A. Ownership/Advisory History
Schamberger, Greylak & Utterback Wealth Management, LLC (“SGU Wealth” or the “firm”) is a
Wisconsin limited liability company. The firm was formed in January 2022 and is owned by
Larry Schamberger, Thomas Greylak, and David Utterback.
B. Advisory Services Offered
Discretionary Asset Management Services
For its discretionary asset management services, SGU Wealth receives a limited power of
attorney to effect securities transactions on behalf of its clients that include securities and
strategies described in Item 8 of this brochure.
SGU Wealth’s discretionary asset management services are predicated on the client's investment
objectives, goals, tolerance for risk, and other personal and financial circumstances. SGU Wealth
will analyze each client's current investments, investment objectives, goals, age, time horizon,
financial circumstances, investment experience, investment restrictions and limitations, and risk
tolerance and implement a portfolio consistent with such investment objectives, goals, risk
tolerance and related financial circumstances. SGU Wealth’s objective is to review the client’s tax,
financial, and estate planning objectives and goals in connection with the client’s investment
objectives, goals, tolerance for risk, and other personal and financial circumstances and make
appropriate recommendations and implementation decisions. SGU Wealth may engage third-
party service providers to assist with the tax and estate planning portion of the services provided
to clients. In addition, SGU Wealth may utilize third-party software to analyze individual security
holdings and separate account managers utilized within the client’s portfolio.
SGU Wealth’s investment advisory services to clients take into account a client's personal
financial circumstances, investment objectives and tolerance for risk (e.g., cash-flow, tax and
estate). SGU Wealth’s engagement with a client will include, as appropriate, the following:
Providing assistance in reviewing the client's current investment portfolio against the
client's personal and financial circumstances as disclosed to SGU Wealth in response to a
questionnaire and/or in discussions with the client and reviewed in meetings with SGU
Wealth.
Analyzing the client's financial circumstances, investment holdings and strategy, and
goals.
Providing assistance in identifying a targeted asset allocation and portfolio design.
Implementing and/or recommending individual equity and fixed income securities,
mutual funds and ETFs.
Reporting to the client on a quarterly basis or at some other interval agreed upon with
the client, information on contributions and withdrawals in the client's investment
portfolio, and the performance of the client's portfolio measured against appropriate
benchmarks (including benchmarks selected by the client).
Proposing changes in the client's investment portfolio in consideration of changes in the
client's personal circumstances, investment objectives and tolerance for risk, the
performance record of any of the client's investments, and/or the performance of any
fund retained by the client.
If the client’s portfolio and personal circumstances, investment objectives, and tolerance
for risk make such advice appropriate, providing recommendations to hedge a client’s
portfolio through the use of derivative strategies, to generate additional income through
the use of covered call option writing strategies involving exchange listed or OTC
options, and/or to monetize or hedge concentrated stock positions.
In addition to providing SGU Wealth with information regarding their personal financial
circumstances, investment objectives and tolerance for risk, clients are obligated to provide the
firm with any reasonable investment restrictions that should be imposed on the management of
their portfolio, and to promptly notify the firm in writing of any changes in such restrictions or in
the client's personal financial circumstances, investment objectives, goals and tolerance for risk.
SGU Wealth will remind clients of their obligation to inform the firm of any such changes or any
restrictions that should be imposed on the management of the client’s account. SGU Wealth will
also contact clients at least annually to determine whether there have been any changes in a
client's personal financial circumstances, investment objectives and tolerance for risk.
LPL Financial Sponsored Advisory Programs
SGU Wealth may provide advisory services through programs sponsored by LPL Financial LLC
(LPL), a registered investment advisor and broker-dealer. Below is a brief description of each LPL
advisory program available to SGU Wealth. For more information regarding the LPL programs,
including more information on the advisory services and fees that apply, the types of
investments available in the programs and the potential conflicts of interest presented by the
programs, please see the program account packet (which includes the account agreement and
LPL Form ADV program brochure) and the Form ADV, Part 2A of LPL or the applicable program.
