WNWM is an investment adviser registered with the State of Arizona. WNWM was founded in Nevada
as a Limited Liability Company. WNWM is wholly owned by Jacob Williams and Daniel Novak.
Investment Advisory Services
WNWM offers investment advisory services to individuals, high net worth individuals, trusts, estates,
charitable organizations, pension plans, profit sharing plans and businesses (each referred to as a
“Client” or “You”) through affiliated investment advisor representatives (“Financial Advisors”).
WNWM’s investment strategies are primarily long-term focused, but Financial Advisors may, in certain
circumstances, buy, sell, re-allocate or rebalance positions that have been held less than one year to
meet a Client’s objectives or due to market conditions. Prior to rendering investment recommendations,
Financial Advisors ascertain your financial situation, risk tolerance, and investment objectives.
Financial Advisors may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. Financial Advisors may recommend specific positions to increase sector or asset class
weightings. Financial Advisors may recommend employing cash, options, or inverse ETF positions as
possible hedges against general market declines, which could adversely affect the portfolio. Financial
Advisors may recommend selling positions for reasons that include, but are not limited to, harvesting
capital gains or losses, business or sector risk exposure to a specific security or class of securities,
overvaluation or overweighting of the positions in the portfolio, change in a Client’s risk tolerance or
investment objectives, generating cash to meet a Client’s needs, or any risk deemed unacceptable for a
Client’s risk tolerance.
You should immediately advise your Financial Advisor if your investment objectives or risk
tolerance changes, or other factors change that may affect the proper positioning of your
portfolio.
Your participation in this process, including full and accurate disclosure of requested information, is
essential for the analysis of your portfolio. Your Financial Advisor and WNWM shall rely on the financial
and other information provided by you or your designees without the duty or obligation to validate the
accuracy and completeness of the provided information. It is your responsibility to inform your Financial
Advisor or WNWM of any changes in financial condition, goals or other factors that may affect this
analysis. The Financial Advisor will work with you to determine your tolerance for risk as part of the asset
allocation and portfolio construction process.
WNWM Discretionary Investment Management Accounts
WNWM and Clients enter into an Investment Management Agreement (“IMA”) to provide WNWM with
discretion to manage one or more Client accounts. Your Financial Advisor works with you to identify your
investment goals and objectives as well as your risk tolerance and financial situation. Investment
strategies consider your specific needs and are implemented using the investment options most
appropriate for you. Your Financial Advisor may develop an asset allocation or a targeted investment
strategy for you, as appropriate.
Your Financial Advisor will construct your portfolios utilizing various types of securities based upon your
investment objectives, risk tolerance and other factors. WNWM and your Financial Advisor may use
individual equity and fixed income securities, mutual funds, exchange-traded funds (“ETFs”), structured
notes and options as necessary to achieve your investment goals. Individual equity securities may include
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domestic and international securities covering all market capitalizations. Fixed income securities may
include corporate debt securities, U.S. government securities, municipal securities, foreign debt, and
short-term instruments. Investments in tradable or non-tradable real estate investment trusts (“REITs”),
private equity, private debt investments, limited partnerships and non-security investments may be
recommended, if appropriate, for certain Client portfolios.
Financial Advisors construct, implement and monitor your portfolio to ensure it meets the goals,
objectives, circumstances, and risk tolerance that you have agreed to. You have the ability to place
reasonable restrictions on the types of investments to be held in your respective portfolio, subject to the
acceptance by the Financial Advisor and WNWM.
WNWM Investment Advisory Accounts (Non-Discretionary)
WNWM and Clients may enter into an Investment Advisory Agreement (“IAA”) to provide WNWM on a
non-discretionary basis to perform services as described in the IAA to one or more Client accounts.
Financial Advisor shall be responsible for reviewing, analyzing and providing recommendations
regarding your investments and accounts you designate as subject to the IAA. Your Financial Advisor
works with you to identify your investment goals and objectives as well as your risk tolerance and financial
situation. Investment strategies consider your specific needs and the recommendations made are using
the investment options most appropriate for you. Your Financial Advisor may develop and recommend
an asset allocation or a targeted investment strategy for you, as appropriate.
The IAA is a non-discretionary advisory agreement. If your Financial advisor does not have access or
authority to execute trades in your account(s), you are responsible for the implementation, trading and
execution of any recommendations provided by your Financial Advisor.
Educational Workshops and Newsletters
WNWM and affiliated organizations offer educational workshop events and newsletters. These events
and newsletters are offered to educate current and prospective clients on general financial planning
strategies.
You are not obligated to implement any recommendations made by your Financial Advisor and your
Financial Advisor is in no way responsible for ensuring you do so.
Financial Planning, Retainer Financial Planning and Consulting Services
Financial Advisors provide a variety of financial planning and consulting services to individuals, families,
and businesses, depending upon their circumstances. In certain cases, your Financial Advisor will
request that you enter into a separate Financial Planning or Retainer Financial Planning Agreement with
WNWM for the performance of these planning services. Generally, such financial planning services
involve preparing a financial plan or rendering a financial consultation for you based upon your financial
goals and objectives. This planning or consulting may encompass one or more areas of need, including,
but not limited to investment planning, retirement planning, personal savings, education savings and
other areas of your financial situation. A financial plan developed for you or financial consultation
rendered to you usually includes general recommendations for a course of activity or specific actions to
be taken by you. For example, recommendations may be made that you initiate or revise your investment
programs, commence or alter retirement savings, establish education savings and/or charitable giving
programs. The financial planning agreement may be for a specific project, a specified period or on-going,
depending upon your situation, goals, objectives and other factors.
