A. Description of the Advisory Firm
Waterstone Financial Advisory LLC (hereinafter “WFA”) is a Limited Liability Company organized in the
State of Florida. The firm was formed in January 2023, and the principal owner is James Stuart Gallagher.
Karly Ann Young is the firm’s chief compliance officer.
B. Types of Advisory Services
Investment Management Services
WFA offers ongoing portfolio management services based on the individual goals, objectives, time horizon,
and risk tolerance of each client. After reviewing your situation in depth, WFA creates an Investment Policy
Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance)
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
Clients are advised to promptly notify the firm if there are changes in their financial situation or investment
objectives. If a client wishes to impose a reasonable restriction or mandate on the management of their
accounts, it will be at WFA’s sole discretion, that the conditions will not materially influence the performance
of a portfolio strategy or prove burdensome to its management efforts.
WFA seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its
accounts and without consideration of WFA’s economic, investment, or other financial interests. To meet its
fiduciary obligations, WFA attempts to avoid, among other things, investment or trading practices that
systematically advantage or disadvantage certain client portfolios. It is WFA’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.
Investment Management services can be provided by means of third-party managers, or by custom internal
management defined as Advisor as Strategist:
1. Third Party Managers
AssetMark Advisory Platform. – WFA has entered into a sub-advisory relationship with AssetMark, an
investment adviser registered with the U.S. Securities and Exchange Commission. Through this relationship,
clients can utilize the AssetMark investment platform to access various third-party investment solutions,
including specialized tactical strategy portfolios, diversified baskets of exchange-traded funds, indexing
mutual funds, portfolios of individual equity securities, or strategists specializing in other alternative styles.
AssetMark provides WFA with research, due diligence, and a curated list of the various third-party managers
that have been fully vetted, rated for their expertise, categorized for their trading style, and are monitored
by the AssetMark investment team.
WFA will remain responsible for determining the client’s investment objectives and whether one or more of
the available managers is best suited to meet the designed investment objective of a specific account. The
third-party strategist selected for an account is then responsible for the discretionary management of those
assets.
2. Custom Management – Advisor as Strategist
A client may choose to have a specific account managed in a way that cannot be provided by the diversified
choices available through the AssetMark platform. This typically is driven by the clients desire to retain a
certain set of equities or focus on an allocation that is a narrower in scope. The tax management of an
account may also lead to a recommendation by WFA to enter into an Advisor as Strategist arrangement.
The account is managed by WFA on a discretionary basis based on your financial situation, investment
objectives, and risk tolerance. We actively monitor the account and make investment decisions regarding
buying, selling, reinvesting, or holding securities, cash, or other investments.
By the nature of potentially being less diversified, or having a narrower scope, these accounts may have a
higher risk rating than a similar Third-Party Manager. This will be considered in the overall household risk
planning and allocation.
Financial Planning
Financial plans and financial planning may include but are not limited to creating a structured income plan;
developing savings targets; tax optimization; risk mitigation; wealth transfer strategies; college planning;
and estate planning. Because investing involves varying degrees of risk, our advice will only be
recommended
when consistent with a client’s stated investment objectives, risk tolerance, liquidity needs,
and suitability.
Financial Planning Services include the initial creation and formulation of a personal financial plan, with
recommendations and comparative scenarios as necessary. It also includes the ongoing tracking of your
progress in achieving the personal financial goals targeted in the plan. The scope of the financial planning is
defined in advance and documented using a Financial Planning Agreement. Fees for Financial Planning
Services are defined below under Item 5- Fees and Compensation.
The Financial Planning process typically begins with the collection, organization, and assessment of relevant
client data, including information concerning your lifestyle, risk tolerance, and cash flow, as well as the
identification of your financial concerns, goals, and objectives. The primary objective of this process is to
assist you in developing possible scenarios and a strategy for the successful management of income, assets,
and liabilities. To help achieve this objective, we may provide education, explain the merit of possible
solutions, as well as perform ongoing validation to the attainment of plan benchmarks.
Services Limited to Specific Types of Investments
WFA generally limits its investment advice to fixed income securities, equities, and ETFs. WFA may use
other securities as well to help diversify a portfolio when applicable.
Written Acknowledgement of Fiduciary Status
When we provide investment advice to you regarding your retirement plan account or individual retirement
account, we are 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. 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 interest ahead of yours. 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.
C. Client Tailored Services and Client Imposed Restrictions
WFA 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 WFA on behalf of the
client. WFA 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 WFA from properly servicing the client account, or if the restrictions would require WFA to deviate
from its standard suite of services, WFA reserves the right to end the relationship.
D. Wrap Fee Programs
WFA does not sponsor any wrap-fee programs. However, the AssetMark Platform includes “wrap fee”
arrangements, meaning that if your assets are invested in an AssetMark Investment Solution, you will pay a
fixed fee to AssetMark that includes the management fees, transaction costs, fund expenses, and other
administration fees. AssetMark fees vary depending on which AssetMark Investment Solution or Sub-
Advisor is applied to your account. Clients do not pay separate transaction fees for individual portfolio trades
in the Account when their Account is invested in an AssetMark Investment Solution or another Sub-Advised
Portfolio. The wrap fees may be higher or lower than if such services were obtained separately. Generally,
wrap programs are relatively less expensive for actively traded accounts. Please see Item 14 for more details.
Clients will sign an Account Set-up and Application Form to establish an account on that Platform and will
receive the AssetMark Platform Disclosure Brochure describing the wrap program.
E. Assets Under Management
As of January 01, 2024, WFA has total assets under
management of $174,121,647 of which are managed on a
discretionary basis and $7,259,561 which are non-discretionary.