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Item 2- Material Changes
This Disclosure document is being offered to you by Buck Wealth Strategies, LLC (“BWS”
“E.A. Buck” or “Firm”) about the investment advisory services our Firm provides. It
discloses information about the services that our Firm provides and the way those services
are made available to you, the client.
Buck Wealth Strategies, LLC was registered as an Investment Advisor with the SEC in July
2022. BWS is owned by Buck Enterprise, Inc. Jim Dixon is the Chief Compliance Officer of
the Firm.
Our Firm is committed to helping clients build, manage, and preserve their wealth. Our
Firm provides services that help clients to achieve their stated financial goals. BWS will
offer initial complimentary meetings upon our discretion; however, investment advisory
services are initiated only after you and BWS execute an Investment Management
Agreement.
INVESTMENT MANAGEMENT AND SUPERVISION SERVICES
BWS manages advisory accounts on a discretionary basis. For discretionary accounts, once
we have determined a profile and investment plan with a client, our Firm will execute the
day-to-day transactions without seeking prior client consent but within the expected
investment guidelines. Account supervision is guided by the client’s written profile and
investment plan. BWS will accept accounts with certain trading restrictions if
circumstances warrant. Our Firm will primarily allocate client assets among various
equities, Exchanged Traded Funds (“ETFs”), no-load or load-waived mutual funds in
accordance with their stated investment objectives. All of which are considered asset
allocation categories for the client’s investment strategy.
During personal discussions with clients, our Firm will determine the client’s objectives,
time horizons, risk tolerance, and liquidity needs. As appropriate, our Firm will also review
a client’s prior investment history, as well as family composition and background. Based
on client needs, BWS will develop a client’s personal profile and investment plan. We then
create and manage the client’s investments based on that policy and plan. It is the client’s
obligation to notify us immediately if circumstances have changed with respect to their
goals. Once we have determined the types of investments to be included in a client’s
portfolio and have allocated the assets, we provide ongoing investment review and
management services.
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With our discretionary relationship, BWS will make changes to the portfolio, as we deem
appropriate, to meet client financial objectives. Our Firm will trade these portfolios based
on the combination of our market views and client objectives, using our investment
process. BWS will tailor our advisory services to meet the needs of our clients and seek to
ensure that your portfolio is managed in a manner consistent with those needs and
objectives. Clients have the ability to leave standing instructions with us to refrain from
investing in particular industries or invest in limited amounts of securities.
Clients may engage us to advise on certain investment products that are not maintained
at our Firm’s recommended custodian, and assets held in employer sponsored retirement
plans. Where appropriate, our Firm will provide advice about any type of held away
account that is part of a client portfolio.
You are advised and are expected to understand that our past performance is not a
guarantee of future results. Certain market and economic risks exist that adversely affect
an account’s performance. This could result in capital losses in your account.
Buck Wealth Strategies has engaged AE Wealth Management, LLC (“AEWM”), an SEC
registered investment advisor, to provide asset management services to our clients.
The Program provides clients with the opportunity to participate in the asset management
services available to BWS through AEWM. Through the Program, AEWM serves as a
Turnkey Asset Management Program (“TAMP”) for Buck Wealth Strategies, and provides
the following services:
• Selection of model managers, portfolio managers, and third-party asset managers
on the platform;
• Research;
• Access to AEWM’s reporting systems, client relationship management systems
and workflow systems;
• Operational support to assist BWS with trading of its client accounts.
Through the financial planning process, our team strives to engage our clients in
conversations around the family’s goals, objectives, priorities, vision, and legacy – both for
the near term as well as for future generations. With the unique goals and circumstances
of each family in mind, our team will offer financial planning ideas and strategies to
address the client’s holistic financial picture, including estate, income tax, charitable, cash
flow, wealth transfer, and family legacy objectives. Our team partners with our client’s
other advisors (CPAs, Enrolled Agents, Estate Attorneys, Insurance Brokers, etc.) to ensure
a coordinated effort of all parties toward the client’s stated goals. Such services include
FINANCIAL PLANNING
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various reports on specific goals and objectives or general investment and/or planning
recommendations, guidance to outside assets, and periodic updates.
