Family Wealth Planning Partners, LLC (“FWPP” or “Firm”) is an Investment Adviser registered with the Securities and
Exchange Commission (“SEC”). Our firm is a limited liability company formed in the State of Kentucky. FWPP has
been in business as an investment adviser since 2022 and is owned by members who have been providing investment
advice for many years in their capacity as professional investment advisors with other firms. The Firm is owned by the
following managing members:
• Brian W. Ramsey 25% Ownership
• Eric T. Douglas 25% Ownership
• Christopher A. Vaughn 25% Ownership
• Aaron M. McAndrew 25% Ownership
FWPP provides personalized investment advisory services to you. These services include investment
advice/management, financial planning, consulting services and referrals to third-party asset managers. FWPP’s
recommendations and services are provided based on your specific needs. Investment strategies and philosophies differ
among IARs who are responsible for determining and implementing their own investment advice under the supervisory
controls of FWPP.
You and your IAR will discuss your financial goals, investment objectives, investment experience and time horizon,
among other factors specific to your financial situation. You are given the ability to impose written restrictions on your
accounts, including specific investment selections and sectors. When you impose these restrictions, FWPP will make
best efforts to honor those restrictions. For this reason, it is important you understand that FWPP performs advisory
and/or brokerage services including investment reporting for various clients, and that we give advice or take actions for
clients other than you that differ from the advice given to you.
FWPP has direct relationships with Qualified Custodians, consisting of Schwab, Pershing Advisory Services (“PAS”),
Fidelity Institutional Wealth Services (“FIWS”), and SEI, which provide brokerage execution through their own
broker/dealer(s).
Changes in Your Finances and Investment Objectives
It is your responsibility to promptly notify us if there is a change in your financial situation or investment objectives.
You are not obligated to use FWPP for securities transactions or individual insurance provider products.
Other
Additional descriptive information is provided under Fees and Compensation so that you and prospective clients can
review the services and description of fees more thoroughly. Descriptions for some of our investment advisory and
management services is contained in the following pages and section of this document, as well as in the respective
program’s Wrap Fee Disclosure Brochure of its 3rd Party Asset Managers/TPAMs.
FINANCIAL PLANNING SERVICES (PLANS AND CONSULTATIONS)
FWPP IARs will provide financial planning services that focus on your specific needs and concerns. These services can
be (i) comprehensive in nature and focus on your overall financial situation, risk, goals, and objectives, or (ii) modular in
nature, focusing on specific areas of concern that you have such as asset allocation, college planning, estate planning,
etc.
Financial Planning consists of:
• Helping you determine and set your long-term financial goals, through investments, tax planning, asset
allocation, risk management, retirement planning, estate planning and other areas. The role of a financial planner
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is to identify your investment and planning objectives and to assess and/or provide effective/optimal strategies
and recommendations to achieve your objectives.
• In this sense, we offer:
o Comprehensive and segmented (modularized) financial plans and also through
specific recommendations. Comprehensive planning services focus on a client’s overall financial
situation;
o Modular planning services and consultations focus on specific areas of client concern,
like retirement planning or education planning; and
o Recommendations can be for asset allocation advice to specific accounts held away from an
IAR (e.g., 401(k).
Your IAR will collect a variety of information and documentation from you that is necessary to perform the requested
services. Your IAR will gather the information in order to review your current financial condition, to assist you in
determining your attitude toward risk, and to identify your financial goals, objectives and challenges. Financial data
that is gathered and reviewed include, but is not necessarily limited to, statements and account data from banks, broker-
dealers, and mutual funds, as well as tax returns and insurance policies.
Depending on the level and the scope of the financial planning engagement, your IAR will also review wills and trusts
for financial considerations (FWPP may not and does not provide legal services). Your IAR will rely on the information
provided by you. Therefore, it is important the information you provide is complete and accurate. FWPP is not
responsible for verifying the information you provide. In addition, if authorized by you, your IAR will gather
information or documentation from your other professionals and are expressly authorized to rely on that information
provided. We urge you to work closely with your attorney, accountant, or other professionals regarding the tax/financial
and legal aspects of your personal situation.
