This section of the brochure tells you about our business, including ownership and a description of
the services we offer.
Comprehensive Wealth Management, LLC is referred to in this document as “CWM”, “the
Company”, “us”, “we”, or “our”. In this document, we refer to current and prospective clients of
CWM as “you”, “client”, or “your”. CWM was created in 2001 and is owned by several holding
companies, FUPA, Inc., and B & S Lockett, Inc. FUPA, Inc. is owned and controlled by Morgan
Arford. B & S Lockett, Inc. is owned and controlled by Brian and Shilo Lockett.
Types of Advisory Services
proVest® Platform
All of our clients receive our investment advice through the proVest
®
Platform. CWM is the only
money manager in the proVest
®
Platform, that provides discretionary investment advisory
services, and is responsible for all investment decisions in your account. You authorize CWM to
manage your assets on a discretionary basis by purchasing and/or selling individual stocks, bonds,
money market instruments, money market funds, or other instruments as and when we see fit
without your approval of each transaction. In managing your account, we will employ various
investment strategies as described in the Investment Strategies section of this document and any
other material we may give to you. You grant us discretionary authority in the Investment
Advisory Agreement that you enter into with us and it will remain in full force and effect, even if
you become incompetent or disabled, unless revoked or terminated by you. We will collect
information about your investment objectives. We regularly inquire about, and you are
responsible for providing, information about your investment goals, time horizon, and risk
tolerance. You are encouraged to contact CWM directly at its home office shown on the first page
of this document. These investment supervisory services are generally not provided to all your
holdings or net worth but rather only to assets specifically designated by you and agreed to by us
as managed assets.
Advice on Matters Not Involving Securities
CWM from time-to-time provides advice on topics not involving securities. The fees for this advice
may be included as part of an assets under management billing agreement, hourly charges, or a
fixed fee agreement described in the written agreement between us. Non-securities-related advice
is only provided to you upon request and agreement between us. Not all clients receive this type of
advice.
Financial Planning
Some clients are provided a written plan that may include a personal balance sheet and certain
projections. Any reports, financial statement projections, and analyses are intended exclusively for
your use in developing and implementing your financial plan. In view of this limited purpose, the
statements should not be considered complete financial statements. CWM will not audit, review or
compile financial statements and, accordingly, we will not express an opinion or other form of
assurance on them, including the reasonableness of assumptions and other data on which any
prospective financial statements are based. It is likely that there will be material differences
between projected and actual results because events vary, and circumstances frequently do not
occur as expected.
Our analyses will be highly dependent on certain economic assumptions about the future.
Therefore, you should establish familiarity with historical data regarding key assumptions such as
inflation and investment rates of return, as well as an understanding of how significantly these
assumptions affect the results of our analyses. We may counsel you as to the consistency of your
assumptions with relevant historical data, but we will not express any assurance as to the
accuracy or reasonableness of your specific data and assumptions. You are ultimately responsible
for the assumptions and personal data upon which our procedures and projections are based. The
financial
plan assumptions and reports are primarily a tool to alert you to certain possibilities. The
reports are not intended to, nor do they provide any guarantee about future events including your
investment returns. The implementation of the plan is solely your responsibility.
The financial plans provided for some of our clients do not address all potential aspects of
financial planning. Typically, our plans address retirement planning, college funding, estate
planning, and risk management issues such as life, disability, and long-term care insurance are
typically addressed in every financial plan.
Types of Investments Used
We consider many different types of securities when formulating the investment advice we give to
you. If you come to us with existing investments, we evaluate them with respect to your financial
goals, risk tolerance, and investment time horizon. Depending upon your situation, your
account(s) managed by us may contain individual stocks, corporate and/or government bonds,
mutual funds, or exchange-traded funds (“ETFs”). In some situations, we may recommend that
real estate be part of your investment portfolio.
Tailored Services and Investment Restrictions
We attempt to tailor your investment portfolio to your situation as you have described it to us.
This is why it is so important that you let us know about changes to your financial situation, goals,
or investment time horizon. You may impose restrictions on investing in certain securities or
types of securities. You must clearly identify these restrictions in writing to CWM.
Potential Effect of the Company Paying Transaction Costs
On the proVest
®
Platform, we pay for costs associated with securities transactions and have the
full discretionary power to decide if and when a securities transaction is made. Because of this, we
have a financial incentive not to make securities transactions in your account, or choose securities
that won’t incur a transaction fee. Paying for securities transactions in your investment portfolio
creates a potential conflict of interest where we have the financial incentive not to make securities
transactions in your account when it is in your best interests to do so. The proVest
® Platform may
cost you more or less than purchasing such services separately.
Non-Transaction Fee (NTF) Mutual and Exchange Traded (ETF) Funds
When selecting investments for our clients’ portfolios we choose mutual and exchange-traded
funds (mutual funds) on your account custodian’s Non-Transaction Fee (NTF) list. This means
that your account custodian will not charge a transaction fee or commission associated with the
purchase or sale of the mutual fund.
The mutual fund companies that choose to participate in your custodians NTF fund program pay a
fee to be included in the NTF program. The fee that a mutual fund company pays to participate in
the program is ultimately borne by the owners of the mutual fund including clients of CWM.
As part of the proVest® program we pay for securities trading commissions for normal trades
made in your account, we have a financial incentive to select mutual funds on the NTF list. This
financial incentive creates a conflict of interest between you and us where our interests might not
be aligned. Specifically, we have the incentive to choose a mutual fund that does not incur trading
charges, which may result in the selection of a fund with a higher expense ratio. You, the owner of
the fund, ultimately pay the fee by way of the fee charged by the mutual fund.
Some mutual funds also impose a short-term redemption fee if the mutual fund is purchased and
then sold in less than a specified period (i.e. 180 days). You as the owner of the mutual fund will
bear the cost of the mutual fund’s redemption fee.
Assets Under Management
As of December 31, 2023, CWM manages approximately $288,264,741 of client assets, on a
discretionary basis and $10,322,681 of client assets on a non-discretionary basis.