Description of the Firm
210 Wealth Management, Inc., is an Illinois Corporation founded in 2023 with its principal place of
business in Illinois and is principally owned by Phil & Kelly Cooper.
210 is a financial services firm helping individuals create financial strategies using a variety of
investment and insurance products to suit their needs and objectives.
Description of Services Offered
Retirement Income Strategies / Investment Advisory / Portfolio Management Services
Our firm offers continuous and ongoing investment advice and portfolio management services. Our
advice and services are tailored to meet our client's individual needs, life circumstances and
investment goals. We conduct an initial meeting with clients and prospects in order to understand
their current financial situation, existing resources, financial goals, investment objectives, risk
tolerance, time horizons and liquidity needs.
The primary investment management service we provide is a discretionary asset management
program. Clients participating in this program are generally placed in a model overseen by a financial
professional at our firm and sub-advised by a third-party investment adviser. Under this program,
210 and any sub-advisers we hire to manage the assets in your account are authorized to buy and
sell investments in the account without asking you in advance. We will monitor the portfolio's
performance on an ongoing and continuous basis, unless otherwise agreed, and will make
adjustments and reallocations as necessary due to changes in market conditions and your unique
circumstances.
Clients have the ability to impose reasonable restrictions and guidelines on investing in certain
securities, types of securities or industry sectors. We expect all such restrictions to be timely
communicated to us in writing. Client restrictions and guidelines could negatively affect investment
performance.
Clients must inform us of any changes to their financial circumstances, investment objectives or risk
tolerance, or of any modifications or restrictions that are imposed on the management of the client's
account. In this manner, our firm can better serve clients' needs.
On a case-by-case basis, we may also agree to provide maintenance only and/or non-discretionary
asset management services where appropriate. For these services, we will receive a limited power
of attorney to effect securities transactions on your behalf and we will continue to make investment
recommendations based on your individualized investment strategy. However, unlike discretionary
accounts, we would first be required to obtain your approval before executing transactions. You will
be responsible for responding in a timely manner to any approval requests.
Our services encompass asset management designed to assist clients in meeting their retirement
financial goals using financial investments. We explore different types of investment options and
strategies in the design of a client’s portfolio. Our investment recommendations are not limited by
any specific product or service. Below is a list of commonly recommended investment vehicles.
• Exchange listed securities and over the counter traded securities
• Mutual funds
• Exchange-traded fund shares
• Commodities
• Separate accounts; and
• Money market funds and other cash instruments
We will also provide advice regarding the following security types:
• Certificates of deposit
• Corporate debt securities
• Municipal securities
• U.S. governmental securities
• Variable (No-Load) annuity products
• Life Insurance Products
Each type of security has its own unique set of risks associated with it, and it would not be possible
to list all the specific risks of every type of investment. Even within the same type of investment, risks
can vary widely. However, in very general terms, the higher the anticipated return of an investment,
the higher the risk of loss associated with it.
Because some types of investments involve certain additional degrees of risk, they will only be
recommended and implemented when consistent with the client's risk tolerance, investment
objectives, and where the investment is determined to be suitable.
Asset Management Services through AE Wealth Management or The Pacific Financial Group
We offer discretionary asset management services. Our investment advice is tailored to meet our
clients' needs and investment objectives. If you retain our firm for asset management services, we
will meet with you to determine your investment objectives, risk tolerance, and other relevant
information at the beginning of our advisory relationship. We will use the information we gather to
develop a strategy that enables our firm to give you continuous and focused investment advice. We
may also consult with you about options available to you in your pension plan. As part of our asset
management services, we will customize an investment portfolio for you according to your risk
tolerance and investing objectives. We may also invest your assets according to one or more model
portfolios developed by an unaffiliated investment adviser firm. Once we select a model portfolio, we
will monitor your portfolio's performance on an ongoing basis, and will rebalance the portfolio as
required by changes in market conditions and in your financial circumstances.
If you participate in our discretionary asset management services, we require you to grant our firm
discretionary authority to manage your account. Discretionary authorization will allow us to
determine the specific securities, and the amount of securities, to be purchased or sold for your
account and the commissions to be paid to brokerage firms without your approval prior to each
transaction.
Discretionary authority is typically granted by the Investment Advisory Agreement you sign with our
firm and the appropriate trading authorization forms. You may limit our discretionary authority (for
example, limiting the types of securities that can be purchased or sold for your account) by providing
our firm with your restrictions and guidelines in writing.