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Financial Advisors may also refer you to an accountant, attorney, or another specialist, as appropriate
for your unique situation. For certain financial planning engagements, Financial Advisors generally
provide a written summary of your financial situation, observations, and recommendations. For retainer,
consulting or ad-hoc engagements, your Financial Advisor may not provide you with a final written
summary, depending on the arrangement. Your Financial Advisor will communicate the work performed
and any recommendations as defined in the Agreement throughout the engagement.
You are not obligated to implement any recommendations made by your Financial Advisor and your
Financial Advisor is in no way responsible for ensuring you do so.
Sub-advisors
Some of our Financial Advisors utilize third-party managers to sub-advise your accounts if you need or
are seeking a specific type of investment management or strategy. Sub-advisors provide investment
allocation and securities selection and may execute securities transactions in your accounts pursuant to
an agreement with WNWM and your IMA. Certain sub-advisors use ETFs and/or mutual funds in Client
portfolios to which they are manager or sub-advisor. In such cases, the selection of these investments
creates a conflict of interest for the sub-advisor. These sub-advisors disclose conflicts of interests,
including their selection of such investments, in their Form ADV Part 2. Financial Advisors advise you in
establishing investment objectives, and work with the sub-advisors to ensure an appropriate investment
strategy for you. You are provided with the sub-advisor’s Form ADV Part 2 (or a brochure such as this).
Third-party Account Managers
Some of our Financial Advisors may recommend to you that all or a portion of your portfolio be
implemented by utilizing one or more unaffiliated money managers. This involves entering into an IMA
with WNWM and a separate agreement with a third-party manager. Financial Advisors advise you in
establishing investment objectives for the account, the selection of the third-party manager, and defining
any restrictions on the account. Financial Advisors continue to provide management oversight of your
account and ongoing monitoring of the activities of the third-party manager. Certain third-party managers
use ETFs and/or mutual funds in Client portfolios to which they are manager or sub-advisor. In such
cases, the selection of these investments creates a conflict of interest for the third-party manager. These
third-party managers disclose conflicts of interests, including their selection of such investments, in their
Form ADV Part 2. You are provided with the third-party manager's Form ADV Part 2 (or a brochure such
as this one).
Third-party Administrative Support
Certain aspects of our investment and platform operations are performed by Dynamic Advisor Solutions,
LLC (“Dynamic” See Section 10.). The administration of, and access to, Dynamic’s wealth management
platform as well as advisor and client portal are utilized by our firm for a fee charged to our firm. Dynamic
provides assistance in trading and rebalancing our designed models and investment models designed
by Dynamic. Investment models are selected by our firm based upon client circumstances. Dynamic
generates our fee calculations and performs fee debiting and other administration based upon our
specifications.
Outside Accounts
Some of our Financial Advisors also manage and recommend allocations as well as provide consolidated
reporting for Outside Accounts such as sub accounts of variable annuities, fixed annuities, 529 Plans,
401ks, REITs and other similar accounts. Generally, these accounts are not held by a custodian that is
holding other accounts managed by WNWM and Financial Advisors. We regularly review the current
holdings and available investment options in these accounts, monitor the accounts, rebalance and
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implement our strategies as necessary. In some cases, we use an Order Management System to
implement asset allocation or rebalancing strategies on behalf of the client. In other cases, we do not
have the ability to execute the recommended asset allocation or strategies and therefore you are
responsible for implementing any such recommendations. Outside Accounts may be included in the
accounts on the IMA and subject to an Investment Advisory Fee, if applicable (See “Fees and
Compensation” section herein below and your IMA).
Employee Retirement Income Security Act (“ERISA”)
WNWM may authorize certain of its Financial Advisors to provide fiduciary or non-fiduciary services to
ERISA plans. ERISA plan documents typically designate one of more persons, such as the plan trustee,
to undertake fiduciary responsibility for the operation of, and take actions on behalf of, the plan. Such
persons are known as Responsible Plan Fiduciaries (“RPFs”). Financial Advisors may provide the
following services to ERISA plans:
• Assessment and Selection of Investments
• Investment Policy Statement Development
• Non-ERISA Fiduciary Services
• Investment Policy Statement Review
• Performance Monitoring
• Employee Enrollment and/or assistance
• Employee Education
• Vendor Review and Conversion
When we provide investment advice to you regarding your retirement plan or individual retirement plan
account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security
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.
Your Adviser may provide additional or other services to you which are not described in this Brochure.
You should read and review your Adviser’s ADV Part 2A Brochure for information regarding services
provided by your Adviser.
Assets Under Management
As of May 16, 2023, total assets under management were $0; with discretionary assets under
management of $0 and non-discretionary assets under management of $0.