Description of Firm
Wildes Financial Strategies, Inc. is a registered investment adviser based in Georgetown, South
Carolina. We are organized as a corporation under the laws of the State of South Carolina, and we
have been providing investment advisory services since October 2017. Jeffrey D. Wildes is our firm's
owner, President, and Chief Compliance Officer.
As used in this Brochure, the words "we," "our," and "us" refer to Wildes Financial Strategies, Inc. and
the words "you," "your," and "client" refer to you as either a client or prospective client of our firm. Also,
you may see the term Associated Person in this Brochure. Our Associated Persons are our firm's
officers, employees, and all individuals providing investment advice on behalf of our firm.
Wrap Fee Program - Portfolio Management Services
We offer portfolio management services through a wrap-fee program ("Program") as described in this
Wrap Fee Program Brochure. We are the sponsor and investment adviser for the Program, and the
portfolio manager is our firm and same individuals within our firm. A wrap-fee program is a type of
investment program that provides clients with asset management and brokerage services for one all-
inclusive fee. At our discretion, we will provide complimentary financial planning and consulting
services to clients participating in the Program. Prior to becoming a client under the Program, you will
be required to enter into a separate written agreement with us that sets forth the terms and conditions
of the engagement and describes the scope of the services to be provided, and the fees to be paid.
If you participate in our wrap fee program, you will pay our firm a single fee, which includes money
management fees, certain transaction costs, and certain custodial and administrative costs. You are
not charged separate fees for the respective components of the total services. We receive a portion of
the wrap fee for our services. The overall cost you will incur if you participate in our wrap fee program
may be higher or lower than you might incur by separately purchasing the types of securities available.
Wildes Financial Strategies pays Schwab transaction costs for each executed trade in wrap fee
accounts. As a result, we have a financial incentive to limit orders for wrap fee accounts because
trades increase our transaction costs. Thus, an incentive exists to trade less frequently in a wrap
program.
As part of the Program, we also provide discretionary management services to certain held-away
assets that primarily consist of retirement accounts, such as a 401(k) account. These services are
provided on an unaffiliated third-party web-based platform where clients will go through a one-time
setup process enabling our firm to make any necessary trades or rebalancing to their portfolios. Under
no circumstances will we possess privileges that would impute custody to our firm under applicable
rules and regulations, including, but not limited to: maintaining your account log-in credentials on file;
having the ability to change your address on record or ability to authorize distributions from your
accounts; or authorization to open any new accounts on your behalf through the web-based platform.
Unless we agree to invoice you directly, these arrangements require clients to have a taxable account
with a qualified custodian where our advisory fees will be deducted from.
Client Investment Process
We offer discretionary portfolio management services tailored to meet our clients' needs and
investment objectives. If you participate in our discretionary portfolio management services, we require
you to grant our firm discretionary authority to manage your account. Discretionary authorization will
allow us to determine the specific securities, and the number of securities, to be purchased or sold for
your account without your approval prior to each transaction. Discretionary authority is typically granted
by the investment advisory agreement you sign with our firm and the appropriate trading authorization
forms. You may limit our discretionary authority (for example, limiting the types of securities that can be
purchased or sold for your account) by providing our firm with your restrictions and guidelines in
writing.
This Program allows you to choose an investment option that employs a model portfolio allocation
developed by our firm that is diversified among investment styles and/or asset classes. We will use the
information we gather to develop a strategy that enables our firm to customize an investment portfolio
for you in accordance with your risk tolerance and investment objectives. Once we construct an
investment portfolio for you, we will monitor your portfolio's performance and re-balance your
investments as required by changes in market conditions and in your financial circumstances.
Assets for program accounts are held at Charles Schwab & Co, Inc. and Raymond James &
Associates ("Custodians"). The Custodians also act as the executing broker/dealer for transactions
placed in Program accounts, and provide other administrative services as described throughout this
Brochure. To compare the cost of the wrap fee program with non-wrap fee portfolio management
services, you should consider the frequency of trading activity associated with our investment
strategies and the brokerage commissions charged by respective broker-dealer/custodian and the
advisory fees charged by our firm in comparison to other registered investment advisers.
