A. DESCRIPTION OF THE ADVISORY FIRM.
Rockport Wealth, LLC, doing business as “Rockport Wealth Advisors” and “J. Arnold Wealth
Management” (hereinafter referred to as the “Advisor”) was formed in May 2018. The
Advisor is an Ohio limited liability company headquartered in Fairview Park, Ohio. The
principal owners are ARS Capital Inc. and JJK Financial Inc. Adam R Stalnaker is the owner
of ARS Capital Inc and Joseph John Kovach is the owner of JJK Financial Inc. C. David
Dickinson is the Advisor’s Chief Compliance Officer.
The Advisor is a registered investment adviser and as such is a fiduciary to each of its clients.
The Advisor is registered with and regulated by the United States Securities and Exchange
Commission (SEC). The Advisor is not a broker/dealer or insurance agency and therefore
does not accept commissions. The Advisor is only compensated in the form of advisory fees
paid by its clients.
“Investment Advisor Representatives” are those persons who are appropriately registered and
authorized to deliver investment advisory services on behalf of the Advisor. Three of the
Advisor’s investment adviser representatives, Adam Stalnaker, Joseph Kovach, and Michael
Curley are separately engaged as registered as registered representatives of an unaffiliated
broker/dealer and are independently licensed insurance agents and as such can accept
commissions for securities and insurance representatives in these capacities. These activities
are discussed at Item 10.C of this Brochure.
B. TYPES OF ADVISORY SERVICES
The Advisor offers
fee-based Financial Planning, Investment Management, and
Consultation Services. The Advisor offers an initial, complimentary consultation to discuss
the advisory services available; to give a prospective client an opportunity to review services
desired; and to determine the possibility of a potential Client-Advisor relationship.
Stand-Alone Financial Planning Services
The Advisor’s’ Financial Planning Services may be comprehensive in nature or can be
tailored to address one or more components of financial planning. The services requested
may include short-term and/or long-term goal planning as directed by the client. Financial
Planning Services are available on an hourly basis, where services terminate at the
conclusion of services, or the Advisor can be engaged to provide ongoing services. The
services to be provided and the Advisor’s fee(s) are agreed upon at the time of engagement
and may include (as requested):
1. Initial Consultation (Free)
a. Assess current financial situation and discuss the planning process and the
Advisor's services.
2. Detailed meeting to review the client’s financial situation in depth in an effort to
determine our client’s objectives, goals, and concerns.
3. Prepare and deliver recommendations
a. Delivery of a financial plan including current net worth (balance sheet),
documented goals, action items and more.
b. Recommendations
c. Client walkthrough of plan and any questions
Included in the ongoing planning services:
1. Quarterly check-ins with our client to assess the financial plan, implementation of
the plan, limitations, adjustments needed, and assess new variables in a client’s
financial picture.
2. Year-end review and discussion pertaining to the plan and identify necessary
updates based on input from our client,
3. A new/updated financial plan annually.
Financial Planning Services can include the following topics (as agreed at engagement):
1. Income/Spending/Budgeting Analysis
2. Savings
3. Debt Strategies
4. Credit Card Reward Analysis
5. Tax Planning
6. Estate Planning
7. Retirement Planning
8. Education Planning
9. Employee Benefits Planning
10. Insurance Planning
11. Charitable Gift Planning
When financial planning services or information are limited, clients must understand that
comprehensive planning needs and or objectives may not be fully considered due to the
client’s option to receive limited services, the lack of information received, and/or client
disclosure.
When providing a review or advice on investments within retirement plans, the advice and any
recommendations are limited to plan offerings and the service provider(s) selected by the plan
providers.
Implementation of any advice or recommendations pertaining to securities or non-securities
matters, in whole or in part, is entirely at the client’s discretion via the service provider(s) of
the client’s choice.
Clients requiring assistance on issues relating to matters outside of financial and investment
advisory topics should consult their personal tax adviser, legal counsel, or other professionals
for expert opinions.
