This Disclosure document is being offered to you by First Source Investment Partners, LLC
DBA Tier One Wealth Management (“Tier One” or “Firm”) about the investment advisory
services we provide. It discloses information about the services that we provide and the
way those services are made available to you, the client.
Tier One was registered as an Investment Advisor with the SEC in September 2022, the
firm converted to state registration with Colorado, Texas, California and Nebraska during
February and March 2023. The owners of Tier One are as follows: Gregory Dexter, AIF®,
CRPC® and Garret Jett, APMA®. Garret Jett is the Chief Compliance Officer of the Firm.
We are committed to helping clients build, manage, and preserve their wealth. Our Firm
provides services that help clients to achieve their stated financial goals. We will offer initial
complimentary meetings upon our discretion; however, investment advisory services are
initiated only after you and Tier One execute an Investment Management Agreement.
INVESTMENT MANAGEMENT AND SUPERVISION SERVICES
We manage advisory accounts on a discretionary basis. For discretionary accounts, once
we have determined a profile and investment plan with a client, we 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. We will accept accounts with certain trading restrictions if circumstances
warrant. We primarily allocate client assets among various equities, Exchanged Traded
Funds (“ETFs”), no-load or load-waived mutual funds, options, structured CD and notes
and limited alternative investments in accordance with their stated investment objectives.
During personal discussions with clients, we determine the client’s objectives, time
horizons, risk tolerance, and liquidity needs. As appropriate, we also review a client’s prior
investment history, as well as family composition and background. Based on client needs,
we 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.
With our discretionary relationship, we will make changes to the portfolio, as we deem
appropriate, to meet client financial objectives. We trade these portfolios based on the
combination of our market views and client objectives, using our investment process. We
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
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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, we 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.
FINANCIAL PLANNING
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, Certified Financial
Planners, etc.) to ensure a coordinated effort of all parties toward the client’s stated goals.
Such services include 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
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• 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
For employer-sponsored
retirement plans with participant-directed investments, our firm
provides its advisory services as an investment adviser as defined under Section 3(21) of
the Employee Retirement Income Security Act of 1974, as amended (“ERISA”).
When serving as an ERISA 3(21) investment adviser, the Plan Sponsor and our Firm share
fiduciary responsibility. The Plan Sponsor retains ultimate decision-making authority for
the investments and may accept or reject the recommendations in accordance with the
terms of a separate ERISA 3(21) Plan Sponsor Investment Management Agreement
between our Firm and the Plan Sponsor. Under the 3(21) agreement, our Firm provides
the following services to the Plan Sponsor:
• Screen investments and make recommendations.
• Monitor the investments and suggests replacement investments when
appropriate.
• Provide a quarterly monitoring report.
• Assist the plan sponsor in developing an Investment Policy Statement (“IPS”).
• Recommend QDIA alternatives.
• Recommend non-discretionary model portfolios.
We can also be engaged to provide Plan Consulting Services. Plan Consulting Services
include financial education to Plan participants, benchmarking the Plan services, education
to fiduciary committee members, and monitoring the service provider. The scope of
education provided to participants will not constitute “investment advice” within the
meaning of ERISA and participant education will relate to general principles for investing
and information about the investment options currently in the Plan. We may also
participate in initial enrollment meetings and periodic workshops and enrollment meetings
for new participants.
CONSULTING SERVICES
We also provide clients investment advice on a more-limited basis on one or more isolated
areas of concern such as estate planning, real estate, retirement planning, or any other
specific topic. Additionally, we provide advice on non-securities matters about the
rendering of estate planning, insurance, real estate, and/or annuity advice or any other
business advisory / consulting services for equity or debt investments in privately held
businesses. In these cases, clients will be required to select their own investment managers,
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custodian, and/or insurance companies for the implementation of consulting
recommendations. If client needs include brokerage and/or other financial services, we
will recommend the use of one of several investment managers, brokers, banks, custodians,
insurance companies, or other financial professionals ("Firms"). Consulting clients must
independently evaluate these Firms before opening an account or transacting business and
have the right to effect business through any firm they choose. Clients have the right to
choose whether or not to follow the consulting advice provided.
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
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.
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We are fiduciaries under the Investment Advisers Act of 1940 and similar state statutes
and rules 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.
ASSETS
As of January 13, 2023, we managed $64,867,635 in client assets on a discretionary basis.