Changes in Your Financial Circumstances
In providing the contracted services, we are not required to verify any information we receive from you
or from your other professionals (e.g., attorney, accountant, etc.) and we are expressly authorized to
rely on the information you provide. Furthermore, unless you indicate to the contrary, we shall assume
that there are no restrictions on our services, other than to manage your account in accordance with
your designated investment objectives, risk tolerance, and time horizon (collectively, "investment
parameters"). It is your responsibility to promptly notify us if there are ever any changes in your
financial situation or investment parameters for the purpose of reviewing, evaluating, and/or revising
our previous recommendations and services.
The Program Fee
We charge an annual "wrap-fee" for participation in the Program where you will pay our firm a single
fee, which includes money management fees and transaction costs. As of the date of this Brochure our
firm absorbs any custodial and/or administrative fees imposed by the acting broker-
dealers/custodians. However, it is possible that the acting broker-dealer/custodian imposes newly
added custodial/administrative fees after the inception of our advisory engagement. In such event, our
firm will review the newly imposed custodial/administrative fee and adopt a policy, which will be
disclosed to all clients, as to whether such fee(s) will be absorbed by our firm as part of the Wrap Fee
Program. In special circumstances, and in our sole discretion, we may negotiate a lesser management
fee based upon certain criteria (i.e., anticipated future earning capacity, dollar amount of assets to be
managed, related accounts, account composition, pre-existing client relationship, account retention,
etc.).
Our fee for portfolio management services is based on a percentage of your assets we manage. The
fee arrangement is set forth in the following blended tiered-fee schedule*:
Assets Under Management Maximum Annual Fee
$0 - $100,000 1.75%
$100,001 - $500,000 1.50%
$500,001 - $1,000,000 1.35%
$1,000,001 - $2,500,000 1.25%
$2,500,001 - $5,000,000 1.00%
$5,000,001 - $10,000,000 0.90%
$10,000,001 and Above 0.80%
*For example, the applicable management fee for a client with $1,500,000 would be as follows: the first
$100,000 would be billed at an annual rate of 1.75%; the next $400,000 would be billed at an annual
rate of 1.50%; the next $500,000 would be billed at 1.35%; and the remaining $500,000 would be billed
at an annual rate of 1.25%.
The annual fee is billed in quarterly installments in advance based on the account balance at end of
billing period. If the Investment Advisory Agreement is executed at any time other than the first day of a
calendar quarter, our fees will apply on a pro rata basis, which means that the advisory fee is payable
in proportion to the number of days in the quarter for which you are a client. In our sole discretion, we
may negotiate other fee arrangements.
As a client, you should be aware that the wrap fee charged by our firm may be higher (or lower) than
those charged by others in the industry, and that it may be possible to obtain the same or similar
services from other firms at lower (or higher) rates. A client may be able to obtain some or all of the
types of services available through our firm's wrap fee program on an individual basis through other
firms and, depending on the circumstances, the aggregate of any separately paid fees may be lower or
higher than the annual fees shown above.
At our discretion, we may combine the account values of family members living in the same household
to determine the applicable advisory fee. For example, we may combine account values for you and
your minor children, joint accounts with your spouse, and other types of related accounts. Combining
account values may increase the asset total, which may result in your paying a reduced advisory fee
based on the available breakpoints in our fee schedule stated above.
Deposit / Withdrawal of Assets
If cash or securities, or a combination thereof, amounting to at least $100,000 are deposited to or
withdrawn from an existing account held at your acting qualified custodian on an individual business
day in the first two months of the calendar quarter, we will: (i) assess Management Fees to the
deposited assets based on the value of the assets on the date of deposit for the pro rata number of
days remaining in the calendar quarter; or, (ii) refund prepaid Management Fees based on the value of
the assets on the date of withdrawal for the pro rata number of days remaining in the calendar quarter.
No additional fees or adjustments to previously assessed Management Fees will be made in
connection with deposits or withdrawals that occur during the last month of the calendar quarter unless
requested by you. Notwithstanding the above, we reserve the right, in our sole discretion, to process or
not process fee adjustments, as applicable, when the source and destination of deposits and
withdrawals involve your other fee-based Portfolio(s).
You may withdraw account assets on notice to our firm, and subject to the usual and customary
securities settlement procedures. However, we design our portfolios as long-term investments and
asset withdrawals may impair the achievement of your specific investment objectives.