As part of our investment advisory services, we may use one or more third-party money manager(s)
to manage a portion of your account on a discretionary basis. Our firm may utilize the services of
various third-party money managers for the management of client accounts, allocating client assets
among such managers as appropriate. In such cases, the third-party money managers will be
responsible for continuously monitoring client accounts and making trades in client accounts when
necessary. While the chosen third-party money manager(s) will provide advice on specific securities
and/or other investments in connection with this service, our firm has discretionary authority to hire
and fire such managers and reallocate assets among them as deemed appropriate. We will assist you
with identifying your risk tolerance and investment objectives, and, in turn, retain third-party money
managers in relation to your stated investment objectives and risk tolerance. As a result, we allocate
a portion of the total fee charged and collected from you to the third-party money managers, if
utilized, as compensation for their direct management of your account.
We have sub-advisory relationships with AE Wealth Management, LLC ("AEWM") & The Pacific
Financial Group (“TPFG”) to provide investment advisory services to clients. These arrangements
allow us to access model portfolios, model managers, strategists, third-party money manager(s), and
trading services through AEWM or TPFG managed account programs. AEWM and TPFG are not
affiliated entities.
As part of a sub-advisory program, you will give us and the sub-advisor discretion to select third
party, nonaffiliated investment managers ("Model Managers") to design and manage model
portfolios for your assets. If we offer you services through a sub-advisor, we will provide you with a
copy of the sub-advisor’s disclosure brochure which contains a detailed description of their services.
We will regularly monitor the performance of your accounts managed by AEWM, TPFG, or other
third-party money manager(s), and may hire and fire any third party money manager(s) without
your prior approval. Sub-advisors will calculate the advisory fee and instruct the qualified
custodian(s) to deduct the fee and pay the sub-advisor and our firm in accordance with your
agreement. However, you will not pay anything over and above our firm’s advisory fee in order to
receive the third party money manager’s services.
Wrap Fee Programs
A wrap fee program is a program under which the client pays a single fee that covers both receipt of
investment advice and the execution of securities transactions. We do not sponsor any wrap fee
programs. However, the structure and nature of the various accounts under the AEWM or TPFG
arrangements as described above may be considered to be wrap fee type programs in that
commissions are not charged to the client. In these programs, the advisory fee paid by the client
includes custody, trades, management expertise and reporting in a bundled format. A client's total
cost of each of the services provided through wrap fee programs could be different if purchased
separately. Cost factors may include the client's ability to:
1. Obtain the services provided within the programs separately from any of the mutual fund sponsors,
2. Invest and rebalance the selected securities without the payment of a transaction charge, and
3. Obtain performance reporting comparable to those provided within each program.
When comparing
costs, the combination of multiple mutual fund or securities investments, advisory
services, custodial and brokerage services available through each program may not be available
separately. Clients may be required to have multiple accounts, sign numerous documents and incur
various fees. If an account is not actively traded or the client qualifies for reduced sales charges, the
fees in these programs may be more expensive than if utilized separately.
We believe the charges and fees offered within each fee-based program are competitive and
reasonable when compared to alternative programs available through other firms and/or
investment sources. However, we make no guarantee that the aggregate cost of a particular program
is lower than that which may be available elsewhere.
If you participate in a wrap program with a sub-advisor it will be on a discretionary basis. The
strategies implemented are based on clients' individual investment objectives. If you participate in a
wrap fee program, we will provide you with a separate Wrap Fee Program Brochure from the sub-
advisor explaining the program and costs associated with the program.
Financial Planning Services
Our firm also provides financial planning services. Depending on your particular circumstance, such
services could include a comprehensive evaluation of your financial situation by using currently
known facts and variables, or it might focus on a few items of particular importance to you. Generally,
such financial planning services will involve preparing a financial plan or rendering a financial
consultation for clients based on the client's current situation, financial goals and objectives. The
financial planning process is used with clients to discuss the current state of their finances and to
establish goals and objectives for the future. The Firm does not charge additional fees for planning,
at this time. Regardless of the nature of the service, the implementation of all recommendations will
be at the client's discretion.
A financial plan will address one or more of the following areas:
• Financial Position: Understanding of a client's current financial situation.
• Investment Planning: Determining the most suitable way to structure investments to meet
financial goals, and determine the appropriate account type (e.g., joint tenants, IRA, Roth IRA,
etc.)
• Personal Tax Planning: Evaluating the current tax situation to help minimize a client's taxes
and find more profitable ways to use the extra income generated.