Your IAR will discuss his or her recommendations with you as well as steps to be taken in order to implement those
recommendations. It is your responsibility to notify your IAR if there are changes in your financial situation or
investment objectives. You should notify your IAR of changes so that they can work with you to determine if the
changes will affect the advice previously provided. Together, with your IAR, you can determine if you wish to engage
him or her to review, evaluate, and revise the previous recommendations provided.
Although financial planning services are provided with the intention that you will implement the recommendations, you
are not obligated to do so. You retain discretion over implementing decisions relating to financial planning services
and are free to accept or reject any recommendation from your IAR. You have the option to purchase investment
products that are recommended through other brokers or agents that are not affiliated with FWPP. To the extent you
would like your IAR to implement transactions on your behalf, you will need to enter into a separate investment
advisory/management contract for services involving discretionary or non-discretionary continuous and regular account
oversight and/or implementation services for an investment advisory fee (typically a % of assets in the account subject
to advice or “under management”).
The fees for these types of services are negotiated between you and your IAR and depend on the nature of the financial
planning services provided, as well as the time and the complexity of your circumstances and our services. All fees are
agreed upon prior to entering into the Financial Planning and Consultancy Agreement signed by you.
Fee arrangements are documented on the Financial Planning and Consultancy Agreement (see Item 5 – Fees below for
a specification of the ranges of fees.
These services do not involve actively managing your accounts. Depending on the specific planning service, if other
than comprehensive financial planning, such plans may not consider all important financial issues of the client; clients
and FP will agree of the scope of each financial plan.
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INVESTMENT MANAGEMENT
Advisor Managed
In an Advisor Managed Account, sometimes known as "Rep as Portfolio Manager" ("RPM"), FWPP will be responsible
for managing your account consistent with your defined objectives and risk tolerance and will assist you to develop a
personalized asset allocation program and customized portfolio. FWPP does not offer proprietary products. FWPP’s
investment recommendations are not limited to any specific types of securities. Your portfolio holdings can include,
but are not limited to, securities listed on the stock market exchanges; corporate and municipal bonds; Mutual Funds;
Unit Investment Trusts (“UITs”); Exchange Traded Funds (“ETFs”); Variable Annuities (“VAs”) and/or the sub-
accounts within a VA; Variable Universal Life insurance (“VUL”); alternative products, including project-specified
private placements, Real Estate Investment Trusts ("REITs”), Direct Participation Programs (“DPPs”) or Business
Development Companies (“BDCs”); equity options; warrants; United States government and government agency
securities; certificates of deposit and commercial paper. Depending upon the issuer and how it structures the product,
some investment products, (e.g., REITs, DPPs and BDCs) historically have been more often designed for the brokerage
versus investment advisory channel, although platform availability for these products is expanding. If the product was
structured and sold as a brokerage product, which means a commission was charged, it generally is not eligible to be
held in an Advisor Managed Account, unless it is excluded from billing.
In an Advisor Managed Account, FWPP will typically diversify your holdings across various asset classes unless your
objective is to invest in specific assets. The percentage weightings within the asset classes will be based on your risk
profile, investment objectives, individual preferences and availability. You will have the opportunity to meet with your
IAR to periodically review the assets in your Advisor Managed Account. We recommend you and your IAR meet on
a regular basis to review your financial situation, investment objectives and current holdings, and you should let your
IAR know about any changes in your circumstances in the meantime.
FWPP does not pool your assets with those of other customers. Portfolio Models are managed as separately managed
accounts (“SMAs”), and FWPP manages accounts individually, not as a pool of investor capital. FWPP provides
continuous and regular supervisory services over what are known as separately managed account. Among other things,
the advice and management of your account are tailored to your individual and specific needs and objectives. Also,
you retain the right to add or withdraw securities or cash, pledge securities, and vote securities. You will receive
periodic statements directly from the qualified custodian.
We offer both discretionary and non-discretionary portfolio management and advisory services. Thus, the underlying
accounts subject to ongoing account monitoring and supervisory services are handled on either a discretionary trading
basis or non-discretionary trading basis as agreed upon between you and your IAR. In order to have trading authorization
on your account, you must grant your IAR limited power of attorney over your account. This can be done through the
standard FWPP investment advisory agreement with specific language that authorizes your IAR to place orders for
your account without contacting you in advance. Such limited trading authority places more power and trust with your
IAR, and if you proceed in that way, you should be comfortable with the investment management approach and plan
and understand that the implementation of that approach/plan is within the control of your IAR.