Financial Planning Services will not include any portfolio monitoring, investment reviews, or
investment management. investment management services may be available via a new client
agreement.
The Advisor offers a separate financial planning program for Army Rangers, other
military members, and veterans. Services include:
• An all-in-one comprehensive financial planning solution to support every stage of life.
• A customized “Financial Navigation Map” designed to help our client accomplish their
most important financial goals.
• Personal collaboration with an investment adviser representative with many years of
experience in investment and financial planning.
• State of the art mobile technology, allowing clients to view their plan on any device at
any time of day or night.
• Ongoing education to keep clients abreast of the most important financial issues they
may face.
Investment Management Services
The Advisor’s investment management services are ongoing in nature, focus solely on
portfolio management, and include financial planning services. This service does not include
consultation services outside the scope of the managed investments. Investment
Management Services are ongoing until terminated in writing by either party. These services
are normally provided within the Rockport Wrap Fee Program, (as discussed in Appendix 1 of
this Brochure), which provides for portfolio management fees as well as commissions, trade
execution costs, custody, and other standard brokerage services within a single, bundled fee.
Clients are welcome to opt out of the wrap fee and in such cases, their accounts are charged
normal commission and trade execution costs (in addition to the Advisor’s management fees).
Please be certain to read this Brochure as it discusses the Program as well as conflict of
interest information and other important considerations.
Investment Management Services begin only after the Client and Advisor formalize the
relationship with a properly executed client agreement. After the formal engagement and
depending upon the scope of the engagement, the Advisor and client will share in a data
gathering and discovery process in an effort to determine the client’s stated needs, goals,
intentions, time horizons, risk tolerance and investment objectives, based upon information
provided by the client and the nature of services requested. The Advisor and its client will
normally complete a risk assessment, investment policy statement (“IPS”) or similar
document, depending upon the scope of services to be provided.
After an analysis and data-gathering process and depending upon the nature of services
requested, The Advisor may prepare reviews, analysis, asset allocation recommendations,
and may recommend specific investments. The Advisor utilizes the information provided by
the client to prepare portfolio recommendations or adjustments in an existing portfolio. The
Advisor can tailor services as desired by the client, however where Investment Management
Services or information are limited, clients must understand that comprehensive investment
needs and or objectives may not be fully considered due to the client’s option not to receive
limited services, the lack of information received, and/or client disclosure.
The Advisor’s financial planning services include all of the services outlined in the stand-alone
service described above
with the following exceptions: estate planning, charitable gift
planning, income-spending, and budgeting analysis, and credit card reward analysis. All
financial planning services are client-initiated and are not transferrable.
Recommendations may include planning for long-range goals (i.e., retirement planning or
college funding) or other segments of an investment plan that may be desired. Recommended
investments will normally include (as appropriate for each client’s stated situation): exchange
traded index funds, mutual funds, other similar equity related index funds, stocks, bonds, real
estate investment trusts, master limited partnerships, money market funds, U.S. treasury
funds, cash sweep accounts, and other liquid cash and cash-like vehicles.
Wrap Fee Program Disclosures
• The benefits under a wrap fee program depend, in part, upon the size of the account, the
costs associated with managing the account, and the frequency or type of securities
transactions executed in the account. For example, a wrap fee program may not be
suitable for all accounts, including but not limited to accounts holding primarily, and for
any substantial period of time, cash or cash equivalent investments, fixed income
securities or no-transaction-fee mutual funds, or any other type of security that can be
traded without commissions or other transaction fees.
• In order to evaluate whether a wrap [or bundled] fee arrangement is appropriate for you,
you should compare the agreed-upon Wrap Program Fee and any other costs associated
with participating in our Wrap Fee Program with the amounts that would be charged by
other advisers, broker-dealers, and custodians, for advisory fees, brokerage and
execution costs, and custodial services comparable to those provided under the Wrap
Fee Program.
