Gateway Wealth offers a variety of advisory services, which include financial planning, consulting, and
investment management services. Prior to Gateway Wealth rendering any of the foregoing advisory
services, clients are required to enter into one or more written agreements with Gateway Wealth setting
forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”).
Gateway Wealth has been registered as an investment adviser since September 2022 and is principally
owned by David Wood (Chief Visionary Officer), Eric Hall (Chief Executive Officer) and Jill Batley
(President and Chief Compliance Officer). As of December 31, 2023, Gateway Wealth had $891,580,271
in regulatory assets under management, $556,507,460 of which were managed on a discretionary basis and
$335,072,811 on a non-discretionary basis.
While this brochure generally describes the business of Gateway Wealth, certain sections also discuss the
activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons
occupying a similar status or performing similar functions), employees or other persons who provide
investment advice on Gateway Wealth’s behalf and are subject to the Firm’s supervision or control.
Financial Planning and Consulting Services
Gateway Wealth will typically provide a variety of financial planning and consulting services to clients,
pursuant to a written financial planning agreement. 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. Gateway Wealth may
also refer clients to an accountant, attorney or other specialists, as appropriate for their unique situation.
For certain financial planning engagements, the Firm will provide a written summary of the client’s
financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Firm
may not provide a written summary.
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 of interest. For example, the Firm has an incentive to recommend that
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clients engage the Firm for investment management services or to increase the level of investment assets
with the Firm, as it would increase the amount of advisory fees paid to the Firm. Clients are not obligated
to implement any recommendations made by Gateway Wealth or maintain an ongoing relationship with the
Firm. If the client elects to act on any of the recommendations made by the Firm, the client is under no
obligation to implement the transaction through the Firm. Clients are advised that it remains their
responsibility to promptly notify the Firm of any change in their financial situation or investment objectives
for the purpose of reviewing, evaluating or revising Gateway Wealth’s recommendations and/or services.
While these services are available on a stand-alone basis, certain of them can also be rendered in conjunction
with investment portfolio management as part of a comprehensive wealth management engagement
(described in more detail below).
In performing these services, Gateway Wealth is not required to verify any information received from the
client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized
to rely on such information. Gateway Wealth recommends certain clients engage the Firm for additional
related services, its Supervised Persons in their individual capacities as insurance agents or registered
representatives of a broker-dealer and/or other professionals to implement its recommendations.
Wealth Management Services
Gateway Wealth provides clients with wealth management services which include a broad range of
financial planning and consulting services as well as discretionary and/or non-discretionary management
of investment portfolios.
In accordance with the client’s stated investment objectives, Gateway Wealth primarily allocates client
assets among various low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”). The Firm
may also utilize individual stocks and bonds and independent investment managers (“Independent
Managers”) where appropriate.
Where appropriate, the Firm also provides advice about any type of legacy position or other investment
held in client portfolios, but clients should not assume that these assets are being continuously monitored
or otherwise advised on by the Firm unless specifically agreed upon. Clients can engage Gateway Wealth
to
manage and/or advise on certain investment products that are not maintained at their primary custodian,
such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans
and qualified tuition plans (i.e., 529 plans). In these situations, Gateway Wealth directs or recommends the
allocation of client assets among the various investment options available with the product. These assets
are generally maintained at the underwriting insurance company or the custodian designated by the
product’s provider.
Gateway Wealth tailors its advisory services to meet the needs of its individual clients and seeks to ensure,
on a continuous basis, that client portfolios are managed in a manner consistent with those needs and
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objectives. Gateway Wealth consults with clients on an initial and ongoing basis to assess their specific
risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of
their portfolios. Clients are advised to promptly notify Gateway Wealth if there are changes in their
financial situation or if they wish to place any limitations on the management of their portfolios. Clients
can impose reasonable restrictions or mandates on the management of their accounts if Gateway Wealth
determines, in its sole discretion, the conditions would not materially impact the performance of a
management strategy or prove overly burdensome to the Firm’s management efforts.
Retirement Plan Consulting Services
Gateway Wealth provides various consulting services to qualified employee benefit plans and their
fiduciaries. This suite of institutional services is designed to assist plan sponsors in structuring, managing
and optimizing their corporate retirement plans. Each engagement is individually negotiated and
customized, and includes any or all of the following services:
• Vendor Analysis
• Employee Enrollment
• Education Tracking
• IPS Support
• Investment Management
• Investment Consulting
• Performance Reports
• ERISA 404(c) Assistance
• Benchmarking Services
• Ongoing Investment Assistance
As disclosed in the Advisory Agreement, certain of the foregoing services are provided by Gateway Wealth
as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In
accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of
Gateway Wealth’s fiduciary status, the specific services to be rendered and all direct and indirect
compensation the Firm reasonably expects under the engagement. The Firm can provide investment
advisory services on behalf of the Plan and Plan Sponsor, which may be in either a 3(21) or 3(38) context
depending on whether or not the Furn is also providing discretionary investment management over the Plan
assets. For 3(38) services, the Firm shall have the discretion to select the investments for the Plan and/or
make investment decisions on behalf of Plan Participants.
Use of Independent Managers
As mentioned above, Gateway Wealth selects certain Independent Managers to actively manage a portion
of its clients’ assets. The specific terms and conditions under which a client engages an Independent
Manager are set forth in a separate written agreement with the designated Independent Manager. That
agreement can be between the Firm and the Independent Manager (often called a subadvisor) or the client
and the Independent Manager (sometimes called a separate account manager). In addition to this brochure,
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clients will typically also receive the written disclosure documents of the respective Independent Managers
engaged to manage their assets.
Gateway Wealth evaluates a variety of information about Independent Managers, which includes the
Independent Managers’ public disclosure documents, materials supplied by the Independent Managers
themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks
to assess the Independent Managers’ investment strategies, past performance and risk results in relation to
its clients’ individual portfolio allocations and risk exposure. Gateway Wealth also takes into consideration
each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing
and research capabilities, among other factors.
Gateway Wealth continues to provide services relative to the discretionary or non-discretionary selection
of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts
being managed by Independent Managers. Gateway Wealth seeks to ensure the Independent Managers’
strategies and target allocations remain aligned with its clients’ investment objectives and overall best
interests.
Gateway Wealth includes securities transaction fees together with its wealth management fees. Including
these fees into a single asset-based fee is considered a “Wrap Program.” The Firm sponsors the Gateway
Wealth Wrap Fee Program solely as a supplemental disclosure regarding the combination of fees.
Participants in the Wrap Program may pay a higher or lower aggregate fee than if investment management
and brokerage services are purchased separately. Additional information about the Wrap Program is
available in Gateway Wealth’s Wrap Brochure, which appears as Part 2A Appendix 1 of the Firm’s Form
ADV (the “Wrap Brochure”).