Our specific services in preparing your plan may include:
• Review and clarification of your financial goals.
• Assessment of your overall financial position including cash flow, balance sheet,
investment strategy, risk management, and estate planning.
• Creation of a unique plan for each goal you have, including personal and business
real estate, education, retirement or financial independence, charitable giving,
estate planning, business succession, and other personal goals.
• Development of a goal-oriented investment plan, with input from various advisors
to our clients around tax suggestions, asset allocation, expenses, risk, and liquidity
factors for each goal. This includes IRA and qualified plans, taxable, and trust
accounts that require special attention.
• Design of a risk management plan including risk tolerance, risk avoidance,
mitigation, and transfer, including liquidity as well as various insurance and
possible company benefits; and
• Crafting and implementation of, in conjunction with your estate and/or corporate
attorneys as tax advisor, an estate plan to provide for you and/or your heirs in the
event of an incapacity or death.
A written evaluation of each client's initial situation or Financial Plan is provided to the
client.
Retirement Plan Advisory Services consists of helping employer plan sponsors to establish,
monitor and review their company's retirement plan. Our firm offers (1) Discretionary
Investment Management Services, (2) Non-Discretionary Investment Advisory Services
and/or (3) Retirement Plan Consulting Services to employer-sponsored retirement plans
and their participants. Depending on the type of the Plan and the specific arrangement
with the Sponsor, we may provide one or more of these services. Prior to being engaged
by the Sponsor, we will provide a copy of this Form ADV Part 2A along with a copy of our
Privacy Policy and the Investment Fiduciary & Retirement Plan Consulting Agreement
("Agreement") that contains the information required under Sec. 408(b)(2) of the
Employee Retirement Income Security Act ("ERISA") as applicable.
The Agreement authorizes our Investment Adviser Representatives ("IARs") to deliver one
or more of the following services:
RETIREMENT PLAN ADVISORY SERVICES
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DISCRETIONARY INVESTMENT MANAGEMENT SERVICES
These services are designed to allow the Plan fiduciary to delegate responsibility for
managing, acquiring, and disposing of Plan assets that meet the requirements of the
Employee Retirement Income Security Act of 1974 ("ERISA"). We will perform these
investment management services through our IARs and charge fees as described in this
Form ADV and the Agreement. If the Plan is subject to ERISA, we will perform these
services as an “investment manager” as defined under ERISA Section 3(38) and as a
“fiduciary” to the Plan as defined under ERISA Section 3(21). Specifically, the Sponsor may
determine that we perform the following services:
Selection, Monitoring & Replacement of Designated Investment Alternatives
(“DIA”)
Our Firm will review with Sponsor the investment objectives, risk tolerance and
goals of the Plan and provide to Sponsor an IPS that contains criteria from which
we will select, monitor, and replace the Plan's DIAs. Once approved by Sponsor,
we will review the investment options available to the Plan and will select the
Plan's DIAs in accordance with the criteria set forth in the IPS. On a periodic basis,
our Firm will monitor and evaluate the DIAs and replace any DIA(s) that no longer
meet the IPS criteria.
Selection, Monitoring & Replacement of Qualified Default Investment Alternatives
(“QDIA(s)”)
Based upon the options available to the Plan, we will select, monitor, and replace
the Plan's QDIA(s) in accordance with the IPS.
Management Of Trust Fund
Our Firm will review with Sponsor the investment objectives, risk tolerance and
goals of the Plan and provide to Sponsor an IPS that contains criteria from which
we will select, monitor, and replace the Plan's investments. Once approved by
Sponsor, our Firm will review the investment options available to the Plan and will
select the Plan's investments in accordance with the criteria set forth in the IPS.