Relative Cost of Wrap Fee Program
A wrap fee is not based directly on the number of transactions in your account. Various
factors influence the relative cost of the Program to clients, including the cost of our
investment advice, custody, and brokerage services if you purchased them separately, the
types of investments held in your account, and the frequency, type and size of trades in your
account. The program could cost you more or less than purchasing our investment advice and
custody/brokerage services separately.
Conflict of Interest
When managing a client's account on a wrap fee basis, we receive as compensation for our
investment advisory services, the balance of the total wrap [or program] fee you pay after
custodial, trading, and other management costs (including execution and transaction fees)
have been deducted.
The Advisor does not charge clients higher advisory fees based on their trading activity, but
you should be aware that we have an incentive to limit our trading in your account(s) because
we are charged for executed trades.
Schwab has eliminated commissions [or transaction fees] for online trades of U.S. equities,
ETFs and options (subject to $0.65 per contract fee). This means that, in most cases, when
we buy and sell these types of securities, we will not have to pay any commissions to
Schwab. We encourage you to review Schwab’s pricing to compare the total costs of entering
into a wrap fee arrangement versus a non-wrap fee arrangement. If you choose to enter into
a wrap fee arrangement, your total cost to invest could exceed the cost of paying for
brokerage and advisory services separately. To see what you would pay for transactions in a
non-wrap account please refer to Schwab’s most recent pricing schedules available at
schwab.com/aspricingguide.
Betterment Services
In addition to its in-house investment management services, the Advisor has entered into an
agreement with Betterment, LLC (“Betterment”) to utilize among other things, Betterment’s
software, advice, and digital services on a sub-advisory basis. This means the Advisor
maintains its role as your primary investment adviser while utilizing the investment platform
available through Betterment. In order to utilize this program, clients will sign a client
agreement with Betterment. Betterment’s services are not included in the Advisor’s wrap fee
program.
Betterment’s program will recommend an investment plan via the digital interface that is
based on Betterment’s investment methodology regarding asset allocation strategies, ongoing
portfolio management, and certain information and preferences provided by the Advisor
and/or our client
information (via the IPS). The Advisor and our client may adjust the IPS via
the available options in the interface in order to provide further input for Betterment’s
discretionary investment management. The IPS memorializes the investment goals and
strategic management policies governing our client’s account.
Betterment may also make available certain model investment portfolios developed by third-
party provides (each, a “Model Portfolio Provider”) with products and/or allocations (a “Model
Portfolio”) that differ from the products and/or allocations Betterment has selected based on
Betterment’s investment methodology. These investment opportunities are outside the realm
of Betterment’s IPS, and management and certain features of Betterment’s digital interface
may not work in conjunction with a given model portfolio. In such cases, The Advisor shall be
responsible for managing the assets in a selected model portfolio.
The ongoing Investment Management Services provided are based upon the client’s stated
individual needs and objectives. In each case, the stated individual needs, goals, and desires
of clients are taken into consideration. Clients utilizing the Betterment program will grant
Betterment limited discretionary authority to implement securities transactions via the
Betterment service agreement. The Advisor may also maintain limited discretion (with the
client’s authorization in the Advisor’s client agreement) in order to assist clients with the
implementation of the investment recommendations and portfolio changes. Within the
Betterment program, the Advisor is not be permitted to make withdrawals or deposits of funds,
establish any sources for funding an account or destinations for withdrawals from an account,
and will not have the authority to establish new Betterment accounts on a client’s behalf.
Throughout its engagement, the Advisor will remain available for ongoing consultation,
advice, and recommendations. The Advisor will provide ongoing monitoring of the portfolio in
accordance with the directives provided. The underlying portfolio assets will be reviewed
internally on a frequent basis (generally daily), the client’s portfolio will be internally reviewed
no less than quarterly, but reviews may occur more frequently, depending upon the types of
investments, market conditions, when the client reports (actual or potential) changes in their
financial condition, at the discretion of the Advisor, and in conjunction with significant deposits
or withdrawals. The review process is discussed at Item 13 of this Brochure.