• Retirement Planning: Assessing retirement needs to help a client determine how much to
accumulate, as well as distribution strategies designed to create a source of income during
retirement years.
• Insurance Planning and Risk Management: Evaluating the client's insurance needs and
reviewing insurance policies and the like.
• Estate Planning: Reviewing the client's cash needs at death, income needs of surviving
dependents and estate planning goals.
• Charitable Planning: Providing strategic charitable giving plans for clients and researching and
evaluating charitable entities and private foundations.
• Mortgage/Debt Analysis: Analyzing client's current mortgage debt, home equity, and financing
alternatives.
• Review of Employee Benefit Plans: Reviewing the client's investment options, allocation
models and historical performance of client assets held through employee benefit plans.
We gather information at an initial meeting which includes interviews and a review of documents
provided by the client. Information gathered includes the client's current financial status, future
goals, investment objectives, risk tolerance and family circumstances.
Typical financial planning services include one or more of each of the service components. A financial
plan could require the services of a specialist such as an insurance specialist, attorney or tax
accountant. We will recommend third-party service providers if we feel it is appropriate and in your
best interest, but you are under no obligation to use any service provider recommended by us.
Likewise, you are under no obligation to act on our financial planning recommendations. We do not
receive referral or other fees from third-party service providers.
Financial plans are based on the client's financial situation at the time we present the financial plan
to the client, and on the information provided to us. The client must promptly notify us if his/her
financial situation, goals, objectives or needs change. Certain assumptions are made with respect to
interest rates, inflation rates, and use of past trends and performance of the market and economy.
Past performance is in no way an indication of future performance. We do not offer any guarantees
or promises that a client's financial goals will be met.
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.
Client Assets Under Management
As of March 15, 2023, 210 had Assets Under Management of approximately $116,830,850.
Information Regarding Potential Conflicts of Interest
Although we seek to avoid them, our firm has actual or potential conflicts of interest arising from our
advisory services. These include, but are not limited to:
• Conflicts related to allocating time and resources between client accounts, allocation of
brokerage commissions and investment opportunities generally. For further information on
our brokerage and allocation policies, and related conflicts of interest, please refer to Item 12
below.
• Conflicts related to asset-based fees. At times our investment professionals will recommend
that a client move assets form another investment account to one managed by our firm. This
would result in a higher total advisory fee for that investment professional and generate
revenue for the firm. There is therefore a conflict of interest whenever we encourage clients to
move their assets to our firm. For further information, please refer to Item 5 which discusses
the fees we earn when providing advisory services.
• Conflicts related to one or more of our investment advisor representatives also being licensed
as an independent insurance agent through licensed insurance brokers. For further
information, please refer to Item 10 below.
• Conflicts related to investing in securities recommended to clients and contemporaneous
trading of securities (i.e., personal trading) by the firm and its related persons. Please refer to
Item 11 for further information.
• Conflicts related to third parties. When appropriate, we will recommend third parties to advise
a client on matters including but not limited to: legal, tax or accounting advice. These
recommendations are sometimes made because of existing relationships our firm and its
employees have with these groups or individuals. We do not currently have any formal solicitor
or referral arrangements.
Actual or potential conflicts of interest generally can be addressed in several ways, including
prohibiting the conduct that gives to the conflict of interest, implementing procedures to prevent a
person from gaining or utilizing knowledge that potentially give rise to a conflict; establishing
parameters for conduct that are designed to protect client interests or limit the benefit that creates
the conflict of interest, or disclosing the conflict of interest to our clients. Our material conflicts of
interest have been disclosed in our Investment Management Agreement and in this ADV Part 2A. If
you have any questions, please contact the firm at 309-263-1333.
Our firm has adopted a Code of Ethics. (Please refer to Item 11 below for further information on our
Code of Ethics) and we also have policies and procedures in place to mitigate and address conflicts
of interest. We believe that such policies and procedures are reasonably designed to treat clients
equitably and to advance the best interests of the clients. The clients' best interest is paramount in
any situation involving a conflict of interest.
Wrap Fee Programs
Wrap Fee Programs are arrangements between broker-dealers, investment advisers, banks and
other financial institutions and affiliated and unaffiliated investment advisers through which the
clients of such firms receive discretionary investment advisory, execution, clearing and custodial
services in a “bundled” form. In exchange for these “bundled” services, the clients pay an all-inclusive
(or “wrap”) fee determined as a percentage of the assets held in the wrap account.
210 Wealth Management does not participate in and is not a sponsor of any wrap fee program(s).