Optimum Market Portfolios Program (OMP)
OMP offers clients the ability to participate in a professionally managed asset allocation
program using Optimum Funds shares. Under OMP, client will authorize LPL on a discretionary
basis to purchase and sell Optimum Funds pursuant to investment objectives chosen by the
client. SGU Wealth will assist the client in determining the suitability of OMP for the client and
assist the client in setting an appropriate investment objective. SGU Wealth will have discretion
to select a mutual fund asset allocation portfolio designed by LPL consistent with the client’s
investment objective. LPL will have discretion to purchase and sell Optimum Funds pursuant to
the portfolio selected for the client. LPL will also have authority to rebalance the account.
A minimum account value of $10,000 is required for OMP. In certain instances, LPL will permit a
lower minimum account size.
Model Wealth Portfolios Program (MWP)
MWP offers clients a professionally managed mutual fund asset allocation program. SGU Wealth
will obtain the necessary financial data from the client, assist the client in determining the
suitability of the MWP program and assist the client in setting an appropriate investment
objective. SGU Wealth will initiate the steps necessary to open an MWP account and have
discretion to select a model portfolio designed by LPL’s Research Department consistent with
the client’s stated investment objective. LPL’s Research Department, a third-party portfolio
strategist and/or SGU Wealth, through its IAR, may act as a portfolio strategist responsible for
selecting the mutual funds or ETFs within a model portfolio and for making changes to the
mutual funds or ETFs selected.
The client will authorize LPL to act on a discretionary basis to purchase and sell mutual funds
and ETFs and to liquidate previously purchased securities. The client will also authorize LPL to
effect rebalancing for MWP accounts.
MWP requires a minimum asset value for a program account to be managed. The minimums
vary depending on the portfolio(s) selected and the account’s allocation amongst portfolios. The
lowest minimum for a portfolio is $25,000. In certain instances, a lower minimum for a portfolio
is permitted.
Guided Wealth Portfolios (GWP)
GWP offers clients the ability to participate in a centrally managed, algorithm-based investment
program, which is made available to users and clients through a web-based, interactive account
management portal (“Investor Portal”). Investment recommendations to buy and sell exchange-
traded funds and open-end mutual funds are generated through proprietary, automated,
computer algorithms (collectively, the “Algorithm”) of FutureAdvisor, Inc. (“FutureAdvisor”),
based upon model portfolios constructed by LPL and selected for the account as described
below (such model portfolio selected for the account, the “Model Portfolio”). Communications
concerning GWP are intended to occur primarily through electronic means (including but not
limited to, through email communications or through the Investor Portal), although SGU Wealth
will be available to discuss investment strategies, objectives or the account in general in person
or via telephone.
A preview of the Program (the “Educational Tool”) is provided for a period of up to forty-five
(45) days to help users determine whether they would like to become advisory clients and
receive ongoing financial advice from LPL, FutureAdvisor and SGU Wealth by enrolling in the
advisory service (the “Managed Service”). The Educational Tool and Managed Service are
described in more detail in the GWP Program Brochure. Users of the Educational Tool are not
considered to be advisory clients of LPL, FutureAdvisor or SGU Wealth, do not enter into an
advisory agreement with LPL, FutureAdvisor or SGU Wealth, do not receive ongoing investment
advice or supervisions of their assets, and do not receive any trading services.
A minimum account value of $5,000 is required to enroll in the Managed Service.
Features of the Educational Tool
Users of the Educational Tool (each, a “user”) agree to a terms of use (“Terms of Use”) and
complete an investor profile. An investment objective (“Investment Objective”) and Model
Portfolio is assigned to each user based upon factors in the investor profile, including risk
tolerance and the number of years remaining until the age of retirement (such time being
referred to herein as the “Retirement Age”). (See description in “Features of the Managed
Service” below for information regarding the design of the Model Portfolios.) Based on the
Investment Objective and Model Portfolio, the Educational Tool generates sample analysis,
advice, and investment recommendations (“Sample Recommendations”).
The Educational Tool provides Sample Recommendations that may assist users in determining
whether to utilize the Managed Service. Access to the Educational Tool is generally limited to a
period of forty-five (45) days. The Educational Tool is intended to be used for educational and
informational purposes only. The Educational Tool does not provide comprehensive financial
planning and is not intended to constitute legal, financial or tax advice. There may be other
relevant factors and financial considerations (e.g., debt load or financial obligations) that LPL,
FutureAdvisor and SGU Wealth do not take into consideration in formulating any Sample
Recommendations provided. The Sample Recommendations made are meant solely as a
sample of the types of recommendations available through the Managed Service. LPL,
FutureAdvisor and SGU Wealth are not responsible for any actions taken with respect to the
Sample Recommendations, and users are solely responsible for making their own investment
decisions. The Educational Tool is only one of many tools that users may use as part of a
comprehensive investment analysis process. Users should not rely on the Educational Tool as
the sole basis for investment decisions.
Although LPL is an investment adviser and broker-dealer registered with the SEC and a
member of the Financial Industry Regulatory Authority, and FutureAdvisor is an investment
adviser registered with the SEC, in providing access to the Educational Tool, LPL,
FutureAdvisor, and SGU Wealth do not intend to establish an advisory relationship, or in the
case of LPL, a brokerage relationship, with users of the Educational Tool. Users are not charged
an advisory fee or any other fee or expense to use the Educational Tool. The scope of any
investment advisory relationship with LPL, FutureAdvisor, and SGU Wealth begins when users
enroll in the Managed Service. The output that users receive by using the Educational Tool,
including the Sample Recommendations, may differ materially from the advice users would
receive as an advisory client of LPL, FutureAdvisor, and SGU Wealth.
None of LPL, FutureAdvisor, or SGU Wealth provides ongoing investment management or
trading services for assets of users of the Educational Tool, makes any determination as to
whether the website through which the Program is accessed or the Educational Tool is
appropriate for any user, can access any assets in any accounts users aggregate in the
Educational Tool, places any trades on behalf of users of the Educational Tool, or provides
ongoing supervision of assets of users of the Educational Tool. The Sample Recommendations
provided are intended as an informational preview of the Managed Service, and the Sample
Recommendations are being provided to demonstrate the types of analysis, advice and
recommendations provided by the Managed Service.
Features of the Managed Service
Investors participating in the Managed Service (“clients” and each, a “client”) complete an
account application (the “Account Application”) and enter into an account agreement (the
“Account Agreement”) with LPL, SGU Wealth and FutureAdvisor. As part of the account
opening process, clients are responsible for providing complete and accurate information
regarding, among other things, their age, risk tolerance, and investment horizon (collectively,
“Client Profile”). LPL, SGU Wealth, and FutureAdvisor rely on the information in the Client
Profile in order to provide services under the Program, including but not limited to,
determination of suitability of the Program for clients and an appropriate Investment
Objective and Model Portfolio for clients. The Model Portfolios have been designed and are
maintained by LPL or, in the future, a third-party investment strategist (as applicable, the
“Portfolio Strategist”) and shall include a list of securities holdings, relative weightings and a
list of potential replacement securities for tax harvesting purposes. FutureAdvisor, SGU Wealth,
and clients cannot access, change or customize the Model Portfolios. Only one Model
Portfolio is permitted per account.
Based upon a client’s risk tolerance as indicted in the Client Profile, the client is assigned an
investment allocation track (currently Fixed Income Tilt, Balance Tilt or Equity Tilt), the purpose
of which is to slowly rotate the client’s equity allocation to fixed income over time. LPL
Research created these tracks using academic research on optimal retirement allocations, the
industry averages as calculated by Morningstar for the target date fund universe, and input
from FutureAdvisor.
Within the applicable allocation track and based upon a client’s chosen Retirement Age in the
Client Profile, the client will be assigned a Model Portfolio and one of five of LPL’s standard
investment objectives:
Income with capital preservation. Designed as a longer term accumulation account, this
investment objective is considered generally the most conservative. Emphasis is placed
on generation of current income with minimal risk of capital loss. Lowering the risk
generally means lowering the potential income and overall return.
Income with moderate growth. This investment objective emphasizes generation of
current income with a secondary focus on moderate capital growth.
Growth with income. This investment objective emphasizes modest capital growth with
some focus on generation of current income.
Growth. This investment objective emphasizes achieving high long-term growth and
capital appreciation. There is little focus on generation of current income.
Aggressive
growth. This investment objective emphasizes aggressive growth and
maximum capital appreciation, with no focus on generation of current income. This
objective has a very high level of risk and is for investors with a longer timer horizon.
