Our Advisory Business
West Wealth Group, LLC, d/b/a BML Wealth Management, and Ensemble Wealth Management
(together "West Wealth Group", "WWG", "us", "we", "our") is a registered investment adviser with the
Securities and Exchange Commission ("SEC"). The Adviser was founded in 2021 by Brian Levy and
Michael Clark, CFP(r) and is owned by the Brian and Ruth Levy Living Trust and the Michael R. Clark
Trust.
Services
West Wealth Group offers asset management and financial planning and consulting services, with an
emphasis on building portfolios designed to meet the needs of our clients. Our focus is on helping you
develop and execute plans that are designed to build and preserve your wealth. We are available
during normal business hours either by telephone, email, or in person by appointment to answer your
questions. Services are offered on either discretionary or non-discretionary basis. 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 amount 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. If you enter
into non-discretionary arrangements with our firm, we must obtain your approval prior to executing any
transactions on behalf of your account. You have an unrestricted right to decline to implement any
advice provided by our firm on a non-discretionary basis.
Asset Management Services
As part of the active asset management process, we will meet with you to discuss your financial
circumstances, investment goals and objectives, and to determine your risk tolerance. We will ask you
to provide statements summarizing current investments, income and other earnings, recent tax returns,
retirement plan information, other assets and liabilities, wills and trusts, insurance policies, and other
pertinent information.
As part of our asset management services, in addition to other types of investments (see disclosures
below in this section), we may invest your assets according to one or more model portfolios we have
developed using funds offered by an unaffiliated investment manager. These models are designed for
investors with varying degrees of risk tolerance ranging from a more aggressive investment strategy to
a more conservative investment approach. Clients whose assets are invested in model portfolios may
not set restrictions on the specific holdings or allocations within the model, nor the types of securities
that can be purchased in the model. Nonetheless, clients may impose restrictions on investing in
certain securities or types of securities in their account. In such cases, this may prevent a client from
investing in certain models that are managed by our firm.
These services allow us to provide our clients with operational and advisory efficiencies which may
create a conflict of interest since the models use mutual funds and exchange traded funds
("ETF") funds affiliated with the unaffiliated investment manager. It is possible that there are other
mutual funds and ETF funds not included in these models that may be in our clients' best interest. In all
cases we strive to recommend only products and services that we believe are in your best interest.
Accounts invested in these investment models that include mutual funds may be subject to short-term
redemption fees imposed by custodians and/or the mutual fund sponsor. West Wealth Group is not
responsible for these short-term redemption fees. They are the responsibility of the client.
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We will work with you on an ongoing basis to evaluate your asset allocation as well as rebalance your
portfolio to keep it in line with your goals as necessary. We will be reasonably available to help you
with questions about your account.
Please note that pursuant to the investment advisory agreement you are obligated to notify us
promptly when your financial situation, goals, objectives, or needs change.
You shall have the ability to impose reasonable restrictions on the management of your account,
including the ability to instruct us not to purchase certain mutual funds, stocks or other securities.
These restrictions may be a specific company security, industry sector, asset class, or any other
restriction you request. We have the right to refuse your restrictions if we feel they are too burdensome
to adequately manage your account.
We typically recommend investments in mutual funds and exchange-traded funds ("ETFs") but if other
investment types meet your investment objectives and risk tolerance, we could also recommend
investments in individual stocks and bonds, other fixed income investments, alternative asset classes
or investments, real estate investment trusts (REITs), private equity investments, fixed and variable
annuities, and structured products. If you currently own these or other investment types, we will review
them during our initial meetings with you and will take them into account during the implementation of
your selected investment strategy.
Under certain conditions, securities from outside accounts may be transferred into your advisory
account; however, we may recommend that you sell any security if we believe that it is not suitable for
the current recommended investment strategy. Additionally, trading may be required to meet initial
allocation targets, after substantial cash deposits that require investment allocation, and/or after a
request for a withdrawal that requires liquidation of a position.
Periodically, your account may need to be rebalanced or reallocated in order to reestablish the
targeted percentages of your initial asset allocation. This rebalancing or reallocation will occur as
required or pursuant to the schedule we have determined together.
