This Disclosure document is being offered to you by Wakefield Asset Management, LLLP (“Wakefield”, “WAM” or
“Firm”) about the investment advisory services we provide. It discloses information about our services and the
way those services are made available to you, the client.
Wakefield Asset Management, LLLP is a registered investment adviser with the U.S. Securities and Exchange
Commission (SEC) under the Investment Advisers Act of 1940 (Advisers Act). Wakefield was founded in 2003 and
is 100% employee owned. G. Todd Gervasini is the principal owner, Managing Partner, and Chief Investment
Officer of Wakefield.
We are committed to helping clients build, manage, and preserve their wealth. Our Firm provides services that
help clients to achieve their stated financial goals. We will offer an initial complimentary meeting upon our
discretion; however, investment advisory services are initiated only after you and WAM execute an Investment
Management Agreement.
INVESTMENT AND WEALTH MANAGEMENT AND SUPERVISION SERVICES
WAM furnishes discretionary and non-discretionary investment advisory services to individual and institutional
investors. In a discretionary relationship, WAM makes investment decisions for its clients based on a highly
disciplined and technologically advanced process for research, security selection, implementation, and
monitoring. Investors are permitted to impose restrictions on investing in certain securities or types of securities.
During personal discussions with clients, we determine the client’s objectives, time horizons, risk tolerance, and
liquidity needs. As appropriate, we also review a client’s prior investment history, as well as family composition
and background. Based on client needs, we develop a client’s personal profile and investment plan. We then
create and manage the client’s investments based on that policy and plan. It is the client’s obligation to notify us
immediately if circumstances have changed with respect to their goals.
Once we have determined the types of investments to be included in a client’s portfolio and have allocated the
assets, we provide ongoing investment review and management services.
With our discretionary relationship, we will make changes to the portfolio, as we deem appropriate, to meet client
financial objectives. We trade these portfolios based on the combination of our market views and client objectives,
using our investment process. We tailor our advisory services to meet the needs of our clients and seek to ensure
that your portfolio is managed in a manner consistent with those needs and objectives. Clients have the ability to
leave standing instructions with us to refrain from investing in particular industries or invest in limited amounts of
securities.
In all cases, clients have a direct and beneficial interest in their securities, rather than an undivided interest in a
pool of securities. We do have limited authority to direct the Custodian to deduct our investment advisory fees
from your accounts, but only with the appropriate written authorization from clients.
Where appropriate, we provide advice about any type of legacy position held in client portfolios. Typically, these
are assets that are ineligible to be custodied at our primary custodian. Clients will engage us to advise on certain
investment products that are not maintained at their primary custodian, such as variable life insurance, annuity
contracts, and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans).
To the extent requested by the client, WAM may recommend the services of other professionals for advice and
implementation of non-investment related matters such as estate planning, tax planning, banking matters,
insurance, etc. The client is under no obligation to engage the services of any recommended professional and
retains absolute discretion over the selection of professionals and the implementation of products they
recommend.
You are advised and are expected to understand that our past performance is not a guarantee of future results.
Certain market and economic risks exist that adversely affect an account’s performance. This could result in capital
losses in your account.
NON-DISCRETIONARY CONSULTING SERVICES
WAM also furnishes non-discretionary financial consulting services to individual and institutional investors. We
evaluate each investor’s financial circumstances, investment objectives and investable assets and recommend
investment strategies for implementation. The investor determines whether to implement such recommendations
and, if implemented, which service providers
will be used.
THIRD PARTY INVESTMENT & SUB-ADVISER SERVICES
WAM provides portfolio specific separate account management for accounts referred by Wakefield Wealth
Management, LLLP (WWM), or third-party investment advisers, brokers, and/or broker-dealers. Under these
programs, participating clients (generally with the assistance from the third-party investment adviser) may select
WAM to provide selected investment advisory services for their account. This may be only a portion of the client’s
overall investment portfolio. These accounts are managed according to the investment strategies described in
Item 8.
WAM provides sub-advisory services to clients of WWM, an affiliated investment adviser. The Assets under
Management reported below includes $342 million of discretionary assets and $479 million of assets under
advisement attributed to this sub-advisory relationship.
These assets are also reported on WWM’s Form ADV Part 2A.
WRAP FEE PROGRAMS
Our Firm does not sponsor a Wrap Fee Program.
WAM has agreements with various financial services firms (“Program Sponsors”) to provide investment advisory
services to managed accounts in programs sponsored or administered by these firms. These programs are
commonly referred to as Managed Account Programs or UMA or SMA programs. Under these programs,
participating clients (generally with assistance from the Program Sponsor) may select WAM to provide selected
investment advisory services for their account (or a portion thereof). The services WAM provides to Managed
Accounts may differ among the Managed Account Programs and may differ from the services provided to clients
who do not participate in Managed Account Programs. WAM generally receives a portion of the wrap fee charged
on these accounts for the services we provide. Please see further discussion of management fees under Item 5 –
Fees and Compensation.
For Managed Accounts, WAM is appointed to act as an investment adviser through a process administered by the
Program Sponsor. WAM will generally make its representatives available for communications as reasonably
requested by clients and or Program Sponsors. In the course of providing services to Managed Account Programs,
WAM may reasonably rely on information or directions communicated by the Program Sponsor acting with
apparent authority on behalf of its client. WAM reserves the right to decline to manage any account.
Clients should review all materials related to their Managed Account Program (including the wrap fee program
brochure of the Program Sponsor) including materials related to the terms, conditions, and fees. Each client should
evaluate the potential advantages, disadvantages, and overall appropriateness of the program in light of the
client’s particular circumstances. Clients are encouraged to consult their own financial advisers and legal and tax
professionals in connection with selecting and engaging the services of an investment adviser in a particular
strategy and participating in a Managed Account Program.
ASSETS
As of December 31, 2023
Market Value
(U.S. Dollars)
Discretionary Assets $342,823,141
Non-Discretionary Assets $271,802
Total Regulatory Asset Under Management $343,094,943
Assets Under Advisement $479,031,250
Total Assets Managed $822,126,193
“Discretionary Assets” are those accounts where the client has granted WAM authority, without any further
approval except as otherwise required by law, (a) to make all investment decisions for the account; (b) to buy, sell
and otherwise deal with the assets of the account; and (c) in furtherance of the foregoing, to do anything which
WAM deems requisite, appropriate or advisable, including, without limitation, the submission of instructions to
the custodian, if any, of the account.
“Non-Discretionary Assets” are those accounts where the client retains authority for approving the final
investment decisions. WAM provides advice to clients regarding these accounts but does not make independent
investment decisions.
“Assets Under Advisement” (AUA) include assets in Managed Account Programs where WAM provides model
investment portfolios. The program sponsor retains final discretion to implement the model strategy and performs
all trading and account administration. Also included in AUA are assets in qualified plans (retirement plans) where
WAM provides continuous and regular advice to the trustees of the plans regarding the selection of their vendors
including the selection of investment options available under the plan.