Both the client and SGU Wealth are required to review and approve the initial Investment
Objective. As a client approaches the Retirement Age, the Algorithm will automatically adjust
the client’s asset allocation. Any change to the Investment Objective directed by a client due
to changes in the Client’s risk tolerance and/or Retirement Age will require written approval
from the client and SGU Wealth before implementation. Failure to approve the change in
Investment Objective may result in a client remaining in a Model Portfolio that is no longer
aligned with the applicable Client Profile. The Investment Objective selected for the account is
an overall objective for the entire account and may be inconsistent with a particular holding
and the account’s performance at any time and may be inconsistent with other asset
allocations suggested to client by LPL, SGU Wealth or FutureAdvisor prior to client entering
into the Account Agreement. Achievement of the stated investment objective is a long-term
goal for the account, and asset withdrawals may impair the achievement of client’s investment
objectives. A Client Profile that includes a conservative risk tolerance over a long-term
investment horizon may result in the selection of an Investment Objective that is riskier than
would be selected over a shorter-term investment horizon. Clients should contact SGU Wealth
if they believe the Investment Objective does not appropriately reflect the Client Profile, such
as their risk tolerance.
By executing the Account Agreement, clients authorize LPL and FutureAdvisor to have
discretion to buy and sell only exchange-traded funds (“ETFs”) and open-end mutual funds
(“Mutual Funds”) (collectively, “Program Securities”) according to the Model Portfolio selected
and, subject to certain limitations described in the Account Agreement, hold or liquidate
previously purchased non-model securities that are transferred into the account (“Legacy
Securities”). In order to be transferred into an account, Legacy Securities must be Mutual
Funds with which LPL has a full or partial selling agreement, ETFs or individual U.S. listed
stocks. Securities that are not Program Securities included within the Model Portfolio will not
be purchased for an account, and FutureAdvisor, in its sole discretion, will determine whether
to hold or sell Legacy Securities, generally, but not solely, with the goal of optimizing tax
impacts for accounts that are subject to tax. Additional Legacy Securities will not be purchased
for the account. Clients may not impose restrictions on liquidating any Legacy Securities for
any reason. Clients should not transfer in Legacy Securities that they are not willing to have
liquidated at the discretion of FutureAdvisor.
In addition, uninvested cash may be invested in money market funds, the Multi-Bank Insured
Cash Account (“ICA”) or the Deposit Cash Account (“DCA”), as applicable, as described in the
Account Agreement. Dividends paid by the Program Securities in the account will be
contributed to the cash allocation and ultimately reinvested into the account based on the
Model Portfolio once the tolerance within cash allocation is surpassed.
Pursuant to the Account Agreement, FutureAdvisor is authorized to perform tax harvesting
when deemed acceptable by the Algorithm based on the Legacy Securities’ respective tax lot
information. If tax lot information is missing for a Legacy Security, the Legacy Security will be
retained in the Account while FutureAdvisor and SGU Wealth use reasonable efforts to obtain
the missing information. If the information cannot be obtained within a reasonable timeframe
(generally no longer than 30 days), the Legacy Security will be sold and replaced with a
Program Security in the Model Portfolio. LPL, SGU Wealth and clients cannot alter trades made
for tax harvesting purposes. In order to permit trading in a tax-efficient manner, the Account
Agreement also grants FutureAdvisor the authority to select specific tax lots when liquidating
securities within the account. Although the Algorithm attempts to achieve tax efficiencies, by
doing so a client’s portfolio may not directly align with Model Portfolio. As a result, a client
may receive advice that differs from the advice received by accounts using the same Model
Portfolio, and the client’s account may perform differently than other accounts using the same
Model Portfolio.
During the term of the Account Agreement, FutureAdvisor will perform a daily review of the
account to determine if rebalancing is appropriate based on tolerance thresholds established
by LPL and/or FutureAdvisor. At each rebalancing review, the account will be rebalanced if at
least one of the account positions is outside such thresholds, subject to a minimum
transaction amount established by LPL and/or FutureAdvisor. In addition, LPL and/or
FutureAdvisor may review the account for rebalancing in the event that the Portfolio Strategist
changes a Model Portfolio. FutureAdvisor may delay placing rebalancing transactions for non-
qualified accounts by a number of days, to be determined by FutureAdvisor, in an attempt to
limit short-term tax treatment for any position being sold. In addition, trading in the account
at any given time is also subject to certain conditions, including but not limited to, conditions
related to trade size, compliance tests, the target cash allocation and allocation tolerances.
