Independent Solutions Wealth Management LLC, hereinafter referred to as “Independent
Solutions”, “we”, “us” or “Firm”, has been in business since 2008. The Firm is owned by Glenn
Wiggle, Michael Lomas and Big Time & Associates (Daniel Neiman is the sole owner of Big Time
& Associates), each of whom retain more than 25% ownership interest in the Firm. We provide
various types of investment advice and related financial services for individuals and businesses,
based upon the investment objectives of the particular client. We offer our investment advisory
services on both a discretionary and non-discretionary basis. If we are engaged on a non-
discretionary basis, you are under no obligation to act upon any of our recommendations or to
implement those recommendations through Independent Solutions. If we are engaged on a
discretionary basis and a client wishes to impose restrictions on investments by specific security
or asset class, the client may do so in writing.
Depending upon your circumstances and desired services, our investment management services
are primarily offered through the following asset management options:
(1) Mutual Fund Portfolio Management (selecting and managing a portfolio of mutual
funds);
(2) Exchange Traded Fund (ETF) Portfolio Management (selecting and managing a
portfolio of exchange traded funds
(3) Stock Portfolio Management (selecting and managing a portfolio of individual
securities;
(4) Third-Party Manager Selection (selecting one of more third-party managers for your
account);
(5) Financial Plans and Third-Party Financial Plans (consulting services including
financial analyses and development of long-term strategies);
(6) Tactical Portfolio Management (selecting and managing actively traded portfolios
using primarily ETFs, mutual funds and/or individual securities); and/or
(7) Small Account Models.
Mutual Fund Portfolio Management
You may engage us to provide diversified portfolio management. In that case, depending on your
personal financial situation, we may recommend that you invest in accordance with one or more
of our mutual fund portfolios. We have developed a number of portfolios which may include
limited partnerships and/or other non-traditional asset classes. All portfolios are based upon asset
allocation and diversification principles paired with a client’s specific risk tolerance. Management
of these portfolios is generally delegated to third-party money managers that have been subjected
to an in-house due diligence review prior to being included on our list of “Best in Breed Money
Managers.”
The first step we take in determining our list of “Best in Breed Money Managers” is to establish
an asset allocation model for portfolio offered. Each model is designed to adhere to one of the
widely recognized broad asset allocation classifications which are:
i. very conservative
ii. conservative
iii. moderate
iv. moderate aggressive
v. very aggressive
After determining the broad asset classes, we next determine the more detailed allocations using
categories from large cap growth and value to international real estate. In most cases, we use at
least eight sub-asset classes in each portfolio. We then break down the available mutual funds into
these sub-asset classes. By doing so we are able to compare various fund managers’ styles and
performance to other managers who are buying the same types of investments. By following these
specific research procedures, we are able to identify our “Best in Breed Money Managers.”
We re-evaluate the managers on a monthly basis in order to determine whether our managers are
still performing according to our criteria. If we are concerned about the performance of one of our
managers, that manager will be placed on probation and tracked on a monthly basis. If we
determine that the manager is solidly performing, then the manager will likely stay on our list of
managers. If we determine that the underperformance is due to a manager change, a shift in
investment policy, poor security selection or other factors, the manager may be replaced.
The last step in our approach is portfolio review. We will review, on a semi-annual basis, the
clients’ portfolio allocations in relation to their model allocation. If warranted, we will rebalance
at that semi-annual review. In certain cases, based on market conditions or possibly in the event of
a manager change, we may rebalance more frequently or less frequently than semi-annually.
Exchange Traded Fund (ETF) Portfolio Management
You may engage us to provide Exchange Traded Fund (ETF) Portfolio Management services to
you. In that case, depending on your personal financial situation, we may recommend that you
invest in one or more ETF portfolios. We manage our ETF portfolios in a manner similar to our
management of mutual fund portfolios. An ETF is a security that tracks an index, a commodity or
a basket of assets like an index fund, but trades like a stock on an exchange, thus experiencing
price changes throughout the day as it is bought and sold. We use our research capabilities to allow
us to compare performance and cost of funds that track the same or similar indexes to determine
the “Peer Group Outperformers.” The indexes used follow the same broad asset allocations as
previously referenced in the mutual fund description above.