On a periodic basis, we will monitor and evaluate the investments and replace any
investment(s) that no longer meet the IPS criteria.
NON-DISCRETIONARY FIDUCIARY SERVICES
These
services are designed to allow the Sponsor to retain full discretionary authority or
control over the assets of the Plan. We will solely be making recommendations to the
Sponsor. We will perform these Non-Discretionary investment advisory services through
our IARs and charge fees as described in this Form ADV and the Agreement. If the Plan is
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covered by ERISA, we will perform these investment advisory services to the Plan as a
"fiduciary" defined under ERISA Section 3(21). The Sponsor may engage us to perform one
or more of the following Non-Discretionary investment advisory services:
Investment Policy Statement (“IPS”)
Our Firm will review with Sponsor the investment objectives, risk tolerance and
goals of the Plan. If the Plan does not have an IPS, we will provide
recommendations to Sponsor to assist with establishing an IPS. If the Plan has an
existing IPS, our Firm will review it for consistency with the Plan's objectives. If the
IPS does not represent the objectives of the Plan, we will recommend Sponsoring
revisions to align the IPS with the Plan's objectives.
Advice regarding designated investment alternatives (“DIAs”)
Based on the Plan's IPS or other guidelines established by the Plan, we will review
the investment options available to the Plan and will make recommendations to
assist Sponsor with selecting DIAs to be offered to Plan participants. Once Sponsor
selects the DIAs, our Firm will, on a periodic basis and/or upon reasonable request,
provide reports and information to assist Sponsor with monitoring the DIAs. If a
DIA is required to be removed, we will provide recommendations to assist Sponsor
with replacing the DIA.
Advice Regarding Qualified Default Investment Alternatives (“QDIA”)
Based on the Plan's IPS or other guidelines established by the Plan, our Firm will
review the investment options available to the Plan and will make
recommendations to assist Sponsor with selecting or replacing the Plan's QDIA(s).
Participant Investment Advice
Our Firm will meet with Plan participants, upon reasonable request, to collect
information necessary to identify the Plan participant's investment objectives, risk
tolerance, time horizon, etc. We will provide written recommendations to assist
the Plan participant with creating a portfolio using the Plan's DIAs or Models, if
available. The Plan participant retains sole discretion over the investment of
his/her account.
Advice Regarding Investment of Trust Fund
Based on the Plan's IPS, we will review the investment options available to the Plan
and will make recommendations to assist Sponsor with selecting investments that
meet the IPS criteria. Once Sponsor selects the investment(s), our Firm will, on a
periodic basis and/or upon reasonable request, provide reports and information
to assist Sponsor with monitoring the investment(s). If the IPS criteria require any
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investment(s) to be replaced, we will provide recommendations to assist Sponsor
with replacing the investment(s).