You will be responsible for all tax consequences resulting from the sale of any security, rebalancing or
reallocation of the account. You are responsible for any taxable events in these instances. We are not
tax professionals and do not give tax advice. However, at your request we will work with your tax
professionals to assist you with tax planning.
You will be notified of any purchases or sales through trade confirmations and statements that are
provided by the custodian. These statements list the total value of the account, itemize all transaction
activity, and list the types, amounts, and total value of securities held. You will at all times maintain full
and complete ownership rights to all assets held in your account, including the right to withdraw
securities or cash, proxy voting and receiving transaction confirmations.
Financial Planning & Consulting Services
Financial planning is included at no additional cost for clients that participate in our Asset Management
Services. We also offer financial planning and consulting as standalone services.
These services are a comprehensive relationship which incorporates many different aspects of your
financial status into an overall plan that meets your goals and objectives. The financial planning
relationship consists of face-to-face or virtual meetings and ad hoc meetings with you and/or your other
advisors (attorneys, accountants, etc.) as necessary.
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In performing financial planning services, we typically examine and analyze your overall financial
situation, which may include issues such as taxes, insurance needs, overall debt, credit, business
planning, retirement savings and reviewing your current investment program. Our services may focus
on all or only one of these areas depending upon the scope of our engagement with you.
It is essential that you provide the information and documentation we request regarding your income,
investments, taxes, insurance, estate plan, etc. We will discuss your investment objectives, needs and
goals, but you are obligated to inform us of any changes. We do not verify any information obtained
from you, your attorney, accountant or other professionals.
If you engage us to perform these services, you will receive a written agreement detailing the services,
fees, terms and conditions of the relationship. You will also receive this Brochure. You are under no
obligation to implement recommendations through us. You may implement your financial plan through
any financial organization of your choice.
Clients are under no obligation to implement our recommendations. If you are a standalone financial
planning and consulting client who decides to engage us for asset management services, we will help
you open a custodial account(s), as needed. The funds in your account will generally be held in a
separate account, in your name, at an independent custodian, and not with us. We recommend using
Charles
Schwab & Co., Inc.
ERISA Plan Services
West Wealth Group provides both 3(21) and 3(38) services to Employee Retirement Income Security
Act of 1974, as amended ("ERISA"), plans. 3(21) and 3(38) fiduciaries are both individuals or entities
that provide investment expertise to ERISA plan sponsors, but there are some differences between
services. At a high level, a 3(21) fiduciary is an investment adviser and 'co-fiduciary' with the company
fiduciary (business owner, board, or named fiduciary). They provide investment recommendations on
how to build the fund lineup and monitor the investment options. But they don't have any decision-
making or discretionary authority. A 3(38) fiduciary, on the other hand, will actually make the decisions
about what to include in the plan menu, implement it, and then manage the investments on an ongoing
basis. Further details on our service offering for each fiduciary service are included below.
Non-Discretionary 3(21) Fiduciary Services
Through our non-discretionary 3(21) fiduciary services, the Adviser is appointed by the plan sponsor or
trustee to determine a recommended lineup of investments to be included in the Plan. These
recommendations are presented to the Plan Sponsor, who has the ultimate responsibility to accept or
reject the recommendation. The Adviser will not have any further responsibility to communicate
instructions to any third-party, including the custodian, and/or third-party administrator. The Adviser will
not communicate directly with the recordkeeper regarding administrative and recordkeeping matters
arising under the Adviser's investment advisory agreement with the Plan Sponsor, or more generally
about the recordkeeper's services to the Plan.
West Wealth Group offers 3(21) services based on each client's need. Services are included in the
advisory agreement.
We will conduct research to determine appropriate investment selections and allocations and to project
potential ranges of returns and market values over various time periods and using various cash flows
to assist the Plan Sponsor in determining the appropriate investment options for the retirement plan.
