A. Firm Information Coombs Wealth Advisory, LLC (“Coombs Wealth” or the “Advisor”) is a registered investment advisor with the U.S.
Securities and Exchange Commission (“SEC”), which is organized as a Limited Liability Company (“LLC”) under the laws of Pennsylvania. Coombs Wealth was founded in August 2015, and is owned and operated by Brian C.
Coombs (Managing Partner and Chief Compliance Officer) and Lonnie A. Coombs (Managing Partner). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Coombs Wealth.
B. Advisory Services Offered Coombs Wealth offers investment advisory services to individuals, high net worth individuals, trusts, estates and businesses and other corporations (each referred to as a “Client”).
The Advisor acts as a fiduciary to Clients, as defined under the applicable laws and regulations. As such, each recommendation made as part of the advisory services are based on the belief that the recommendation is in the Client's best interest. The Advisor’s fiduciary commitment to each Client is further described in the Advisor’s Code of Ethics. For more information regarding the Advisor’s Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.
Wealth Management Services Coombs Wealth provides Clients with wealth management services, which generally includes discretionary management of investment portfolios in connection with a broad range of comprehensive financial planning services. Coombs Wealth offers two types of wealth management solutions for its Clients based on the size and complexity of the relationship. Both wealth management services include financial planning and investment management services as described below. Wealth Management Advisory (“WMA”) services are provided based a percentage of assets under management with Coombs Wealth pursuant to the terms of the advisory agreement.
Please see Item 5.A for fees. Wealth Management Fixed Fee Advisory (“WMFF”) services are generally offered when it is more appropriate to incorporate investment management services on a fixed-fee basis, which is detailed in a Wealth Management Fixed Fee Advisory Agreement.
Investment Management Services – Coombs Wealth provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while, providing discretionary and non-discretionary investment management, and financial planning services. Coombs Wealth works 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. Coombs Wealth will then construct a portfolio, consisting of diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, individual bonds and other types of investments, as appropriate, to meet the needs of particular Clients.
Coombs Wealth’s investment approach is 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. Coombs Wealth typically seeks tax efficiency with respect to its investment strategies. Coombs Wealth 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.
Coombs Wealth evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Coombs Wealth may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Coombs Wealth 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, which may adversely affect the portfolio. Coombs Wealth 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 Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
At no time will Coombs Wealth 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 Client investment management agreement. Please see Item 12 – Brokerage Practices.
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 sponsored plan or to roll over the assets to an Individual Retirement Accounts (“IRAs”), 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). In such instances, the Advisor will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. 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 Coombs Wealth will typically provide a variety of ongoing financial planning services to Clients, either as a component of its wealth management services or 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 will involve preparing a formal plan based on the Client’s financial goals and objectives. Planning encompasses one or more areas of need, including, but not limited to investment planning, retirement planning, personal savings, education savings and other areas of a Client’s financial situation.
A financial plan developed for 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.
Coombs Wealth 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 Client’s financial situation, observations, and recommendations. Plans are typically completed within six months of contract date, assuming all information and documents requested are provided promptly.
Financial planning 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 the 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.
Independent Managers Coombs Wealth will recommend that Clients utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the Client’s needs and objectives. In certain instances, the Client may be required to authorize and enter into an investment management agreement with the Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide its services. The Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with Clients investment objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client relationship. The Client, prior to entering into an agreement with an Independent Manager, will be provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures).
C. Client Account Management Prior to engaging Coombs Wealth to provide investment advisory services, each Client is required to enter into a wealth management agreement with the Advisor that defines the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: ●Establishing an Investment Strategy – Coombs Wealth in connection with the Client, will develop a strategy that seeks to achieve the Client’s investment goals and objectives.
●Asset Allocation – Coombs Wealth 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 – Coombs Wealth will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
●Investment Management and Supervision – Coombs Wealth will provide investment management and ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs Coombs Wealth does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Coombs Wealth.
E. Assets Under Management As of February 20, 2024, Coombs Wealth manages $ 145,253,997 in Client assets, $133,364,948 of which are managed on a discretionary basis, and $11,889,049 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor.