This Disclosure document is being offered to you by O’Domhnaill Enterprises, Inc., which
conducts its advisory business under the name, O’Donnell Wealth Management (“OWM”
or “Firm”). This Brochure discloses information about the services that we provide and the
way those services are made available to you, the client. O’Donnell Wealth Management
became a licensed investment advisor in September 2022. The firm is wholly owned by the
Stephen Patrick O’Donnell Sr. and Sue Jean O’Donnell Living Trust. Stephen P. O’Donnell
Sr. and his wife Sue J. O’Donnell serve as trustees for the Stephen Patrick O’Donnell Sr. and
Sue Jean O’Donnell Living Trust. Sue Jean and Stephen O’Donnell are affiliated, indirect
owners of OWM. Stephanie O’Donnell 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 OWM 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 cash, individual stocks, exchange traded
funds (“ETFs”), corporate bonds, municipal bonds, and U.S. Government Treasuries in
accordance with their stated investment objectives, and mutual funds. We generally invest
Client’s cash balances in money market funds. Ultimately, we try to achieve the highest
return on our client’s cash balances through relatively low-risk and conservative
investments. In most cases, at least a partial cash balance will be maintained in a money
market account so that our firm may debit advisory fees for our services related to this
service.
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.
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Financial planning is included within our investment management services for all accounts.
Financial planning services can include asset allocation, estate planning, insurance needs
analysis, business retirement planning, and retirement planning/analysis. OWM will
customize the deliverables based on each individual clients’ needs.
Clients should be aware that:
a) a conflict exists between the interests of the investment adviser and the interests
of the client,
b) the client is under no obligation to act upon the investment adviser's
recommendation, and
c) if the client elects to act on any of the recommendations, the client is under no
obligation to effect the transaction through the investment adviser OWM
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
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, such as variable life insurance, annuity contracts,
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.
WRAP FEE PROGRAM
Our Firm provides its advisory services as part of a wrap fee program. A wrap fee program
is an arrangement where brokerage commissions and transaction costs are absorbed by
the Firm. The fee covers transaction costs or commissions resulting from the management
of your accounts. Participants in the Program may pay a higher aggregate fee than if
brokerage services are purchased separately. Additional information about the Program is
available in OWM’s Wrap Brochure, which appears as Part 2A Appendix 1 of the Firm’s
Form ADV. Our “wrap” fee may be more or less than the fees and commissions charged by
other advisory firms, third-party managers, and brokerage firms if the services were
acquired separately.
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LPL FINANCIAL SPONSORED ADVISORY PROGRAMS
We may provide advisory services through certain 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 our Firm. 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.
LPL PROGRAM, SWM II ACCOUNT
All client accounts managed by our firm will utilize the LPL SWM II account program.
Although clients do not pay a transaction charge for transactions in a SWM II account,
clients should be aware that our Firm pays LPL transaction charges for those transactions.
Custodians
such as LPL are compensated for their services which include, but are not
limited to execution, custody and reporting. LPL can charge a fixed percentage fee for its
services based upon the dollar amount of the assets placed in its custody and/or on their
platform (for example: if LPL was to charge an annual percentage of the market value of
the client assets in its custody, the fee would include the execution of all account
transactions). This is referred to as an “Asset-Based Fee.” In the alternative, rather than a
fixed percentage fee based upon the market value of the assets in its custody, LPL could
charge a separate fee for the execution of each transaction. This is referred to as a
“Transaction-Based Fee.” Under a Transaction Based fee, the amount of total fees charged
to the client account for trade execution will vary depending upon the number of
transactions that are placed for the account. Our Firm has entered into an Asset Based
Pricing (“ABP”) arrangement with LPL Financial, which covers all program transaction fees,
including ticket charges, commissions, and other charges for trading and custody. Because
LPL’s ABP fee is based on a percentage of the value of all program assets other than assets
invested or held in cash, money market funds, non transaction fee mutual funds, and
commission-free exchange traded funds (collectively the “Non-ABP Funds”), a conflict of
interest exists as our Firm has an economic incentive to allocate or reallocate program
clients assets into Non-ABP-Funds to reduce its overall costs under the ABP arrangement.
Because our Firm cannot predict the markets and the amount of trading that will occur in
a client account, our Firm generally favors Asset-Based pricing within its wrap program
offering because it will fix the amount of the fee paid in relation to trade execution,
regardless of the number of transactions that are placed for the account. Our
recommendation that a client enter into an Asset-Based pricing agreement with the
account broker-dealer/custodian would depend upon whether, based upon anticipated
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account size and activity, our Firm reasonably believes that the client would benefit from
the available pricing arrangement. However, account investment decisions are often more
heavily driven by security selection and anticipated market conditions, as opposed to the
amount of commission/transaction fees payable by clients to the account broker-
dealer/custodian. However, our Firm, on an annual basis, will conduct a sampling to
confirm its belief (given the inability to predict the markets and the corresponding amount
of trading that will occur) that Asset-Based pricing continues to be beneficial for its clients.
Clients may request at any time to switch between Asset-Based pricing and Transaction-
Based pricing arrangements, however, there can be no assurance that the volume of
transactions will be consistent from year-to-year given changes in market events and
security selection. Therefore, given the variances in trading volume and pricing
arrangements, any decision by clients to switch between Asset-Based or Transaction-Based
pricing could prove to be economically disadvantageous. Our annual investment advisory
fee shall be prorated and paid quarterly, in advance, based upon the average daily market
value of the client’s account.
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
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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.
ASSETS
As of December 31, 2022, our Firm has $55,201,580 discretionary assets under
management, and $0 non-discretionary assets under management.