If you do not want your IAR to have discretion, your account will be non-discretionary and your IAR will need to speak
with you directly to obtain authorization before placing trades. You should understand that any delay in obtaining your
authorization to execute a recommendation could result in less favorable transaction terms, including a higher security
transaction execution price depending on prevailing market conditions.
Some IARs will utilize an automated investment program through which you are invested in a range of investment
strategies constructed by your IAR. These types of programs assist your IAR in determining your investment objectives
and risk tolerances in order to select an appropriate investment strategy and portfolio. Additionally, these programs
assist your IAR managing portfolio on an ongoing basis through automatic rebalancing and tax loss harvesting (if
applicable). However, this could lead to less frequent contact with your IAR.
To cover transaction costs occurring within accounts, each custodian has asset-based pricing as an alternative, and some
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of them have both asset-based pricing and transaction-based pricing. In situations where the custodian offers asset-
based pricing, then the IAR has the ability to select asset-based pricing in order to pay for the services provided by the
custodian, including account and transaction fees. The latter is typically called a “Wrap Account”. See section titled;
“Wrap Fee Program versus Portfolio Management Program for additional information and disclosures.
As portfolio manager of your account(s), the IAR decides whether the client account should be priced whereby ticket
fees and other transaction costs are borne by the Client or wrapped into one fee, inclusive of FWPP’s fee, which would
result in the IAR absorbing any transaction costs incurred. In the case where custodians such as Schwab, , Fidelity,
Pershing or SEI utilizes an asset-based pricing model, it may cover only a portion of their securities (e.g., asset-based
pricing for stocks and ETFs), but may retain transaction-based pricing for mutual funds, unless the mutual funds are
structured as NTFs (non-transaction costs mutual funds).
FWPP ASSET MANAGEMENT
FWPP offers a variety of model portfolios from which investors choose. The model portfolios are created and managed
on a discretionary basis by FWPP’s Investment Management team. In instances where your IAR uses a model(s), your
IAR will help you determine which FWPP models are best suited for you based on your risk profile, investment
objectives, and preferences, leaving the actual trading decisions to FWPP’s Investment Management team. FWPP offers
a variety of model portfolios with varying investment product types, including mutual fund and ETF portfolios, equity
portfolios and fixed income portfolios.
WRAP FEE PROGRAM VERSUS PORTFOLIO MANAGEMENT PROGRAM
IARs provide asset management services through both Wrap Fee programs and other management programs. Under
FWPP’s traditional management program, there are two separate types of fees. FWPP charges an investment advisory
fee for advisory services, and other fees are charged by activity (e.g., a ticket fee), usage, service for each transaction
(e.g., buy/sell/exchange) or usage or service by FWPP for accounts held at the qualified custodian. Under a Wrap Fee
program, advisory services and transaction services are provided for one fee to the client. From a management
perspective, there is not a fundamental difference in the way an FWPP IAR manages Wrap Fee accounts versus
traditional management accounts. However, in a Wrap Program, there is an incentive to trade less. Otherwise, the
significant difference is the way in which transaction services are paid. For Wrap Fee program, there is a separate
disclosure document that should be provided to you, which is referred to as the Wrap Fee Brochure, and the purpose of
the brochure is, among other things, to alert you about the features of the service, conflicts-of-interest and the fact that
because the Wrap Fee “bundles” all services and transactions into one cost, it could quite possibly result in higher
overall fees assuming a certain level of transactions and other services that you may want or experience in your account.
The maximum fee for Wrap accounts is 1.25%, which coincides with FWPP’s maximum fee, but notably, a non-Wrap
fee arrangement is more likely to be less than 1.25%, on average, because transaction costs and other service costs are
paid in addition to the investment advisory fee. You should discuss with your IAR whether a Wrap Fee program would
be better or worse for you considering the level of transactions and other service needs you have.