LPL, SGU Wealth and clients can alter the rebalancing frequency.
Selection of FutureAdvisor as Third-Party Robo Advisor
Under SGU Wealth’s agreement with LPL, SGU Wealth was provided the opportunity to offer
GWP, which utilizes FutureAdvisor’s Algorithm as described herein, to prospective clients.
FutureAdvisor is compensated directly by LPL for its services, including the Algorithm and
related software, through an annual sub-advisory fee (tiered based on assets under
management by FutureAdvisor, at a rate ranging from 0.10% to 0.17%). As each asset tier is
reached, LPL’s share of the compensation shall increase and clients will not benefit from such
asset tiers. No additional fee is charged for FutureAdvisor’s services.
SGU Wealth believes that certain clients will benefit from GWP’s advisor-enhanced advisory
services, particularly due to the relatively low minimum account balance and the combination
of a digital advice solution with access to an advisor. Unlike direct-to-consumer robo
platforms, SGU Wealth is responsible on an ongoing basis as investment advisor and fiduciary
for the client relationship, including for recommending the program for the client; providing
ongoing monitoring of the program, the performance of the account, the services of LPL and
FutureAdvisor; determining initial and ongoing suitability of the program for the client;
reviewing clients’ suggested portfolio allocations; reviewing and approving any change in
Investment Objective due to changes clients make to their Client Profile; answering questions
regarding the program, assisting with paperwork and administrative and operational details
for the account; and being available to clients to discuss investment strategies, changes in
financial circumstances, objectives or the account in general in person or via telephone. SGU
Wealth can also recommend other suitable investment programs if clients have savings goals
or investment needs for which GWP is not the optimal solution.
Consulting and Financial Planning Services
The firm offers financial planning services, which may include a review of a client’s current
financial situation, such as cash management, risk management, insurance, education funding,
goal setting, retirement planning, estate and charitable gift planning, tax planning, and capital
needs planning. Creation of a comprehensive financial plan generally requires at least four hours
of an investment adviser representative’s time. Financial planning services are offered to those
clients who express need for such comprehensive planning, and some clients do not utilize the
firm for such services.
A financial plan may include both long and short-term considerations, depending upon the
client’s financial situation. Upon completion, a plan is presented to the client, compatible with
the client’s stated goals and objectives. An implementation schedule is reviewed with the client
to determine what steps will be pursued, and with whom the steps may be accomplished.
The firm’s financial plan may be a comprehensive plan encompassing a client’s entire financial
situation, including asset allocation, investments, retirement planning, education expenses,
estate planning and insurance needs. Alternatively, in consultation with a client, the financial
plan may involve less than all of such components.
ERISA Plan Consulting Services
Non-Discretionary 3(21) Fiduciary Services
Investment Policy Statement (“IPS”): SGU Wealth will review with the plan sponsor the
investment objectives, risk tolerance, and goals of the plan. If the plan does not have an
IPS, SGU Wealth will provide recommendations to the plan sponsor to assist the plan
sponsor with establishing an IPS. If the plan has an existing IPS, SGU Wealth will review it
for consistency with the plan’s objectives. If the IPS does not represent the objectives of
the plan, SGU Wealth will recommend to the plan sponsor revisions to align the IPS with
the plan’s objectives, which recommendations may be considered by the plan sponsor.
Designated Investment Alternatives (“DIA”): Based on the plan’s IPS, SGU Wealth will
review the investment options available to the plan and will make recommendations to
assist the plan sponsor with selecting DIAs to be offered to participants. Once the plan
sponsor selects the DIAs, SGU Wealth will, on a periodic basis and/or upon reasonable
request, provide reports and information to assist the plan sponsor with monitoring the
DIAs. If the IPS criteria require a DIA to be removed, SGU Wealth will provide
recommendations to assist the plan sponsor with replacing the DIA.
