This Disclosure document is being offered to you by Dodds Wealth, LLC (“Dodds Wealth”
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.
Dodds Wealth, LLC applied for SEC registration in October 2022. The principal owners are
Andrew Dodds, John Michael Dodds, Deanna Meyer, and Brennan Pate. John Michael
Dodds 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 Dodds Wealth execute an Investment Management Agreement
(“Agreement”).
INVESTMENT MANAGEMENT AND SUPERVISION SERVICES
We manage advisory accounts on a discretionary and non-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 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.
If a non-discretionary relationship is in place, calls will be placed presenting the
recommendation made and only upon your authorization will any action be taken on your
behalf. We do have limited authority to direct the Custodian to deduct our investment
advisory fees from accounts, but only with the appropriate written authorization from
clients.
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.
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, 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
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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
• 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.
In addition, our Firm offers an ongoing financial plan subscription service primarily for
those younger professionals in the wealth accumulation stage. These subscription services
allow our IARs to meet with clients on a quarterly basis to review and update planning
strategies that have been provided to them in their customized Financial Plans. During the
term of a subscription agreement, clients will receive a minimum of four total consultations
during each 12- month period of the term of their consulting subscription contract (which
is prorated for periods of less than 12 months) that will allow our Firm and its IARs to,
among other things: (i) gain additional understanding of the client’s financial
circumstances, objectives, and needs and, if necessary, obtain relevant documentation; (ii)
gain an understanding of the key financial matters the client would like to address during
the term of their financial planning subscription agreement; (iii) provide general
investment advice and guidance regarding the key financial matters the client would like
to address; and (iv) provide timely investment advice and guidance regarding current
matters impacting the client’s financial life.
Additionally, all financial planning subscription clients have reasonable access to their IAR
throughout the term of their financial planning subscription agreement that allows them
to seek additional timely investment advice and guidance from their IAR regarding
significant financial decisions, significant life events, financial concerns, and other
important matters impacting their financial life.
Financial planning subscription contracts do not require Dodds Wealth or your IAR to
provide any other oversight or ongoing asset management or portfolio management
services, including security or other investment product recommendations or selections,
with respect to your accounts with our Firm or other financial services firms or the
securities and other products you purchase and hold in any such accounts. If you would
like Dodds Wealth to provide you with account monitoring, account oversight, or ongoing
asset management or portfolio management services, you should speak with your IAR
regarding our Firm’s fee-based investment advisory programs and services.
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SUB-ADVISORY SERVICES
Our firm may determine that engaging the expertise of an independent sub-advisor is best
suited for your account. Our firm will have discretion to utilize independent third-party
investment adviser to aid in the implementation of investment strategies for your
portfolio. In certain circumstances, we may allocate a portion of a portfolio to an
independent third-party investment adviser (“Manager”) for separate account
management based upon your individual circumstances and objectives, including, but not
limited to, your account size and tax circumstances. Upon the recognition of such
situations, in coordination with you, we will hire a Manager for the management of those
assets. These advisers shall assist our Firm in managing the day‐to‐day investment
operations of the various allocations, shall determine the composition of the investments
comprising the allocation, shall determine what securities and other assets of the
allocation will be acquired, held, disposed of, or loaned in conformity with the written
investment objectives, policies and restrictions and other statements of each client
comprising the allocation, or as instructed by our Firm.
Managers selected for your investments need to meet several quantitative and qualitative
criteria established by us. Among the criteria that may be considered are the Manager’s
experience, assets under management, performance record, client retention, the level of
client services provided, investment style, buy and sell disciplines, capitalization level, and
the general investment process.
You are advised and should understand that:
● A Manager’s past performance is no guarantee of future results;
● There is a certain market and/or interest rate risk which may adversely
affect any Manager’s objectives and strategies, and could cause a loss in a
Client's account(s); and
● Client risk parameters or comparative index selections provided to our firm
are guidelines only and there is no guarantee that they will be met or not
be exceeded.