Payment of Fees
We will deduct our fee directly from your account through the qualified custodian holding your funds
and securities. We will deduct our advisory fee only when the following requirements are met:
• You provide our firm with written authorization permitting the fees to be paid directly from your
account held by the qualified custodian.
• The qualified custodian agrees to send you a statement, at least quarterly, indicating all
amounts dispersed from your account including the amount of the advisory fee paid directly to
our firm.
We encourage you to review the statement(s) you receive from the qualified custodian. If you find any
inconsistent information in the statement(s) you receive from the qualified custodian, please call our
main office number located on the cover page of this Brochure.
Termination of Advisory Relationship
You may terminate the Investment Advisory Agreement upon 7 days written notice to our firm. You will
incur a pro rata charge for services rendered prior to the termination of the Investment Advisory
Agreement, which means you will incur advisory fees only in proportion to the number of days in the
quarter for which you are a client. If you have pre-paid advisory fees that we have not yet earned, you
will receive a prorated refund of those fees.
Upon termination of accounts held at the Custodians, they will deliver securities and funds held in the
account per your instructions unless you request that the account be liquidated. After the Investment
Advisory Agreement has been terminated, transactions are processed at the prevailing brokerage
rates/fees. You become responsible for monitoring your own assets and our firm has no further
obligation to act upon or to provide advice with respect to those assets.
Wrap Fee Program Disclosures
• The benefits under a wrap fee program depend, in part, upon the size of the Account, the
management fee charged, and the number of transactions likely to be generated in the
Account. For example, a wrap fee program may not be suitable for Accounts with little trading
activity. In order to evaluate whether a wrap fee program is suitable for you, you should
compare the Program Fee and any other costs of the Program with the amounts that would be
charged by other advisers, broker-dealers, and custodians, for advisory fees, brokerage and
other execution costs, and custodial services comparable to those provided under the Program.
• In considering the investment programs described in this Brochure, you should be aware that
participating in a wrap fee program may cost more or less than the cost of purchasing advisory,
brokerage, and custodial services separately from other advisers or broker-dealers.
• Our firm and Associated Persons receive compensation as a result of your participation in the
Program. This compensation may be more than the amount our firm or the Associated Persons
would receive if you paid separately for investment advice, brokerage, and other services.
Accordingly, a conflict of interest exists because our firm and our Associated Persons have a
financial incentive to recommend the Program.
• Similar advisory services may be available from other registered investment advisers for lower
fees.
Additional Fees And Expenses
The Program
Fee includes the costs of brokerage commissions for transactions executed through the
Qualified Custodian, costs associated with exchanging currencies, wire transfer fees, or other fees
required by law or imposed by third parties. The Account will be responsible for these additional fees
and expenses.
The Program Fee does not include mark-ups and mark-downs, dealer spreads or other costs
associated with the purchase or sale of securities, interest, taxes, or other costs, such as national
securities exchange fees, charges for transactions not executed through the Qualified Custodian.
The wrap program fees that you pay to our firm for portfolio management services are separate and
distinct from the fees and expenses charged by mutual funds or exchange traded funds (described in
each fund's prospectus) to their shareholders. These fees will generally include a management fee and
other fund expenses. To fully understand the total cost you will incur, you should review all the fees
charged by mutual funds, exchange traded funds, our firm, and others.
While the following items and their associated fees may not be applicable to your individual
circumstances, the following list includes fees that are separate and apart from the Program fee we
charge for the wrap program:
• Costs associated with exchanging currencies;
• Regulatory Transaction Fees ("RT Fee") or other fees required by law;
• Fees charged by Mutual Funds/Exchange Traded Funds (ETFs);
• Custodial Fees;
• Separately Managed Accounts (SMAs);
• Deferred sales charges (on Mutual funds or annuities);
• Foreign Exchange transactions;
• Check reorders and overnight check requests;
• Wire transfer and electronic fund processing fees.
• To the extent we are providing management services to held-away assets (such as a 401(k)
account), 529 plans, or annuities (fee paying arrangements with certain annuities may differ
from our Program fee payment arrangement), there could be annual account fees, short-term
redemption fees, or other fees imposed by unaffiliated third parties where we do not have the
ability to directly absorb the fee. Your account will be responsible for these fees as they are not
covered by our Program fee.
