A. Firm Information
Berry Wealth Group, LP (“Berry Wealth Group” or the “Advisor”) is a registered investment advisor with the U.S.
Securities and Exchange Commission. The Advisor is organized as a Limited Partnership (LP) under the laws of the
State of Texas. Berry Wealth Group was founded in December 2005. Berry Wealth Group is owned by JML Berry
Enterprises, Michelle Berry and Jason Berry. Berry Wealth Group is operated by Michelle Berry (President and Chief
Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices,
and the advisory services provided by Berry Wealth Group.
B. Advisory Services Offered
Berry Wealth Group 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. Berry Wealth Group'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.
Wealth Management Services
Berry Wealth Group provides tailored wealth management solutions to its Clients. This is achieved through personal
Client contact and interaction while providing discretionary investment management services over Client portfolios
and a broad range of comprehensive financial planning. These services are described below.
Investment Management Services – Berry Wealth Group provides customized investment management solutions for
its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary
investment management and related advisory services. Berry Wealth Group works closely with each Client to identify
their investment goals, objectives, risk tolerance and financial situation in order to create a portfolio strategy. Berry
Wealth Group will then construct a investment portfolio utilizing internal investment models that primarily consist of
low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”), individual stocks, and bonds that seek
achieve the Client’s investment goals. The Advisor may retain certain legacy holdings based on portfolio fit and/or
tax considerations.
Berry Wealth Group’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. Berry Wealth Group 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.
Berry Wealth Group evaluates and selects investments for inclusion in Client portfolios only after applying its internal
due diligence process. Berry Wealth Group may recommend, on occasion, redistributing investment allocations to
diversify the portfolio. Berry Wealth Group 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.
Berry Wealth Group 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.
At no time will Berry Wealth Group 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.
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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.
Financial Planning Services - Berry Wealth Group will typically provide a variety of financial planning and consulting
services to Clients, pursuant to a written financial planning agreement. 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.
Berry Wealth Group 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 act on any of the
recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the
Advisor.
C. Client Account Management
Prior to engaging Berry Wealth Group to provide investment advisory services, each Client is required to enter into
an agreement 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 – Berry Wealth Group, in connection with the Client, will develop a
strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Berry Wealth Group 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 – Berry Wealth Group will develop a portfolio for the Client that is intended to meet the
stated goals and objectives of the Client.
• Investment Management and Supervision – Berry Wealth Group will provide investment management and
ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
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Berry Wealth Group does not manage or place Client assets into a wrap fee program. Wealth management services
are provided directly by Berry Wealth Group.
E. Assets Under Management
Berry Wealth Group is a newly established advisor. Assets under management shall be reported with the Advisor’s
next filing of this Disclosure Brochure. Clients may request more current information at any time by contacting the
Advisor.