General Information
Boomfish Wealth Group, LLC (“Advisor” or the “Firm”) was formed in 2011. Advisor is an SEC-
registered investment adviser. Conducting its business under the name Wealth With No Regrets®,
created and designed by Barry Spencer and Scott Noble, Advisor provides investment advisory
services and integrated financial planning services including, but not limited to: portfolio management,
retirement income planning, insurance planning and risk management (including long-term care,
Medicare supplement, life, disability, and annuities), tax planning, charitable planning, estate or legacy
planning to retail investors.
Barry H. Spencer is the sole principal owner of Advisor. Please see Form ADV Part 2B (Brochure
Supplement) for more information on Mr. Spencer and other individuals who formulate investment
advice and have direct contact with clients, or who have discretionary authority over client accounts.
SERVICES PROVIDED
At the outset of each client relationship, Advisor spends time in conversation with you, asking clarifying
questions, discussing your investment experience and financial circumstances, and broadly identify
your major goals and priorities in order to customize your investment and financial plan.
Clients may elect to retain Advisor to prepare a full financial plan as described below. This written
report is presented to the client for consideration. In many cases, clients subsequently retain Advisor to
manage the investment portfolio on an ongoing basis.
For those clients that retain us for investment advisory services or portfolio management services
Advisor generally develops a financial outline tailored to you based on your financial circumstances,
priorities and goals, your risk tolerance level (the “Financial Profile” or “Profile”), your investment
objectives and guidelines, including your own investment restrictions.
The Financial Profile reflects the client’s current financial picture and a look to the future goals and
priorities of the client. The investment plan outlines the types of investments Advisor will make on
behalf of the client to meet those goals. The Profile is discussed regularly with each client but are not
necessarily written documents.
With respect to any account for which the Firm meets the definition of a fiduciary under Department of
Labor rules, Wealth With No Regrets® acknowledges that both the Firm and its Related Persons are
acting as fiduciaries. Additional disclosure may be found elsewhere in this Brochure or in the written
agreement between Wealth With No Regrets® and Client.
Integrated Financial Planning
One of the services offered by Advisor is financial planning, described below. This service may be
provided as a stand-alone service or may be coupled with ongoing portfolio management and/or
insurance solutions.
Financial planning generally includes advice that addresses one or more areas of a client's financial
situation, such as portfolio management, retirement income planning, insurance planning and risk
management (including long-term care, Medicare supplement, life, disability, and annuities), tax
planning, charitable planning, estate or legacy planning, budgeting and cash flow controls, and
education funding.
Depending on a client’s particular situation, financial planning may include some or all of the following:
• Gathering factual information concerning the client's personal and financial situation;
• Assisting the client in establishing financial goals and priorities;
• Analyzing the client's present situation (which may include a review of current fees, costs,
investment allocation, risks, tax liability, distribution plan, legacy plan, adequacy of protection)
and anticipated future activities considering the client's financial goals and priorities;
• Identifying potential problems foreseen in the accomplishment of these financial goals and
priorities and offering alternative solutions to the problems for consideration;
• Making recommendations to help achieve retirement plan goals and priorities;
• Designing an investment portfolio to help meet the goals and objectives of the client;
• Providing estate planning ideas, strategy and design;
• Assessing risk and reviewing basic health, life, long-term care and disability insurance needs;
• Reviewing goals and priorities and measuring progress toward these goals.
Once financial planning advice is given, the client may choose to have Advisor implement the client’s
financial plan and manage the investment portfolio on an ongoing basis. However, the client is under
no obligation to act upon any of the recommendations made by Advisor under a financial planning
engagement and/or to engage the services of any recommended professional.
Stay the Course Planning
The recurring planning services that Advisor provides Client under the Stay the Course arrangement is
ongoing in nature and intended to ensure that Advisor and Client meet at least annually to remain on
course to their desired goals and priorities. This recurring planning begins after the initial planning is
complete and includes but is not limited to updating the plan, determining opportunities, performing
administrative duties, and determining risks that need to be addressed based on changing
circumstances. We also may interact with the other advisors of Client to help Client remain on course.
These services may include, but are not limited to, review of priorities and goals, financial plan
updates, cash flow planning for certain events such as education expenses or retirement, estate
planning
analysis, charitable giving planning and strategies, income and estate tax analysis, and
review of a client’s insurance portfolio, as well as other matters specific to the client or upon request by
the client and agreed to by Advisor.
Portfolio Management
As described above, at the beginning of a client relationship, Advisor meets with the client, gathers
information, and performs research and analysis as necessary to develop the client’s investment plan.
The investment plan will be updated from time to time when requested by the client, or when
determined to be necessary or advisable by Advisor based on updates to the client’s financial or other
circumstances. We also meet with the client to develop an understanding of the client’s financial
objectives and goals. We will also discuss concepts related to risk, as well as the client’s ability and
willingness to take on risk in the client’s overall investment portfolio. We will ask the client questions
designed to determine the appropriate investment horizon, risk profile, financial goals, income and
other various items we deem necessary.
To implement the client’s investment plan, Advisor will manage the client’s investment portfolio on a
discretionary basis. As a discretionary investment adviser, Advisor will have the authority to supervise
and direct the portfolio without prior consultation with the client. We will also monitor the client’s
accounts to ensure that they are meeting the client’s investment objectives and other requirements. If
any changes are needed to the client’s investments, We will either make the changes or recommend
the changes to the client. These changes may involve selling a security or group of investments and
buying others or keeping the proceeds in cash or some liquid alternative. The client will receive written
or electronic confirmations from the client’s account custodian after any changes are made to the
client’s account. The client will also receive statements at least quarterly from the client’s account
custodian.
Retirement Plan Advisory Services
Establishing a sound fiduciary governance process is vital to good decision-making and to ensuring
that prudent procedural steps are followed in making investment decisions. Advisor offers Retirement
Plan consulting services to Plans and Plan Fiduciaries. The particular services provided will be detailed
in the consulting agreement. The appropriate Plan Fiduciary(ies) designated in the Plan documents
(e.g., the Plan sponsor or named fiduciary) will (i) make the decision to retain our firm; (ii) agree to the
scope of the services that we will provide; and (iii) make the ultimate decision as to accepting any of
the recommendations that we may provide. The Plan Fiduciaries are free to seek independent advice
about the appropriateness of any recommended services for the Plan. Retirement Plan consulting
services may be offered individually or as part of a comprehensive suite of services.
The Employee Retirement Income Security Act of 1974 (“ERISA”) sets forth rules under which Plan
Fiduciaries may retain investment advisers for various types of services with respect to Plan assets.
For certain services, Advisor will be considered a fiduciary under ERISA. For example, Advisor will act
as an ERISA § 3(21) fiduciary when providing non-discretionary investment advice to the Plan
Fiduciaries by recommending a suite of investments as choices among which Plan Participants may
select. With respect to any account for which Advisor meets the definition of a fiduciary under
Department of Labor rules, Advisor acknowledges that both Advisor and its Related Persons are acting
as fiduciaries. Additional disclosure may be found elsewhere in this Brochure or in the written
agreement between Advisor and Client.
Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor (“DOL”) Field
Assistance Bulletin 2018-02 ceases to be in effect)), for purposes of complying with the DOL’s
Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable, we are providing the
following acknowledgment to you.
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.
We benefit financially from the rollover of your assets from a retirement account to an account that we
manage or provide investment advice, because the assets increase our assets under management
and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in
your best interest.
Assets Under Management
As of December 31, 2023, we provide continuous management services for $162,320,000 in client
assets on a discretionary basis.