If you have any questions about fees that your account might be responsible for that are in addition to
our Program fee, please contact us at 843-485-4371.
We may trade client accounts on margin. Each client must sign a separate margin agreement before
margin is extended to that client account. Fees for advice and execution on these securities are based
on the total asset value of the account, which includes the value of the securities purchased on margin.
While a negative amount may show on a client's statement for the margined security as the result of a
lower net market value, the amount of the fee is based on the absolute market value. This creates a
conflict of interest where we have an incentive to encourage the use of margin to create a higher
market value and therefore receive a higher fee. The use of margin may also result in interest charges
in addition to all other fees and expenses associated with the security involved.
Brokerage Practices
If you participate in the Program, you will be required to establish an account with Charles Schwab &
Co, Inc. ("Schwab") and/or Raymond James & Associates (RJA) and/or registered broker-dealers,
members SIPC, as the qualified custodians. If you do not direct our firm to execute transactions
through Schwab or RJA, we reserve the right to not accept your account. Not all advisers require their
clients to direct brokerage. Since you are required to use Schwab or RJA, we may be unable to
achieve the most favorable execution of your transactions. We believe that Schwab and RJA provide
quality execution services based on several factors, including, but not limited to, the ability to provide
professional services, reputation, experience and financial stability.
Evaluation of custodial relationships is based on many factors, including the level of services provided,
the custodian’s financial stability, and the cost of services provided by the custodian to our clients,
which includes the yield on cash sweep choices, commissions, custody fees and other fees or
expenses.
Research and Other Soft Dollar Benefits
We do not have any soft dollar arrangements.
Economic Benefits
As a registered investment adviser, we have access to the institutional platform of your account
custodian. As such, we will also have access to research products and services from your account
custodian and/or other brokerage firms. These products may include financial publications, information
about particular companies and industries, research software, and other products or services that
provide lawful and appropriate assistance to our firm in the performance of our investment decision-
making responsibilities. Such research products and services are provided to all investment advisers
that utilize the institutional services platforms of these firms, and are not considered to be paid for with
soft dollars. However, you should be aware that the commissions charged by a particular broker for a
particular transaction or set of transactions may be greater than the amounts another broker who did
not provide research services or products might charge.
The custodian and brokers we use
We do not maintain custody of your assets that we manage, although we may be deemed to have
custody of your assets if you give us authority to withdraw assets from your account. Your assets must
be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. We require
that our clients use Schwab or RJA, registered broker-dealers, members SIPC, as the qualified
custodians.
We are independently owned and operated and are not affiliated with Schwab or RJA. Schwab or RJA
will hold your assets in a brokerage account and buy and sell securities when we instruct them to.
While we require that you use Schwab or RJA as custodian/broker, you will decide whether to do so
and will open your account with Schwab or RJA by entering into an account agreement directly with
them. Conflicts of interest associated with this arrangement are described below as well as in the ADV
Part 2A Item 14 (Client referrals and other compensation). You should consider these conflicts of
interest when selecting your custodian.
How we select brokers/custodians
We seek to use Schwab or RJA, a custodian/broker that will hold your assets and execute
transactions. When considering whether the terms that Schwab or RJA provides are, overall, most
advantageous to you when compared with other available providers and their services, we take into
account a wide range of factors, including:
• Combination of transaction execution services and asset custody services (generally without a
separate fee for custody)
• Capability to execute, clear, and settle trades (buy and sell securities for your account)
• Capability to facilitate transfers and payments to and from accounts (wire transfers, check
requests, bill payment, etc.)
• Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds
[ETFs], etc.)
• Availability of investment research and tools that assist us in making investment decisions
• Quality of services
• Competitiveness of the price of those services (commission rates, margin interest rates, other
fees, etc.) and willingness to negotiate the prices
• Reputation, financial strength, security, and stability
• Prior service to us and our clients
• Services delivered or paid for by RJA or Schwab
• Availability of other products and services that benefit us
Your brokerage and custody costs
For our clients’ accounts that Schwab or RJA maintain, Schwab or RJA generally does not charge you
separately for custody services. Certain trades (for example, many mutual funds and ETFs) may not
incur commissions or transaction fees. Schwab and RJA is also compensated by earning interest on
the uninvested cash in your account in the cash sweep programs.