Clients engaging in investment advisory services must play an active role. The Advisor
requires its client to participate in the formation of the investment plan, the development of
investment advice and recommendations and the ongoing services provided. Clients may call
the office during regular business hours to discuss their portfolio or ask questions, but the
Advisor recommends that clients initiate a meeting with the Advisor no less than annually.
However, clients are obligated to immediately inform the Advisor of any changes in their
financial situation to provide the Advisor with the opportunity to review the new data to ensure
it the portfolio continues to be structured to help meet the client’s stated needs and objectives.
The Advisor is a fiduciary to its clients. As such, the Advisor is responsible for gathering an
appropriate amount of information pertaining to its clients’ financial situation, investment
objectives, and any reasonable restrictions imposed (as well as changes thereto) When a
client is utilizing our services with Betterment’s management offerings, the Advisor is
responsible for ensuing client data (and any material changes in data) is promptly provided to
Betterment. The Advisor is also responsible for monitoring the client’s account(s) on an
ongoing basis. The Advisor will also help to ensure that its clients’ personal data is accurate
and current in- house and in Betterment’s digital records. Betterment is solely responsible for
investment management, best execution, portfolio reporting, fee calculation and withdrawals,
and other services it agrees to provide within its respective program. Betterment’s services
are independent of any other services the Advisor may agree to provide to its client.
Consultation Services
The Advisor offers hourly or project-based consultation services. Services can focus on topics
of interest to the client such as certain components of financial planning, business planning,
Qualified Opportunity Zone investments, or Delaware Statutory Trusts. The Advisor may also
agree to provide consultations relating to non-managed investments (“assets under
advisement”) and in these cases, will not provide continuous monitoring nor maintain
discretionary authority, thus clients make the ultimate decisions regarding these holdings.
Specific consultation services and fees will be agreed upon at the time of engagement.
Consultation services terminate on delivery unless otherwise agreed to in the Client
Agreement.
3(21) Retirement Plan Services
The Advisor may act as a co-fiduciary 3(21) adviser to retirement plan sponsors. In our role as
a 3(21) adviser, we typically provide advice to the plan sponsor, who is free to accept or reject
those recommendations and who must then execute the decisions for the plan. Services are
available through a negotiated fee as part of a written Agreement with the plan sponsor.
C. CLIENT TAILORED SERVICES AND CLIENT IMPOSED RESTRICTIONS
The Advisor focuses on providing individualized services. The Advisor can tailor services to
focus only on certain portfolio components, depending upon the client’s wishes and/or the
nature of the engagement. However, where client services or information are limited, clients
must understand that comprehensive investment needs and objectives may not be fully
considered due to the client’s option to receive limited services, the lack of information
received, and/or client disclosure. The Advisor and the client will share in a data gathering
and discovery process in an effort to determine the client’s stated needs, goals, intentions,
time horizons, risk tolerance and investment objectives, based upon information provided by
the client and the nature of services requested. The client and Advisor may complete a risk
assessment, investment policy statement (“IPS”) or similar documentation, depending upon
the nature of services to be provided.
Clients may impose reasonable restrictions pertaining to certain securities or types of
securities in accordance with their values or beliefs and such instructions will be agreed to in
writing between the client and the Advisor.
Important Note About Retirement Plan Rollovers
As noted throughout this Brochure, the Advisor is a fiduciary to each of its clients. This
includes when we provide investment advice to you regarding your retirement plan account or
individual retirement account, 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. The way we make money creates some conflicts with your
interests, so we operate under a special rule that requires us to act in your best interest and
not put our interests ahead of yours. At the time of a rollover recommendation, we will provide
you with a written disclosure discussing the reasons the rollover is in your best interests. Also,
under this special rule’s provisions, we must:
* Meet a professional standard of care when making investment recommendations (give
prudent advice).
* Never put our financial interests ahead of yours when making recommendations (give
loyal advice).
