, a
recommendation that a client or prospective client leave their plan assets with their
previous employer or roll over the assets to a plan sponsored by a new employer will
generally result in no compensation to the Firm. Our Firm therefore has an economic
incentive to encourage a client to roll plan assets into an IRA that the Firm will manage,
which presents a conflict of interest. To mitigate the conflict of interest, there are various
factors that the Firm will consider before recommending a rollover, including but not
limited to: (i) the investment options available in the plan versus the investment options
available in an IRA, (ii) fees and expenses in the plan versus the fees and expenses in an
IRA, (iii) the services and responsiveness of the plan’s investment professionals versus
those of the Firm, (iv) protection of assets from creditors and legal judgments, (v) required
minimum distributions and age considerations, and (vi) employer stock tax consequences,
if any. All rollover recommendations are also reviewed by the Firm’s Chief Compliance
Officer in a best effort to determine that the recommendation to a client was reasonable
or that the client has determined to make the rollover after being provided ample
information about their options. No client is under any obligation to roll over plan assets
to an IRA advised by the Firm or to engage the Firm to monitor and/or advise on the
account while maintained with the client's employer. Our Firm’s Chief Compliance Officer
remains available to address any questions that a client or prospective client has regarding
this disclosure.
RELATIVE COST OF THE PROGRAM
OCTOBER 2023 | PAGE 7
A wrap fee program allows Clients to pay a specified fee for investment advisory services
and the execution of transactions. Clients do not pay brokerage commissions, markups or
transaction charges for execution of transactions in addition to the advisory fee however,
most investments trade without transaction fees today, so the Firm’s payment of these
and other incidental custodial related expenses should not be considered a significant
factor in determining the relative value of the Firm’s wrap program.
Clients receive investment management services through Peterson Financial Group.
Peterson Financial Group utilizes a third-party IMO (AEWM) for the billing of these services
through a Wrap Program. Fees will be calculated as a percentage of assets under
management (AUM) based on the average daily balance of the account(s) and deducted
from Client account(s) in arrears on a monthly basis.
Although neither Client nor the Firm pay a transaction charge for transactions in the
account(s), Client should be aware that the Firm pays AEWM an annual administrative /
asset-based pricing fee based upon a percentage of assets under management within the
Wrap Fee Program account – this percentage is capped at 0.30% for accounts in the
Platform Program with AEWM. Because the Firm pays an annual administration / asset-
based pricing fee in lieu of paying transaction charges, there is a conflict of interest. Client
understands that the cost to the Firm of the annual administration fee may be a factor that
he/she considers when deciding how much of an annual advisory fee to assess to the
account(s).
The wrap program fees do not exceed 1.40% and will cover the cost charged by Peterson
Financial Group, AEWM, any other third-party partners we utilize and the custodian
(Fidelity). No other management fees are charged to Client account by the Firm.
When invested in a Model there is typically a small percentage invested in cash as part of
that model (i.e., 1%). That “cash” will be included in the AUM fee. Cash held in other types
of accounts, such as a stand-alone money market, a “contribution distribution sleeve” or
“non-managed” account (used for purposes of scheduled distributions or flexibility of
withdrawals) is “not” included in the fee.
Our employees and their family-related accounts are charged a reduced fee for the Firm’s
services.
In some instances, we may not have discretion and an account is set up for client directed
trades only. Our Firm has the ability to view and initiate client-directed trades but the Firm
does not maintain ongoing management or supervision of the accounts. For these
accounts, the custodian bills a $30 annual administration fee. Our Firm does not receive
any compensation.
OCTOBER 2023 | PAGE 8
Either Peterson Financial Group or the Client may terminate the management agreement
immediately upon written notice to the other party. The management fee will be pro-rated
to the date of termination, for the month in which the cancellation notice was given and
billed to Client account. Upon termination, Clients are responsible for monitoring the
securities in Client account, and we will have no further obligation to act or advise with
respect to those assets. In the event of client’s death or disability, Peterson Financial Group
will continue management of the account until we are notified of client’s death or disability
and given alternative instructions by an authorized party.