Model Asset Allocation Portfolios (“Models”): Based on the plan’s IPS or other investment
guidelines established by the plan, SGU Wealth will review the DIAs available to the plan
and will make recommendations to assist the plan sponsor with creating risk-based
models comprised solely among the plan’s DIAs. Once the plan sponsor approves the
models, SGU Wealth will provide reports, information and recommendations, on a
periodic basis, designed to assist the plan sponsor with monitoring the models. If the IPS
criteria require any DIA(s) to be removed, SGU Wealth will provide recommendations to
assist the plan sponsor with evaluating replacement DIA(s) to be included in the models.
Upon reasonable request, and depending upon the capabilities of the recordkeeper, SGU
Wealth will make recommendations to the plan sponsor to reallocate and/or rebalance
the models to maintain their desired allocations.
Qualified Default Investment Alternative (“QDIA”): Based on the plan’s IPS or other
guidelines established by the plan, SGU Wealth will review the investment options
available to the plan and will make recommendations to assist the plan sponsor with
selecting the plan’s QDIA(s). Once the plan sponsor selects the plan’s QDIA(s), SGU
Wealth will provide reports and information, on a periodic basis and/or upon reasonable
request, to assist the plan sponsor in monitoring the QDIA(s). If the IPS criteria require a
QDIA to be replaced, SGU Wealth will provide recommendations to assist the plan
sponsor with evaluating replacement QDIA(s).
Plan Consulting Services
Administrative Support:
• Assist plan sponsor in reviewing objectives and options available through the plan
• Review plan committee structure and administrative policies/procedures
• Recommend participant education and communication policies under ERISA
§404(c)
• Assist with development/maintenance of fiduciary audit file and document
retention policies
• Deliver fiduciary training and/or education periodically or upon reasonable request
• Assist with coordination of participant disclosures under 404a-5
• Develop requirements for responding to participant requests
Service Provider Relationship Oversight:
• Assist fiduciaries with a process to select, monitor and replace service providers
• Assist fiduciaries with review of Covered Service Providers (“CSP”) disclosures under
ERISA §408(b)(2) and fee benchmarking
• Provide reports and/or information designed to assist fiduciaries with monitoring
CSPs
• Review ERISA Spending Accounts or Plan Expense Recapture Accounts
• Assist with preparation and review of Requests for Proposals and/or Information
• Coordinate and assist with CSP replacement and conversion
Investments:
• Periodic review of investment policy in the context of plan objectives
• Assist the plan committee with monitoring investment performance
• Provide analysis of investment managers and model portfolios
• Review and recommend Designated Investment Managers (“DIMs”) and/or third-
party advice providers as necessary
• Educate plan committee members, as needed, regarding replacement of DIA(s)
and/or QDIA(s)
Participant Services:
• Facilitate group enrollment meetings
• Coordinate employee education regarding plan investments and fees
• Assist participants in understanding plan benefits, retirement readiness and impact
of increasing deferrals
Discretionary 3(38) Fiduciary Services
SGU Wealth will implement the IPS by investing and reinvesting the plan’s assets
consistent with the IPS.
SGU Wealth will reallocate and/or rebalance the models to maintain their desired
allocations.
Adviser will select investment options that are available under the plan.
Collateralized Loan Programs
SGU Wealth participates in loan programs offered by Goldman Sachs Bank USA and The
Bancorp Bank whereby SGU Wealth clients may be referred for custom collateralized loans
secured by certain investment property, securities, securities entitlements, and other financial
assets maintained in their securities accounts. In order to participate in the loan programs, the
client’s assets are required to be custodied at certain approved custodians.
C. Client-Tailored Services and Client-Imposed Restrictions
Each client’s account will be managed on the basis of the client’s financial situation and
investment objectives and in accordance with any reasonable restrictions imposed by the client
on the management of the account—for example, restricting the type or amount of security to
be purchased in the portfolio.
D. Wrap Fee Programs
SGU Wealth does not participate in wrap fee programs, where brokerage commissions and
transaction costs are included in the asset-based fee charged to the client.
E. Client Assets Under Management
As of December 31, 2023, SGU Wealth managed $230,448,519 of discretionary assets under
management and $0 non-discretionary assets under management. Additionally, SGU Wealth
has $3,455,000 of assets under advisement (AUA) consisting of a company retirement plan for
which SGU acts as advisor.