* Avoid misleading statements about conflicts of interest, fees, and investments
* Follow policies and procedures designed to ensure that we give advice that is in your
best interest.
* Charge no more than is reasonable for our services; and
* Give you basic information about conflicts of interest.
Self-Directed Assets
Clients may desire to place or keep certain assets within client’s account(s) that have been /
are selected by the client and are not the subject of investment advice by the Advisor. These
are known as “self-directed” assets. The Advisor will not manage this facet of the client’s
portfolio. The Advisor will therefore have no responsibility to provide consultation, suitability
reviews, due diligence research or any other services relating to the self-directed assets in
client’s account(s) and will therefore have no liability for any loss relating to self-directed
assets. Should the Advisor ever agree to assist a client with a transaction involving a self-
directed asset, it will do so only as a value-added service.
D. WRAP FEE PROGRAM
The Advisor is the portfolio manager and sponsor of the Rockport Wealth Wrap Fee Program.
(the “Program”). The Program combines portfolio management and trade execution costs
within a single investment management fee. Rockport Wealth, as the Program’s manager is
responsible for research, security selection, and implementation of transaction orders in the
Client's account.
Schwab’s Brokerage Services
In addition to the advisory services, the wrap fee program includes certain brokerage services
of Charles Schwab & Co., Inc. (“Schwab”) a broker-dealer registered with the Securities and
Exchange Commission and a member of FINRA and SIPC. We are independently owned
and operated and not affiliated with Schwab. Schwab will act solely as a broker-dealer and
not as an investment advisor to you. It will have no discretion over your account and will act
solely on instructions it receives from us [or you]. Schwab has no responsibility for our
services and undertakes no duty to you to monitor our management of your account or other
services we provide to you. Schwab will hold your assets in a brokerage account and buy
and sell securities and execute other transactions when we [or you] instruct them to. The
Advisor and the Program will not open the account for you.
Fees We Pay Schwab
In addition to compensating the Advisor for advisory services, the wrap fee clients pay the
Advisor allows us to pay for brokerage services provided by Schwab.
The Program fee does not include mark-ups. and mark-downs, dealer spreads or other costs
associated with the purchase or sale of securities, interest, taxes, or other costs, such as
charges for transactions not executed through Charles Schwab & Co., Inc., costs associated
with exchanging currencies, wire transfer fees, or other fees required by law or imposed by
third parties. The investor’s account will be responsible for these additional fees and
expenses.
As a fiduciary, an investment adviser must have a reasonable basis to believe that a wrap fee
program is in the best interest of participating clients since high management fees normally
apply to such programs. Further, depending on the level of trading required for the Client’s
account[s] in a particular year, the client may pay total fees that are more or less than if the
client paid its own transaction fees. However, the Advisor’s new 2024 investment
management fee schedule is uniform for all clients engaging the Advisor’s investment
management services on or after January 1, 2024, and participation in the Program is
optional.
Pre-existing clients who engaged the Advisor’s investment management services prior to
January 1, 2024, were grandfathered under the Advisor’s prior fee schedule, as disclosed at
Item 5 of this Brochure. For these clients, participation in the Program is optional. The
Program may not be recommended / appropriate for pre-existing clients, due to low or non-
existent transaction costs associated with their existing portfolio. Further, recommending the
Program may potentially increase the Adviser’s compensation from this set of clients. If a pre-
existing client wishes to participate in the Program due to changes in their investment profile
and the transition is deemed appropriate by the Advisor, the Advisor and the client will enter
into a new or amended investment management agreement and the January 2024 fee
schedule would apply.
Detailed information about The Rockport Wealth Wrap Fee Program is provided in the Form
ADV Part 2A, Appendix 1 (Wrap Fee Program Brochure) which is attached to this Form ADV
Part 2A Disclosure Brochure.
E. AMOUNTS OF ASSETS UNDER MANAGEMENT
The Advisor managed $143,699,000 on a discretionary basis as of December 31, 2023. There
are no non-discretionary assets to report.