This brochure describes the investment services all-inclusive wrap fee program (“Program”) offered by
JDM Financial Group, LLC (“JDM”) and information about JDM. Clients who wish to retain such
services will enter into an investment advisory agreement with JDM (“Client Agreement”) under which
JDM provides discretionary investment advisory services. If the client enters into a Client Agreement,
JDM will, and is authorized by the client to, manage and rebalance client assets without prior consultation
with the client. As of December 31, 2023, we manage total assets of $245.2 million on a discretionary
basis. JDM does not manage assets on a non-discretionary basis.
The Client Agreement sets forth services that the client will receive and any fee that the client will pay.
Under the Client Agreement, all of client’s assets will be managed by JDM directly.
JDM will have full discretionary authority with respect to the investment and reinvestment of client assets
in accordance with, and subject to, the information provided in the Investment Guidelines.
JDM constructs client portfolios by first determining the appropriate asset allocation across major assets
classes, such as but not limited to stocks, real estate, bonds and cash, based on conversations with clients
and information collected from them. JDM determines the appropriate the appropriate asset allocation by
considering factors such as the client’s current and anticipated cash flow needs, psychological and
financial risk tolerance, time horizon for accomplishing stated goals and the relative attractiveness of the
markets for various types of assets. Once selecting an appropriate asset allocation, JDM selects or
recommends mutual funds or exchange traded funds to represent various asset sub categories within each
asset class (For example, an international stock fund to represent the international exposure within the
stock market portion of the portfolio) . JDM generally selects mutual funds or exchange traded funds that
create, either alone or collectively, an acceptable level of diversification within a given asset class given
the size of a client portfolio. This diversification generally includes exposure to specific economic
sectors, regions or countries and JDM may also consider the tax or tax deferred nature of an account when
making investment selections.
JDM will typically invest client assets in various open-end funds, including mutual funds or exchange-
traded funds (“Funds”).
JDM has contracted with First Ascent Asset Management, LLC ("First Ascent"), a SEC-registered
investment advisor to provide subadvisory services. First Ascent primarily invests using ETFs and
mutual funds.First Ascent implements the recommendations made by JDM, and JDM retains full
discretion about which assets are placed at First Ascent. First Ascent Asset Management, when used as a
sub-advisor by JDM for select clients, will not have the discretionary authority to select investments or
determine the asset allocation for portfolios. These remain the sole discretion of JDM. First Ascent's
authority is restricted to executing trades at JDM's request.
For the asset management services described in the Client Agreement, each client will be charged an
asset-based fee each calendar quarter. The fee that may be charged to a client depends on the amount of
client assets under management, and is determined according to the following schedule:
Assets Under ManagementMaximum Annual Fee
$0 - $499,9991.50%
$500,000 - $999,9991.25%
$1,000,000 - $9,999,9991.00%
$10,000,000 and above0.90%
Notwithstanding the above, the asset-based fee to be paid each quarter shall be no less than $1,000 for
clients with an inception date after January 1, 2016. These fees are negotiable at JDM's sole discretion
based on the scope and complexity of services to be rendered and account size. The rate used each
quarter will be approximately one-fourth of the annual rate based on the number of days in the quarter.
The asset-based fee will be payable quarterly in advance. The initial fee (“Initial Fee”) will be calculated
as of the date the applicable Client Agreement is accepted by JDM (“Commencement Date”). The Initial
Fee will cover the period from the Commencement Date until the last day of the initial calendar quarter.
The Initial Fee will be calculated proportionately with respect to the number of days in the initial
quarterly billing period, and will be based on the market value of the client’s assets on the last business
day of the quarter for which the fee is due and will be due at the end of such quarter. Thereafter, the
quarterly fee will be calculated based on the market value of the client’s assets as of the close of business
on the last day of the preceding calendar quarter and will be due on the first business day of the quarter
for which the fee is due. First Ascent receives an asset-based fee for its services, which is paid by JDM.
Charles Schwab & Co., Inc. ("Schwab") currently maintains custody of client assets and will receive and
credit to the account(s) all interest, dividends, and other distributions that it receives on the assets in the
account(s). The quarterly fees will be deducted from the client’s account at Schwab as they become due
and payable.
Fees will generally include an asset-based fee as compensation for the discretionary investment
management services provided by JDM, fees associated with JDM’s use of any Platform, and fees for
custodial services performed by, and transaction charges for transactions executed at, Schwab or another
custodian or registered broker, respectively, with which JDM may establish contractual arrangements.
JDM has the authority to negotiate fee arrangements. As a result, one client may pay a higher fee to JDM
than a second client for whom JDM is providing substantially similar services. The actual fee rate(s) paid
by the client will be set forth in the Client Agreement. Fees paid by the client to JDM may be higher or
lower than the cost of similar services offered through other financial firms. The fees charged to the
client will not be affected by the number of transactions executed on behalf of a client.
