A. Description of the Advisory Firm
Stillwater Wealth Management Group LLC (hereinafter “SWMG LLC”) is a Limited
Liability Company organized in the State of Florida. The firm was formed in June 2020,
and the principal owners are Tyler Steven Wright and Richard Robert Blumenfeld.
B. Types of Advisory Services
Portfolio Management Services
SWMG LLC offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. SWMG LLC creates an
Investment Policy Statement for each client, which outlines the client’s current situation
(income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the
selection of a portfolio that matches each client's specific situation. Portfolio management
services include, but are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring
SWMG LLC evaluates the current investments of each client with respect to their risk
tolerance levels and time horizon. SWMG LLC will request discretionary authority from
clients in order to select securities and execute transactions without permission from the
client prior to each transaction. Risk tolerance levels are documented in the Investment
Policy Statement, which is given to each client.
SWMG LLC seeks to provide that investment decisions are made in accordance with the
fiduciary duties owed to its accounts and without consideration of SWMG LLC’s
economic, investment or other financial interests. To meet its fiduciary obligations,
SWMG LLC attempts to avoid, among other things, investment or trading practices that
systematically advantage or disadvantage certain client portfolios, and accordingly,
SWMG LLC’s policy is to seek fair and equitable allocation of investment
opportunities/transactions among its clients to avoid favoring one client over another
over time. It is SWMG LLC’s policy to allocate investment opportunities and transactions
it identifies as being appropriate and prudent among its clients on a fair and equitable
basis over time.
Pension Consulting Services
SWMG LLC offers consulting services to pension or other employee benefit plans
(including but not limited to 401(k) plans). Pension consulting may include, but is not
limited to:
• identifying investment objectives and restrictions
• providing guidance on various assets
classes and investment options
• recommending money managers to manage plan assets in ways designed
to achieve objectives
• monitoring performance of money managers and investment options and
making recommendations for changes
• recommending other service providers, such as custodians, administrators
and broker-dealers
• creating a written pension consulting plan
These services are based on the goals, objectives, demographics, time horizon, and/or risk
tolerance of the plan and its participants.
Services Limited to Specific Types of Investments
SWMG LLC generally limits its investment advice to mutual funds, fixed income
securities, real estate funds (including REITs), insurance products including annuities,
equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation
protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds
and private placements, although SWMG LLC primarily recommends total return/
growth investment objective in quality dividend-paying large cap equities and
investment grade fixed income. . SWMG LLC may use other securities as well to help
diversify a portfolio when applicable.
C. Client Tailored Services and Client Imposed Restrictions
SWMG LLC will tailor a program for each individual client. This will include an interview
session to get to know the client’s specific needs and requirements as well as a plan that
will be executed by SWMG LLC on behalf of the client. SWMG LLC may use model
allocations together with a specific set of recommendations for each client based on their
personal restrictions, needs, and targets. Clients may impose restrictions in investing in
certain securities or types of securities in accordance with their values or beliefs. However,
if the restrictions prevent SWMG LLC from properly servicing the client account, or if the
restrictions would require SWMG LLC to deviate from its standard suite of services,
SWMG LLC reserves the right to end the relationship.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees, transaction costs, fund expenses, and other administrative
fees. SWMG LLC does not participate in any wrap fee programs.
E. Assets Under Management
SWMG LLC has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$ 102,344,284.00 $ 5,163,613.00 December 2022