The data used to select the investment options is based on estimated, forward-looking performance of
various asset classes and subclasses to create our forward-looking capital markets assumptions (e.g.,
expected return, expected standard deviation, correlation, etc.). Past performance and the return
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estimates of the asset classes and the indices that correspond to these asset classes may not be
representative of actual future performance. Actual results could differ, based on various factors
including the expenses associated with the management of the portfolio, the portfolio's securities
versus the securities comprising the various indices and general market conditions. Before a specific
investment is selected, other factors such as economic trends, which may influence the choice of
investments and risk tolerance, should be considered. The Adviser has the responsibility and authority
to recommend the investment line up including evaluating investment managers and mutual fund
companies, individual mutual funds, and money market funds which may be retained or replaced. The
Plan Sponsor has the responsibility and authority to make the final decision regarding what
investments to include and when to add or exclude a specific security.
The Adviser encourages plan sponsors to consult with other professional advisors since we do not
provide tax or legal advice that may affect asset classes or allocations. The Adviser will apply any
guidelines the client supplies, as directed, however, compliance with these restrictions or guidelines, is
the client's responsibility.
Discretionary 3(38) Fiduciary Services
When a client engages West Wealth Group to perform "3(38) Fiduciary Services", the Adviser acts as
an "investment manager" (as defined in Section 3(38) of ERISA) with respect to the performance of
discretionary fiduciary investment services. Under this arrangement the Adviser is appointed by the
Plan Sponsor or trustee and accepts discretion over plan assets and assumes full responsibility and
liability for fiduciary functions concerning decisions related to the plan assets.
Under this arrangement the Adviser is appointed by the plan sponsor or trustee and accepts discretion
over plan assets and assumes full responsibility and liability for fiduciary functions concerning
decisions related to the plan assets. The Adviser will review the investment options available to the
Plan through documents provided by the Plan Sponsor and notifies the Plan's record-keeper and/or the
Plan Sponsor the Adviser's instructions to add, remove and/or replace these specific investment
options offered to Plan participants and/or used for administrative purposes under the Plan, according
to the criteria set forth in guidelines selected by the Plan Sponsor. The Plan Sponsor retains all
authority, responsibility and decision-making for investment options not available on the Plan record-
keeper's platform (i.e., "non- core" investment options, such as employer stock, plan loans, self-
directed brokerage accounts, frozen guaranteed investment contracts, and life insurance).
West Wealth Group will retain final decision-making authority with respect to removing and/or replacing
investments in the core lineup. The Plan Sponsor will not have responsibility to communicate
instructions to any third-party, custodian and/or third-party administrator.
The Adviser will also monitor the current managed investment line up including the investment's
performance compared to an applicable benchmark. If the Adviser determines that a fund no longer
meets the criteria, they will select alternatives and replace them.
IRA Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field
Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's
Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the
following acknowledgment to you. When we provide investment advice to you regarding your
retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I
of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable,
which are laws governing retirement accounts. The way we make money creates some conflicts with
your interests, so we operate under a special rule that requires us to act in your best interest and not
put our interest ahead of yours. Under this special rule's provisions, we must:
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•Meet a professional standard of care when making investment recommendations (give prudent
advice);
•Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest.
We benefit financially from the rollover of your assets from a retirement account to an account that we
manage or provide investment advice, because the assets increase our assets under management
and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in
your best interest.
Educational Seminars
We shall hold educational seminars and webinars covering a broad range of investment-related topics.
There is no additional fee for this service.
Tax Preparation and Certain Legal Services
We may choose to offer certain tax preparation and/or trusts and estate planning document
preparation services to clients. We will establish maximum amounts for the preparation of taxes and/or
the trust and estate planning document preparation per client per year and these will be outlined in
your agreement with West Wealth Group. These services will be provided by an unaffiliated CPA or
law firm and will be invoiced to us directly and may be paid by either West Wealth Group or your
Advisor. This creates a conflict of interest even though we do not share in the preparation fees charged
by the CPA or law firm because it encourages clients to increase their assets with our firm. It does not
increase the amount of fees we charge you. The services will not be offered to all clients. Typically, the
clients that are offered these services by us will have more assets with us than other clients may have.
Wrap Fee
The Adviser does not sponsor or participate in a third-party sponsored wrap fee program.
Assets Under Management
As of December 31, 2023, we had $349,279,398 in discretionary assets under management. We do
not have any non-discretionary assets under management.