Generally, clients may add assets to, or withdraw assets from, their account at any time. Clients seeking
to withdraw assets from their account must provide at least seven (7) days’ written notice to JDM prior to
such withdrawal. Generally,
fees will not be adjusted for intra-quarter withdrawals or additions.
Generally, the client or JDM may terminate the Client Agreement upon providing thirty (30) days’ prior
written notice to the other party.
If a Client Agreement is terminated by either party within five (5) business days after the Client
Agreement is executed by both parties and dated executed copies are received by both parties, the client
will receive a full refund of any fee paid. If a Client Agreement is terminated by either party more than
five (5) business days after the Client Agreement is executed by both parties and dated executed copies
are received by both parties, the client will receive a pro-rata refund of any fees paid, based on the
number of days remaining in the calendar quarter after the date upon which notice of termination is
received by JDM or the client, as applicable.
Fees paid by the client under the Program may be higher or lower than the fees that JDM and Schwab
would charge a client if the client had purchased the services separately and not as part of the Program.
This will depend on various factors, including the level of the fees charged, the amount of portfolio
activity in the client’s account and the value of services provided under the program.Schwab has
eliminated commissions for online trades of U.S. equities, ETFs and options (subject to a per contract
fee). We encourage you to review Schwab’s pricing to compare the total costs of entering into a wrap fee
arrangement versus a non-wrap arrangement. To see what you would pay for transactions in a non-wrap
account please refer to Schwab’s most recent pricing schedules available on their website.
Fees charged to the client may not include fees for custodial services that are performed by custodians
other than Schwab, or any brokerage commissions or charges on transactions ordered by client, or
brokerage commissions or other charges resulting from transactions executed by a broker other than
Schwab or another registered broker with which JDM may establish contractual arrangements. Generally,
any costs charged by such other custodian or broker will be borne by the client.
Fees charged by JDM to the client do not include the amount of any costs, expenses or commissions
incurred by a client with respect to transactions placed by the client at Schwab independently of JDM.
Fees also do not include the fees and expenses a client may incur as a shareholder of a Fund, or certain
costs or charges that may be imposed by Schwab or third parties, including margin interest, costs
associated with exchanging foreign currencies, odd lot differentials, Securities and Exchange Commission
fees, transfer taxes, exchange fees, wire transfer fees, postage fees, auction fees, foreign clearing,
settlement and custodial fees, and other fees or taxes required by law. In addition, the fees charged by
JDM to the client do not cover “mark-ups” and “mark-downs” that other broker-dealers may receive or
“dealer spreads” that Schwab or other broker-dealers may receive when acting as principal in certain
transactions, or the amount of any annual fee that Schwab may charge on an Individual Retirement
Account (IRA) or certain other retirement plans.
The amount of compensation JDM receives from a client in the Program may be more than what JDM
would have received if the client engaged JDM without participating in the Program, thereby paying
separate expenses relating to investment advice, brokerage and custodial services. As a result, JDM may
have a financial incentive to recommend that a client participate in the Program instead of engaging JDM
independently of the Program. Because JDM pays trading costs for client trades, there is an incentive to
reduce costs by minimizing the number of trades made.
JDM does not aggregate orders for client accounts. The majority of investments are open-end mutual
funds which price daily and exchange traded funds.
JDM is authorized and directed to effect transactions for client account(s) directly through Schwab and
transactions ordinarily will be effected through Schwab. All transactions are subject to any Schwab
internal policies or procedures. In no event is Schwab obligated to effect any transaction that Schwab
believes would violate applicable federal or state law, or the regulations of any regulatory or self-
regulatory body or would otherwise present an unacceptable risk to Schwab.
When a transaction is executed through a broker or dealer other than Schwab, clients may incur a
transaction fee, commission, or other charges. Such fees, commissions or other charges will be in
addition to the fees charged to the client by JDM. Such broker or dealer shall be solely responsible for
the execution and clearance of these transactions.
Clients may authorize Schwab (or another registered broker with which JDM may establish contractual
arrangements) to the extent permitted by applicable law, to invest cash balances in one or more money
market funds, which may or may not be affiliated with Schwab or such other broker. Clients are to
receive from the broker that executed the relevant transaction a current prospectus for each money market
fund in which the client assets are invested. Clients should refer to each prospectus for information about
the money market fund and any applicable fees associated with investment in such fund. Assets held in
such funds are subject to various fees and expenses, which are paid by such funds but ultimately borne by
clients.
When calculating the net value of assets in a client account under the Program, JDM generally uses
information provided by Schwab, which in turn uses recognized independent quotation and valuation
services. Currently, JDM reasonably believes this information to be reliable. As such, JDM does not,
and has no duty to, verify the accuracy of the information provided by these services. If any information
provided by these services is unavailable or is believed to be unreliable, JDM will value assets in a
manner JDM determines in good faith to reflect fair market value. JDM may use different valuation
sources for different purposes. As a result, the determination of account asset values may differ for
various reasons.