Managers may take discretionary authority to determine the securities to be purchased
and sold for the client. As stated in the Investment Management Agreement, our Firm and
its associated persons will have discretionary authority to hire and fire the Manager. Our
firm will work with the sub-advisor to communicate any trading restrictions or standing
instructions to refrain from a particular industry requested by the Client. In all cases,
trading restrictions will depend on the sub-advisor and their ability to accommodate such
restrictions.
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All performance reporting will be the responsibility of the respective Manager. Such
performance reports will be provided directly to you and our firm. Disclosures will indicate
what firm is providing the reporting.
All third-party Managers to whom we will recommend for clients will be licensed as
registered investment advisors by their resident state and any applicable jurisdictions or
registered investment advisors with the Securities and Exchange Commission. A complete
description of the Manager’s services, fee schedules and account minimums will be
disclosed in the Manager’s Form ADV or similar Disclosure
Brochure.
We review the performance of our Managers on at least a quarterly basis. More frequent
reviews may be triggered by changes in Manager’s management, performance, or
geopolitical and macroeconomic specific events. Our Firm only enters into only a select
number of relationships with Managers.
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 Dodds Wealth’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.
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.
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.
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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
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 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.
RETIREMENT PLAN ADVISORY SERVICES
Retirement Plan Advisory Services consists of helping employer plan sponsors to establish,
monitor and review their company's retirement plan. As the needs of the plan sponsor
dictate, areas of advising could include investment selection and monitoring, plan
structure, and participant education.
Pursuant to Section 402(c)(3) of ERISA, the client may appoint us as the Plan’s “investment
manager” with respect to the Plan’s portfolio of investment options. We acknowledge that
we are registered as an investment adviser under the SEC. Our firm acts as a “fiduciary”
within the meaning of Section 3(21) and 3(38) of ERISA with respect to the Plan. We offer
advisory services to employer sponsored retirement plans such as 401(k), 457, & 403(b).
On the plan level, we manage the investment line-up making changes as necessary as well
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as providing risk-based investment models for the participants. On the individual
participant level, we manage risk-based models using the current investment lineup based
on risk tolerance of the individual investor. For employer-sponsored retirement plans with
participant-directed investments, our firm provides its advisory services as an investment
advisor 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) agreements, our Firm can provide the following services to the Plan
Sponsor:
• Review or Development of an Investment Policy Statement
• Perform Due Diligence on Money Managers
• Provide Initial Investment and Management Selection ‐ Our Firm typically uses
mutual funds/managed accounts/collective trusts/cash equivalents to structure
portfolios designed to meet client objectives and risk profiles.
• Provide ongoing Performance Evaluation and Monitoring of Money Mangers
• Make Investment Recommendations when necessary
• Retirement Plan Services Analysis ‐ Our Firm will conduct an analysis of a clients
retirement plan to evaluate the services currently provided to the client by third
parties. The areas of analysis may include asset management services, record
keeping, administration, customer service, participant education, etc. These
services may also include a cost/benefit analysis, recommendation of alternative
vendors, facilitation of the RFP process for solicitation of a new vendor, and/or
assistance in fee negotiations with proposed vendors.
• Provide Employee Education Services ‐ Our Firm will provide enrollment and
educational services the content of the program will be generic in nature.
When servicing as in a 3(38) fiduciary capacity, our Firm is granted full trading authority
over the Plan and have the responsibility for the selection and monitoring of all investment
options offered under the Plan in accordance with the investment policy statement and its
underlying investment objectives and strategies for the Plan. Plan participants have the
ability to exercise control over the investment selection from the plans line up of
investments, and we have no authority or discretion to direct the investment of assets of
any participant’s account under the Plan.
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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,
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
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.
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,
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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. Our Firm’s Chief Compliance Officer remains available to address any questions that
a client or prospective client has regarding the oversight.
ASSETS
As of February 8, 2023, our Firm has $429,579,097 discretionary assets under management
and $0 non-discretionary assets under management.