OTHER TYPES OF FEES & EXPENSES
SIGNAL PROVIDER
Our Firm does engage the services of unaffiliated and independent registered investment
advisor(s) (“Signal Providers”) to receive buy and sell signals, research, or other
information that the Firm uses to manage a particular strategy/portfolio. Such Signal
Providers will not act as fiduciaries with respect to any client as they are engaged to provide
market-related services to the Firm. In providing individualized investment advice, the Firm
will invest a client’s assets in accordance with the recommendations of one or more Signal
Providers or may invest the account in any manner it deems appropriate based on the
client’s personal objectives. All fees incurred by the subscription to various Signal Providers
are paid by Peterson Financial Group (as a percentage of the fees generated within a
particular strategy). Thus, a portion of the advisory fee paid by a client to Peterson Financial
Group may be used to compensate such third-party providers or consultants.
ADDITIONAL FEES AND EXPENSES:
In addition to the Wrap Fee paid to Peterson Financial Group, clients may also incur certain
charges imposed by other third parties, trust companies, banks and other financial
institutions (collectively “Financial Institutions”). These additional charges may include fees
charged by the margin costs, charges imposed directly by a mutual fund or ETF in a client’s
account, as disclosed in the fund’s prospectus (e.g., fund management fees and other fund
expenses), deferred sales charges, regulatory fees assessed by SEC and/or FINRA odd-lot
differentials, transfer taxes, wire transfer and electronic fund fees, and taxes on brokerage
accounts and securities transactions. These fees are not included within the wrap program
fee Clients are charged by the Firm.
Non-Transaction Fee (NTF) Mutual Funds
When selecting investments for Clients’ portfolios we might choose mutual funds on Client
account custodian’s Non-Transaction Fee (NTF) list. This means that Client account
custodian will not charge a transaction fee or commission associated with the purchase or
sale of the mutual fund.
OCTOBER 2023 | PAGE 9
The mutual fund companies that choose to participate in Client custodian’s NTF fund
program pay a fee to be included in the NTF program. The fee that a mutual fund company
pays to participate in the program is ultimately borne by the owners of the mutual fund
including clients of the Firm. When we decide whether to choose a fund from Client
custodian’s NTF list or not, we consider the Firm’s expected holding period of the fund, the
position size and the expense ratio of the fund versus alternative funds. Depending on the
Firm’s analysis and future events, NTF funds might not always be in Client best interest.
Regulatory Fees
To facilitate the execution of trades, regulatory Trading Activity Fees (TAF) are added to
applicable sales transactions. The Securities and Exchange Commission (SEC) regulatory
fee is assessed on client accounts for sell transactions, and a FINRA fee is assessed on client
accounts for sell transactions, for certain covered securities. This fee is not charged by the
Firm but is accessed and collected by the custodian. The Custodian that the Firm uses, is
a FINRA member firm. These fees recover the costs incurred by the SEC and FINRA, for
supervising and regulating the securities markets and securities professionals. The fee
rates vary depending on the type of transaction and the size of that transaction.
For more information on the SEC and FINRA fees, please visit their websites:
www.sec.gov/fast-answers/answerssec31htm.html
www.finra.org/industry/trading-activity-fee
ADMINISTRATIVE SERVICES
Through the Firm’s relationship with AE Wealth Management (AEWM), the Firm utilizes
AEWM’s technology platform to support data reconciliation, performance reporting, fee
calculation and billing, research, client database maintenance, quarterly performance
evaluations, payable reports, web site administration, models, trading platforms, and
other functions related to the administrative tasks of managing client accounts. Due to this
arrangement, AEWM will have access to client information, but AEWM will not serve as an
investment Advisor to Clients. Peterson Financial Group and AEWM are non-affiliated
companies. AEWM charges the Firm an annual fee for each account administered by
AEWM. The annual fee is paid from the portion of the management fee retained by us.