A. Firm Information
DMLO Wealth Planning, LLC (“DMLO” or the “Advisor”) is a registered investment advisor located in the
Commonwealth of Kentucky. The Advisor was organized as a Limited Liability Company (“LLC”) under the laws of
of Kentucky in July 2021. DMLO became a registered investment advisor in June 2022. DMLO changed its legal
entity name from DMLO Wealth Management LLC to DMLO Wealth Planning, LLC in March 2023. DMLO is owned
by Deming, Malone, Livesay & Ostroff, P.S.C. and Guidance Consulting, LLC. The Managing Member of Deming,
Malone, Livesay & Ostroff, P.S.C. is Christopher A. Ward (Director). Guidance Consulting, LLC is owned by
Stephen R, Gibson, CPA (Director and Financial Planner/Chief Compliance Officer) and Beau J. Handy, CFP,
CFS (Director and Financial Planner).
This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory
services provided by DMLO. For information regarding this Disclosure Brochure, please contact Stephen R,
Gibson, CPA (Chief Compliance Officer) at (502) 813-2100.
B. Advisory Services Offered
DMLO offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses,
and retirement plans (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. DMLO's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more
information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading.
Investment Management Services
DMLO provides customized investment advisory solutions for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary investment management and related advisory
services. DMLO works closely with each Client to identify their investment goals and objectives as well as risk
tolerance and financial situation in order to create a portfolio strategy.
DMLO will construct Client investment portfolios either through its internal investment management or an allocation
to other money managers (Please see User of Other Managers below). For its internal investment management,
the Advisor primarily utilizes diversified mutual funds, exchange-traded funds (“ETFs”), individual stocks and/or
individual bonds to achieve the Client’s investment goals. The Advisor may also utilize other types of investments,
as appropriate to meet the needs of the Client. The Advisor may retain legacy investments based on portfolio fit
and/or tax considerations.
DMLO’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions
that have been held for less than one year to meet the objectives of the Client or due to market conditions. DMLO
will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk
tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types
of investments to be held in their respective portfolio, subject to acceptance by the Advisor.
DMLO evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. DMLO may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. DMLO may recommend specific positions to increase sector or asset class weightings. The Advisor may
recommend employing cash positions as a possible hedge against market movement.
DMLO 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 position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any
risk deemed unacceptable for the Client’s risk tolerance.
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At no time will DMLO accept or maintain custody of a Client’s funds or securities, except for the limited authority as
outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian,
pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the
assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account
to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or
increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a
retirement account to an account managed by the Advisor.
Use of Other Managers – DMLO may recommend that a Client utilize one or more other registered investment
advisors to provide discretionary investment management. The Advisor may recommend unaffiliated investment
managers or investment platforms or its affiliated registered investment advisor, Dynamic Market Advantage, LLC
(herein collectively referred to as “Other Managers ”). Other Managers
may be engaged to manage all or a portion
of a Client’s investment portfolio. In such instances, the Client will typically be required to enter into a separate
investment management agreement with the Other Manager that defines the terms in which the Other Manager will
provide its services. The Advisor may also assist in the development of the initial policy recommendations and
managing the ongoing Client relationship. The Advisor will perform initial and ongoing oversight and due diligence
over the selected Other Manager[s] to ensure each Other Manager’s strategies and target allocations remain
aligned with the Client’s investment objectives and overall best interests. The Client, prior to entering into an
agreement with unaffiliated investment manager[s] or investment platform[s], will be provided with the Other
Manager's Form ADV 2A (or a brochure that makes the appropriate disclosures). DMLO advises the Client that a
recommendation to use Dynamic Market Advantage, LLC (“DMA”) presents a conflict of interest due to the common
ownership. Please see Item 10 below.
Financial Planning Services
DMLO will typically provide a variety of financial planning and consulting services to Clients. Financial planning
services may be offered as part of an overall wealth management engagement and single fee or under a separate
financial planning engagement. Services are offered in several areas of a Client’s financial situation, depending on
their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or
rendering a specific financial consultation based on the Client’s 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, insurance needs, and other areas of a Client’s financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs.
DMLO may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique
situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s
financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may
not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date,
assuming all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for
investment management services or to increase the level of investment assets with the Advisor, as it would
increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any
recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to
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act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the
transaction through the Advisor.
Retirement Plan Advisory Services
DMLO provides non-discretionary retirement plan advisory services on behalf of the retirement plans (each a
“Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to
assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement
is customized to the needs of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and Monitoring
• Investment monitoring and oversight
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
These services are provided by DMLO serving in the capacity as a fiduciary under the Employee Retirement
Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan
Sponsor is provided with a written description of DMLO’s fiduciary status, the specific services to be rendered and
all direct and indirect compensation the Advisor reasonably expects under the engagement.
C. Client Account Management
Prior to engaging DMLO to provide investment advisory services, each Client is required to enter into one or more
agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the
Client. These services may include:
• Establishing an Investment Strategy – DMLO, in connection with the Client, will develop a strategy that
seeks to achieve the Client’s goals and objectives.
• Asset Allocation – DMLO will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – DMLO will develop a portfolio for the Client that is intended to meet the stated goals
and objectives of the Client.
• Investment Management and Supervision – DMLO will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
DMLO does not manage or place Client assets into a wrap fee program.
E. Assets Under Management
As of the 12/31/2023, DMLO has $14,224,971 of discretionary assets under management. Clients may request
more current information at any time by contacting the Advisor.