We are not required to select the broker or dealer that charges the lowest transaction cost, even if that
broker provides execution quality comparable to other brokers or dealers.
Although we are not required to execute all trades through Schwab, we have determined that having
Schwab execute most trades is consistent with our duty to seek “best execution” of your trades. Best
execution means the most favorable terms for a transaction based on all relevant factors, including
those listed above (see “How we select brokers/custodians”). By using another broker or dealer you
may pay lower transaction costs.
Products and services available to us
Schwab Advisor Services ™ is Schwab’s business serving independent investment advisory firms like
us. They provide us and our clients with access to their institutional brokerage services (trading,
custody, reporting and related services), many of which are not typically available to Schwab retail
customers. However, certain retail investors may be able to get institutional brokerage services from
Schwab without going through us.
Schwab also makes available various support services. Some of those services help us manage or
administer our clients’ accounts while others help us manage and grow our business. Schwab’s
support services are generally available on an unsolicited basis (we don’t have to request them) and at
no charge to us. Following is a more detailed description of Schwab’s support services:
Services that benefit you
Schwab’s institutional brokerage services include access to a broad range of investment products,
execution of securities transactions, and custody of client assets. The investment products available
through Schwab include some to which we might not otherwise have access or that would require a
significantly higher minimum initial investment by our clients. Schwab’s services described in this
paragraph generally benefit you and your account.
Services that do not directly benefit you
Schwab also makes available to us other products and services that benefit us but do not directly
benefit you or your account. These products and services assist us in managing and administering our
clients’ accounts and operating our firm. They include investment research, both Schwab’s own and
that of third parties. We use this research to service all or a substantial number of our clients’ accounts,
including accounts not maintained at Schwab. In addition to investment research, Schwab also makes
available software and other technology that:
• Provide access to client account data (such as duplicate trade confirmations and account
statements;
• Facilitate trade execution and allocate aggregated trade orders for multiple client accounts;
• Provide pricing and other market data;
• Facilitate payment of our fees from our clients’ accounts; and
• Assist with back-office functions, recordkeeping, and client reporting.
Services that generally benefit only us
Schwab also offers other services intended to help us manage and further develop our business
enterprise. These services include:
• Educational conferences and events
• Consulting on technology and business needs
• Consulting on legal and related compliance needs
• Publications and conferences on practice management and business succession
• Access to employee benefits providers, human capital consultants, and insurance providers
• Marketing consulting and support
Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to
provide the services to us. Schwab also discounts or waives its fees for some of these services or pays
all or a part of a third party’s fees. Schwab also provides us with other benefits, such as occasional
business entertainment of our personnel. If you did not maintain your account with Schwab, we would
be required to pay for these services from our own resources.
Our Interest in Schwab’s Services
The availability of these services from Schwab benefits us because we do not have to produce or
purchase them. We don’t have to pay for Schwab’s services. The fact that we receive these benefits
from Schwab is an incentive for us to require the use of Schwab rather than making such a decision
based exclusively on your interest in receiving the best value in custody services and the most
favorable execution of your transactions. This is a conflict of interest. We believe, however, that taken
in the aggregate, our recommendation of Schwab as custodian and broker is in the best interests of
our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services
(see “How we select brokers/ custodians”) and not Schwab’s services that benefit only us.
Brokerage for Client Referrals
We do not receive client referrals from broker-dealers in exchange for cash or other compensation,
such as brokerage services or research.
Mutual Fund Share Classes
Mutual funds are sold with different share classes, which carry different cost structures. Each available
share class is described in the mutual fund's prospectus. When we purchase, or recommend the
purchase of, mutual funds for a client, we select the share class that is deemed to be in the client’s
best interest, taking into consideration the availability of advisory, institutional or retirement plan share
classes, initial and ongoing share class costs, transaction costs (if any), tax implications, cost basis
and other factors. We also review the mutual funds held in accounts that come under our management
to determine whether a more beneficial share class is available, considering cost, tax implications, and
the impact of contingent or deferred sales charges.
Assets Under Management
As of February 29, 2024, we provide continuous management services for $105,397,018 in client
assets on a discretionary basis. We do not have any client assets on a non-discretionary basis.