USE OF THIRD-PARTY ASSET MANAGERS
Some IARs will utilize the services of TPAMs to assist in managing your investments. The nature of the advisory and
management services are determined between the client and the 3rd party investment adviser, and their services should
be explained in their Form ADV 2A, and their Client Relationship Summary (“CRS”).
Your IAR can assist you with selecting and monitoring unaffiliated TPAMs offering asset management and other
investment advisory services. Such arrangements with TPAMs are structured as either solicitor arrangements, whereby
FWPP would solicit clients to the TPAMs in exchange for a fee, without any authority to provide ongoing advice or
account management, or as co-advisory arrangements, wherein both firms would have authority to provide ongoing
advice and/or account management services in exchange for a fee split as negotiated by the respective firms. In situations
where FWPP/IAR are serving as co-advisors, your IAR is responsible for the initial and ongoing review and is also
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responsible for maintaining your current information. Generally, such a referral to such a third-party must based upon
a fiduciary/”Best Interest” determination, predicated upon reasonable due diligence, which supports the idea that the use
of a third party would be in the best interest of you, the client. That being said, if FWPP is not serving as a co-advisor,
and is merely a solicitor, its scope of services and responsibility is more limited. In co-advisory arrangements, your
IAR should assist you with identifying your risk tolerance, investment objectives, implementation strategies, etc. He or
she will then recommend asset managers geared toward your stated investment objectives and risk tolerance. You will
enter into an agreement directly with the TPAM.
Your IAR is available to answer questions you may have regarding your account and act as the communication conduit
between you and the TPAM. Your IAR will be available to review the account(s) with you to determine if the TPAM
is continuing to meet your investment objectives. Generally, TPAMs will exercise discretionary authority to determine
the securities to be purchased and sold for you. In these situations, FWPP has discretionary trading authority with
respect to your account with the TPAMs(s) and are not responsible for investment selection or trade implementation in
your accounts.
PENSION PLAN ADVISORY AND CONSULTING SERVICES
FWPP provides consulting and advisory services to both ERISA and Non-ERISA employer- sponsored retirement
plans, including, but not limited to, 401(k), 457(b), 457(f), 403(b), Simple IRA, SEP IRA, nonqualified, deferred
compensation, pension and profit-sharing plans (collectively, “Plans” or individually, “Plan”) on both a one-time and/or
ongoing basis.
FWPP offers a suite of detailed engagement agreements which are customized for each client relationship and executed
by the Plan’s designated fiduciary upon conclusion of a careful review, which, at times, includes the client’s
independent legal counsel. Through its agreements, FWPP is engaged to provide investment advisory services on a
“non- discretionary” basis (serving as a “fiduciary” as defined by §3(21)(A)(ii) of the Employee Retirement Income
Security Act of 1974 (“ERISA”)). Certain other additional services available from FWPP would be considered non-
fiduciary by definition and function and are explicitly detailed within the Plan’s executed agreement.
For non-discretionary services, FWPP will act in a solely advisory capacity and will not have or exercise any
discretionary authority or control relative to the management or investment of the assets of the respective Plan.
For discretionary services, FWPP will be designated as the Investment Manager to the Plan and assume responsibility
for the investment selection and asset management for the Plan’s master menu made available to the Plan participants
from which to choose. In all cases, FWPP will not serve as the “named fiduciary” of the Plan.
Our agreements offer our clients the opportunity to select one or more of the following services in various engagement
categories:
ERISA 3(21) Investment Adviser Fiduciary Services (Non-Discretionary):
• Development of an Investment Policy Statement (“IPS”);
• Recommendations for the selection and monitoring of the Plan’s Designated Investment Alternatives
(“DIAs”) that meet the standards set forth within the IPS or as established by other stated goals,
objectives and restrictions communicated to FWPP by the Plan’s fiduciaries that also satisfy ERISA’s
§404(c) requirement that participant-directed retirement plans offer a “broad range” of investment
options;
• Recommendations for selecting and monitoring the Plan’s Qualified Default Investment Alternatives
(“QDIAs”);
• Recommendations for and monitoring of Third-Party Investment Managers, if utilized;
• Investment performance measurement, analysis and reporting;
• Attendance and active participation at Plan Oversight Committee meetings; and
• Individualized investment advice options for Plan Participants;
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ERISA Non-Fiduciary Services:
• Consulting services to assist the Plan Sponsor with plan design (Settlor) decisions;
• Provide the Plan’s Oversight Committee with fiduciary education and “best practices” awareness as
well as advice on the development of a Committee Oversight Charter, if so desired;
• Assistance with selecting and monitoring non-fiduciary vendors (e.g., TPA, Recordkeeper, etc.); and
• Delivering or coordinating individual and/or group investment and plan provision education,
enrollment support and general retirement planning guidance.
