A. Description of the Advisory Firm
B. Types of Advisory Services
Selection of Other Advisers
GSWML may direct clients to third-party investment advisers. Before selecting other
advisers for clients, GSWML will verify that all recommended advisers are properly
licensed, notice filed, or exempt in the states where GSWML is recommending the adviser
to clients.
On-going Financial Planning
On-going financial planning services may include:
1. Initial Consultation (Free)
a. Assess current financial situation and discuss the financial planning process
and my services.
2. Detailed meeting to go through Clients financial situation in depth and better
understanding of client’s financial goals and concerns.
3. Client Recommendation Meeting
a. Delivery of a financial plan including current net worth (Balance Sheet),
goals, action items and more.
b. Recommendations.
c. Client walkthrough of plan and any questions.
Included in the ongoing plan:
1. Biannual check ins with clients to assess financial plan, implementation of the plan,
limitations, adjustments needed, and assess new variables in a client’s financial picture.
2. End of Year meeting to discuss financial plan
3. A new/updated financial plan annually
In offering financial planning, a conflict exists between the interests of the investment
adviser and the interests of the client. The client is under no obligation to act upon the
investment adviser's recommendation, and, if the client elects to act on any of the
recommendations, the client is under no obligation to effect the transaction through the
investment adviser. This statement is required by California Code of Regulations, 10 CCR
Section 260.235.2.
Advisor Credit Exchange (ACX)
Credit solutions for GSWML clients offered through the Adviser Credit Exchange.
Services to include: collateralized and unsecured personal loans. GSWML receives a
commission for each loan that they refer to ACX, ranging from 0 - .25% of the loan amount.
Therefore, GSWML has a financial incentive to recommend ACX to their clients. Clients
are not required to use ACX and may select any lender of their choosing.
Credit solutions offered through Advisor Credit Exchange (“ACX” a third party owned
by Envestnet). The Advisor Credit Exchange solution do charge an interest rate based
amount borrowed and terms of loan.
GreenUp Protection Solutions LLC
Upon review of an investor's financial status, GSWML may propose that the investor
include, as part of his or her financial portfolio, one or more types of products that are not
part of the investment advisory services provided by GSWML, such as insurance
products. If the investor chooses to include such a product in his or her financial portfolio,
GSWML recommends that the investor work closely with his or her attorney, accountant,
insurance agent and other related professionals. Incorporation of the non-advisory
financial product into the investor's financial plan is entirely at the client's discretion.
For insurance products, GSWML provides access to a platform of insurance products by
GreenUp Protection Solutions, LLC. (“GPS”), a licensed insurance agency and affiliate of
GreenUp. The investor is under no obligation to use GPS’s service and may seek insurance
advice from any licensed agent. The insurance products and fee structures available
from
GPS may differ from those available from other third- party insurance agents. GSWML
recommends that the investor fully evaluate products and fee structures to determine
which arrangements are most favorable to the investor prior to making an investment
decision. GPS is entitled to receive commissions and other renumeration on the sale of
insurance products. As such, GPS affects insurance transactions and receive separate, yet
customary compensation.
Pontera
GSWML provides an additional service for accounts not directly held in our custody, but
where we do have discretion, and may leverage an Order Management System to
implement tax-efficient asset location and opportunistic rebalancing strategies on behalf
of the client. These are primarily 401(k) accounts, HSAs, and other assets GSWML does
not custody. GSWML regularly reviews the available investment options in these
accounts, monitor them, and rebalance and implement our strategies in the same way we
do other accounts, though using different tools as necessary
Services Limited to Specific Types of Investments
GSWML generally limits its investment advice to mutual funds, fixed income securities,
real estate funds (including REITs), equities, ETFs (including ETFs in the gold and
precious metal sectors), treasury inflation protected/inflation linked bonds, commodities,
non-U.S. securities, venture capital funds and private placements. GSWML may use other
securities as well to help diversify a portfolio when applicable.
GSWML offers the same suite of services to all of its clients. However, specific client
investment strategies and their implementation are dependent upon the client Investment
Policy Statement which outlines each client’s current situation (income, tax levels, and risk
tolerance levels). Clients may impose restrictions in investing in certain securities or types
of securities in accordance with their values or beliefs. However, if the restrictions prevent
C. Client Tailored Services and Client Imposed Restrictions
GSWML from properly servicing the client account, or if the restrictions would require
GSWML to deviate from its standard suite of services, GSWML reserves the right to end
the relationship.
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees, transaction costs, fund expenses, and other administrative
fees. GSWML does not participate in any wrap fee programs.
GSWML has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$508,512,466
$2,316,568
February 2024
Portfolio Management Fees
Total Assets Under Management Annual Fees
$0 - $500,000 1.25%
$500,001 - $2,000,000 1.00%
$2,000,001 - $5,000,000 0.85%
$5,000,001 - $10,000,000 0.70%
$10,000,001 – and Up 0.45%
The advisory fee is calculated using the value of the assets in the Account on the last
business day of the prior billing period. Lower fees for comparable services may be
available from other sources.
Selection of Other Advisers Fees
For clients utilizing the direct indexing solution from Veriti through First Trust the
additional fees range from 25 – 40bps depending on total assets of the advisor.
D. Wrap Fee Programs
E. Assets Under Management