RETIREMENT PLAN CONSULTING SERVICES
Retirement Plan Consulting Services are designed to allow our IARs to assist the Sponsor
in meeting his/her fiduciary duties to administer the Plan in the best interests of Plan
participants and their beneficiaries. Retirement Plan Consulting Services are performed so
that they would not be considered “investment advice” under ERISA. The Sponsor may
elect for our IARs to assist with any of the following services:
Administrative Support
• Assist in reviewing objectives and options available through the Plan
• Review Plan committee structure and administrative policies/procedures
• Recommend Plan participant education and communication policies under
ERISA 404(c)
• Assist with development/maintenance of fiduciary audit file
• Deliver fiduciary training and/or education periodically
• Recommend procedures for responding to Plan participant requests
Service Provider Support
• Assist with a process to select, monitor and replace service providers
• Assist with review of Covered Service Providers ("CSP") and fee
benchmarking
• Provide reports and/or information designed to assist fiduciaries with
monitoring CSPs
• Assist with use of ERISA Spending Accounts or Plan Expense Recapture
Accounts to pay CSPs
• Assist with preparation and review of Requests for Proposals and/or
Information
• Coordinate and assist with CSP replacement and conversion
Investment Monitoring Support
• Periodic review of investment policy in the context of Plan objectives
• Assist the Plan committee with monitoring investment performance
• Assist with monitoring Designated Investment Managers and/or third-
party advice providers
• Educate Plan committee members, as needed, regarding replacement of
DIA(s) and/or QDIA(s)
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Participant Services
• Facilitate group enrollment meetings and coordinate investment education
• Assist Plan participants with financial wellness education, retirement
planning and/or gap analysis
Potential Additional Retirement Services Provided Outside of the Agreement
In providing Retirement Plan Services, we and our IARs may establish a client relationship
with one or more Plan participants or beneficiaries. Such client relationships develop in
various ways, including, without limitation:
• as a result of a decision by the Plan participant or beneficiary to purchase
services from us not involving the use of Plan assets;
• as part of an individual or family financial plan for which any specific
recommendations concerning the allocation of assets or investment
recommendations relating to assets held outside of the Plan; or
• through a rollover of an Individual Retirement Account ("IRA Rollover"). If
we are providing Retirement Plan Services to a plan, IARs may, when
requested by a Plan participant or beneficiary, arrange to provide services
to that participant or beneficiary through a separate agreement. If a Plan
participant or beneficiary desires to affect an IRA Rollover from the Plan to
an account advised or managed by us, IAR will have a conflict of interest if
his/her fees are reasonably expected to be higher than those we would
otherwise receive in connection with the Retirement Plan Services. IAR will
disclose relevant information about the applicable fees charged by us prior
to opening an IRA account. Any decision to affect the rollover or about
what to do with the rollover assets remains that of the Plan participant or
beneficiary alone.
DISCLOSURE REGARDING ROLLOVER RECOMMENDATIONS
A client or prospect leaving an employer typically has four options regarding an existing
retirement plan (and may engage in a combination of these options): (i) leave the money
in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s
plan, if one is available and rollovers are permitted, (iii) rollover to an Individual
Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending
upon the client’s age, result in adverse tax consequences). Our Firm may recommend an
investor roll over plan assets to an IRA for which our Firm provides investment advisory
services. As a result, our Firm and its representatives may earn an asset-based fee. In
contrast, a recommendation that a client or prospective client leave their plan assets with
their previous employer or roll over the assets to a plan sponsored by a new employer will
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generally result in no compensation to our Firm. Our Firm therefore has an economic
incentive to encourage a client to roll plan assets into an IRA that our Firm will manage,
which presents a conflict of interest. To mitigate the conflict of interest, there are various
factors that our Firm will consider before recommending a rollover, including but not
limited to: (i) the investment options available in the plan versus the investment options
available in an IRA, (ii) fees and expenses in the plan versus the fees and expenses in an
IRA, (iii) the services and responsiveness of the plan’s investment professionals versus
those of our Firm, (iv) protection of assets from creditors and legal judgments, (v) required
minimum distributions and age considerations, and (vi) employer stock tax consequences,
if any. All rollover recommendations are also reviewed by our Firm’s Chief Compliance
Officer in a best effort to determine that the recommendation to a client was reasonable
or that the client has determined to make the rollover after being provided ample
information about their options. No client is under any obligation to roll over plan assets
to an IRA advised by our Firm or to engage our Firm to monitor and/or advise on the
account while maintained with the client's employer. Our Firm’s Chief Compliance Officer
remains available to address any questions that a client or prospective client has regarding
this disclosure.
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide
investment advice to you regarding your retirement plan account or individual retirement
account, we are also 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. We have to act in your best interest and not put our
interest ahead of yours. At the same time, the way we make money creates some conflicts
with your interests.
WRAP FEE PROGRAM
Our Firm does not offer a Wrap Fee Program.
As of December 31, 2023, the firm has $299,865,422 in discretionary assets under
management. the firm has no non-discretionary assets under management.
ASSETS
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