From time to time with the Plan Sponsor’s permission, IARs can make the Plan or Plan participants aware of
and offer services to them available from the IAR that the participant or Plan itself would contract for, separate
and apart, from the retirement plan advisory and consulting services described above specific to Plan assets. In
offering or delivering any such additional services, IAR is not providing the services while acting as a fiduciary
under ERISA with respect to such offering of services applicability to plan assets.
FWPP intends to fully adhere to the guidelines and mandates set forth within the DOL’s Prohibited Transaction
Exemption (PTE) 2020-02 which became effective February 16th, 2020 specific to rollovers from qualified
plans. As such, FWPP will require any participant considering a rollover to complete FWPP’s Employer Plan
Distribution disclosure and acknowledgment document, which details the rationale for the rollover
recommendation and discloses important information and considerations in connection with the rollover
decision that are acceptable to the client. FWPP has a form designed to gather data and serve as a basis to
evaluate the appropriateness of any such rollover recommendations.
RETIREMENT PLAN INVESTMENTS DISCLOSURE AND FEES
Fees for retirement plan services are negotiated prior to the signing of the appropriate FWPP Retirement Plan
Agreement and includes the negotiated fee to be compliant with ERISA §408(b)(2) mandates. This disclosure
is required of all vendors providing services to a retirement plan or its participants and must disclose all direct
and indirect compensation they will receive in exchange for the services they provide to a retirement plan.
FWPP’s agreements with its Plan Sponsor clients disclose the services it will provide and the fee it will charge
for those services and serves as its required ERISA §408(b)(2) disclosure. See Item 5 below for a description
of fees such services, but they generally do not exceed 2% of the Plan assets when AUM-based, or $250,000
for the large- “mega” Plan market and $50,000 for the micro-small Plan market (e.g., <$10 million) when flat
fee-based.
TAX EXEMPT ORGANIZATIONS
Some IARs of FWPP work with tax exempt programs and provides services to employees of public-school
systems and tax-exempt organizations that qualify under Section 501(c)(3) of the Internal Revenue Code.
Services are usually provided through the organization’s retirement accounts held in an Optional Retirement
Plan (“ORP”), also known as a 401(a), 403(b) and 457 accounts.
IRA ROLLOVER/TRANSFER CONSIDERATIONS
As part of our investment advisory services, IARs can make recommendations to qualified plan participants
and IRA owners regarding the rollover or transfer of their employer sponsored retirement plan account or IRA
assets. In the case where an IAR recommends a retirement plan rollover or transfer into an FWPP advisory account
program, the IAR will earn a portion of the advisory fee. This presents a conflict of interest because IARs may
have an economic incentive to recommend a rollover of retirement plan assets into an FWPP advisory program
account.
Plan participants are under no obligation to rollover their retirement plan assets to an IRA with FWPP or a
401(k) advised by FWPP’s IAR and should carefully consider all relevant factors, such as penalty-free
withdrawals, whether loans are permitted, legal protections, required minimum distributions, fees and
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expenses, service levels, available investment options, employer stock considerations, Federal and State taxes
and other competitive alternatives.
In these rollover/transfer situations, FWPP intends to fully adhere to the guidelines and mandates set forth
within the DOL’s Prohibited Transaction Exemption (PTE) 2020-02 that became effective February 16th, 2021
specific to rollovers/transfers to/from qualified plans or between IRAs. We have instituted written policies,
procedures and documentation designed to achieve compliance with the impartial conduct standards, mitigate
conflicts of interest and does not create incentives that place our interests, or that of our IARs/RRs, ahead of
those of the qualified plan participant or IRA account holder involved.
