A. Firm Information
Sieben Wealth Planning LLC (“Sieben Wealth Planning” or the “Advisor”) is a registered investment advisor with
the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company
(“LLC”) under the laws of the State of Minnesota. Sieben Wealth Planning was founded in August 2021 and
became a registered investment advisor in September 2021. Sieben Wealth Planning is owned and operated by
David M. Sieben (Principal and Chief Compliance Officer). This Disclosure Brochure provides information
regarding the qualifications, business practices, and the advisory services provided by Sieben Wealth Planning.
B. Advisory Services Offered
Sieben Wealth Planning offers advisory services to individuals, high net worth individuals, families, trusts,
estates, businesses, and retirement plans (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness, and good faith towards each Client and seeks to mitigate conflicts
of interest. Sieben Wealth Planning ’s fiduciary commitment is further described in the Advisor’s Code of Ethics.
For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest
in Client Transactions and Personal Trading.
Wealth Management Services
Sieben Wealth Planning provides customized wealth management solutions for its Clients. This is achieved
through continuous personal Client contact and interaction while providing discretionary wealth management and
related advisory services. Sieben Wealth Planning works closely with each Client to identify their investment
goals and objectives as well as risk tolerance and financial situation in order to design a portfolio strategy. Sieben
Wealth Planning will then construct an investment portfolio, consisting of exchange-traded funds (“ETFs”) and/or
mutual funds to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, individual
bonds, and other types of investments, as appropriate, to meet the needs of the Client. The Advisor may retain
certain legacy investments based on portfolio fit and/or tax considerations.
Sieben Wealth Planning will select, recommend and/or retain mutual funds on a fund-by-fund basis. Due to
specific custodial and/or mutual fund company constraints, material tax consideration, and/or systematic
investment plans, Sieben Wealth Planning will select, recommend and/or retain a mutual fund share classes that
do not have trading costs when possible. These will in most cases be institutional share classes but, in some
cases, may be share classes with higher internal expense ratios than institutional share classes. Sieben Wealth
Planning will seek to select the lowest cost share class available that is in the best interest of each Client
weighing the expected investment pattern, expense ratios and potential ticket charges, and will ensure the
selection aligns with the Client’s financial objectives and stated investment guidelines.
Sieben Wealth Planning ’s investment approach is primarily long-term focused, but the Advisor may buy, sell or
re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to
market conditions. Sieben Wealth Planning will construct, implement, and monitor the portfolio to ensure it
meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the
opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio,
subject to acceptance by the Advisor.
Sieben Wealth Planning evaluates and selects investments for inclusion in Client portfolios only after applying its
internal due diligence process. Sieben Wealth Planning may recommend, on occasion, redistributing investment
allocations to diversify the portfolio. Sieben Wealth Planning may recommend specific positions to increase
sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge
against the market movement. Sieben Wealth Planning may recommend selling positions for reasons that
include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific
security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk
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tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s
risk tolerance.
Use of Independent Managers – Sieben Wealth Planning may recommend that Clients utilize one or more
unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a
portion of a Client’s investment portfolio, based on the Client’s needs and objectives. In certain instances, the
Client may be required to authorize and enter into a wealth management agreement with the Independent
Manager[s] that defines the terms in which the Independent Manager[s] will provide its services. The Advisor will
perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy
remains aligned with Client’s investment objectives and overall best interests. The Advisor will also assist the
Client in the development of the initial policy recommendations and managing the ongoing Client relationship.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement
accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over
the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based
account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a
new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll
over a retirement account to an account managed by the Advisor.
Financial Planning Services
Sieben Wealth Planning will typically provide a variety of financial planning and consulting services to Clients.
Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives.
Generally, such financial planning services involve preparing a formal financial plan or rendering a specific
financial consultation based on the Client’s financial goals and objectives. This planning or consulting may
encompass one or more areas of need, including but not limited to, investment planning, retirement planning,
personal savings, education savings, insurance needs, and other areas of a Client’s financial situation.
A financial plan developed for or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs. Sieben Wealth Planning may
also refer Clients to an accountant, attorney, or other specialists, as appropriate for their unique situation. For
certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial
situation, observations, and recommendations. For project-based or ad-hoc engagements, the Advisor may not
provide a written summary. Project-based financial plans or consultations are typically completed within six (6)
months of contract date, assuming all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor
for wealth management services or to increase the level of investment assets with the Advisor, as it would
increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any
recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects
to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the
transaction through the Advisor.
Retirement Plan Advisory Services
Sieben Wealth Planning provides non-discretionary retirement plan advisory services on behalf of the retirement
plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are
designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants.
Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include:
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• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and Monitoring
• Investment monitoring and oversight
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
These services are provided by Sieben Wealth Planning serving in the capacity as a fiduciary under the
Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section
408(b)(2), the Plan Sponsor is provided with a written description of Sieben Wealth Planning ’s fiduciary status,
the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects
under the engagement.
C. Client Account Management
Prior to engaging Sieben Wealth Planning to provide advisory services, each Client is required to enter into a
written advisory agreement with the Advisor that define the terms, conditions, authority, and responsibilities of the
Advisor and the Client. These services may include:
• Establishing an Investment Strategy – Sieben Wealth Planning, in connection with the Client, will develop
a strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Sieben Wealth Planning will develop a strategic asset allocation that is targeted to
meet the investment objectives, time horizon, financial situation, and tolerance for risk for each Client or
unique client goal.
• Portfolio Construction – Sieben Wealth Planning will develop a portfolio for the Client that is intended to
meet the stated goals and objectives of the Client.
• Wealth Management and Supervision – Sieben Wealth Planning will provide wealth management and
ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Sieben Wealth Planning does not manage or place Client assets into a wrap fee program. Investment
management services are provided directly by Sieben Wealth Planning.
E. Assets Under Management
As of December 31, 2023, Sieben Wealth Planning manages $ 124,727,185 in total Client assets, of which
$121,047,007 are a managed on a discretionary basis and $3,680,178 are managed on a non-discretionary basis.
Clients may request more current information at any time by contacting the Advisor.