By complying with impartial conduct standards, we will ensure:
• The advice to execute the rollover is in the best interest of the participant at the time it is provided;
• We will only receive reasonable compensation and
• No statements are made to the participant that are materially
misleading. We will provide certain disclosures in advance, including:
• An acknowledgment of our status as a fiduciary;
• A description or the services to be provided;
• A description of any material conflicts of interest and
• Documentation of the specific reason(s) for the rollover recommendation and why it is in the
best interest of the participant/IRA owner.
FWPP will also require any participant considering a rollover or transfer to complete FWPP’s Qualified
Plan/IRA Rollover/Transfer Recommendation and Acknowledgement Form, which details the rationale for the
rollover recommendation and discloses important information and considerations in connection with the
rollover decision that are deemed acceptable to the client as evidenced by their acknowledgement signature.
In the event a commissionable annuity product is included in the recommendation, we will also adhere to the
requirements of the DOL’s PTE 84-24 by incorporating and executing additional documentation in line with
this guidance, including another client acknowledgement signature.
ACCOUNT TRANSFERS FROM ANOTHER FIRM TO FWPP
When FWPP hires or associates with an IAR you are not obligated to transfer your other investments and assets to
FWPP to retain a relationship with your IAR. Any recommendation made by our IARs must be in your best interest,
and you should consider the relative fees, platform services, investment options, and tax effects. FWPP encourages
you to ask your IAR why any recommended account or investment transfer is in your best interest.
LIMITS ADVICE TO CERTAIN TYPES OF SERVICES AND LIMITED SCOPE OF OUR INVOLVEMENT AS A
FIRM
With some exceptions, FWPP IARs are available to offer advice on most types of investments owned by client and, at
the specific request of a client, will explore investment options not currently owned by a client. However, from the
perspective of not being registered to engage in certain business lines, IARs are not permitted to provide advice on futures
or commodity contracts. From a business policy perspective, FWPP also elects to refrain from knowingly accepting
investments in certain industries not covered by its Errors & Omissions insurance policy, including cryptocurrencies,
leveraged/inverse ETFs and marijuana-based business securities. If you happen to have such securities in your account,
you will be asked to either sell the positions or transfer them to another firm. We also require that TPAMs used by
IARs be approved by FWPP.
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Some IARs develop models or strategies that are generally applied across all clients while other IARs will develop
truly individualized portfolios for each client. You will not be necessarily treated the same as other clients, which in a
sense is a limitation of services, and could exist due to the way that IAR or FWPP manages accounts due to business
reasons.
In addition, many of our IARs also act as insurance agents independent from our firm. To the extent your IAR provides
fixed insurance products or services to you (other than fixed indexed annuities), he or she does so outside of FWPP’s
supervision, and if your IAR is involved in other business activities, such as accounting, legal, tax, and other non-
investment services, which are outside the scope of FWPP's services, FWPP is not responsible for such non- investment
services that may be offered by our IARs, although such activities are subject to preclearance procedures of FWPP and
some level of supervisory oversight. Some of our IARs are licensed as independent insurance agents through various
insurance companies; they solicit, offer and sell fixed and/or property and casualty insurance products where they are
duly registered to conduct business.
BUSINESS CONTINUITY PLAN
FWPP has established a Business Continuity Plan (“BCP”). The BCP describes how FWPP would respond to significant
business disruptions and provide you with alternative contact information and access in the event of a significant business
disruption. It is also available upon written request.
PRIVACY POLICY
FWPP has established a Privacy Policy, which essentially stipulates that FWPP will not share information with
unaffiliated 3rd parties not essential to service your investment account in the manner you elect. FWPP will not sell
you information do marketing organizations.
ASSETS UNDER MANAGEMENT
FWPP currently has no assets under management and is awaiting approval by the SEC for federal registration relying on Rule
203A-2(c), the exemption from the prohibition on registration available to an adviser that expects to be eligible for SEC registration
within 120 days.
Assets Under Management
Discretionary $ 161,524,337
Non-Discretionary $56,302,578
Total $217,826,915