By taking these “Peer Group Outperformers” and using them in more specific, detailed asset
classes, we form our ETF Portfolios. The same ongoing management we instill in our mutual fund
portfolios carries over to our ETF Portfolios, namely re-applying research on a monthly basis and
re-balancing semi-annually if necessary.
Stock Portfolio Management
If you are interested in investing in individual securities, we may recommend our Stock Portfolio
Management services using a portfolio of individual stocks, bonds or other types of securities.
Because our Stock Portfolio Management involves more active trading and a higher degree of risk,
this is not a suitable investment for every client. Stocks held in the account are closely monitored,
typically on a daily basis, and may involve short-term trading activities. Generally, we do not take
into consideration the income tax effects of purchases and sales of securities held in the account.
Clients may be subject to additional fees/expenses, such as ticket charges or asset-based pricing,
which could be charged by the clearing firm executing the actual securities trades. We require a
minimum account balance of $100,000 for clients who elect to use our Stock Portfolio
Management services. We may waive this requirement for any reason including, but not limited
to, a client having additional or related accounts under our management that in aggregate meet or
exceed our account minimum requirements.
Third-Party Manager Selection
You may engage us to evaluate, select, utilize and monitor the investment performance of
independent investment managers (“Third-Party Managers”). Third-Party Managers may offer
specialized expertise and experience in specific asset classes and, by retaining their services, you
may achieve greater diversity in your investment portfolio and strategies.
We will obtain and provide you with information about Third-Party Managers, including their
disclosure brochure, Form ADV Part 2. You may, however, be subject to any minimum account
sizes or other conditions which could be imposed by a Third-Party Manager. Generally, though,
we may be able to obtain exceptions from those conditions for our clients. Upon selecting a Third-
Party Manager, clients then directly engage that Third-Party Manager using its respective client
services agreement. Clients are billed for that advisor’s fees and charges which are disclosed in
the advisor’s Form ADV Part 2 and advisory agreement.
On an ongoing basis, Independent Solutions will monitor and periodically report to you on the
Third-Party Manager’s performance with respect to your assets under that advisor’s management
but is not responsible for the manager’s actions, omissions or performance. Our responsibility is
limited to initially evaluating and recommending suitable managers for your account based upon
reasonably available information at the time of that manager’s engagement and periodically
reporting on the manager’s investment performance for your account. We will perform an initial
limited background investigation on each manager, based in large part upon the information
provided to us by the advisor and public sources of information. We may from time to time update
our limited background check on a manager if known changes in the advisor’s circumstances
warrant.
Generally, Independent Solutions does not receive any compensation from a Third-Party Manager
for referring our clients to them. Should we elect to change this policy, our clients will receive a
copy of the Material Changes section of this Brochure which will outline the nature of the referral,
our referral relationship with Third-Party Managers and the referral compensation we would
receive.
If you terminate your relationship with Independent Solutions, you may be able to continue using
the Third-Party Manager, at the discretion of you and the respective Third-Party Manager
utilized.
Independent Solutions, however, will have no continuing responsibilities after our termination
with respect to your account or the manager.
Financial Plans and Third-Party Financial Plans
You may engage Independent Solutions or a Third-Party Manager to develop a formalized
financial plan and corresponding asset management recommendations consistent with your
financial objectives which will serve as a “road map” with which you can make and evaluate your
management decisions. These services may entail separate but additional fees from standard asset
management fees. Generally, these fees may be negotiable or waived, as can any requirement to
implement recommendations with the party developing the plan.
Tactical Portfolio Management
While most of our investment strategies involve strategic asset allocation, we do offer a tactical
models. The tactical model has the ability to hold cash/money market, long and/or short market
positions for varying periods of time depending on market conditions. The Firm will typically use
index funds or ETFs as primary account holdings, however.
The tactical portfolio may also at times use leveraged ETFs. These types of ETFs use financial
derivatives and debt instruments to magnify for its investors the returns of the underlying
respective indexes they track (i.e. Dow Jones Industrial Average, Nasdaq-100, etc.). They seek to
maintain a constant amount of leverage, such as 2:1 or 3:1, over the timeframe that assets are
invested in them. For example, in a 2:1 leveraged ETF every $1 of investor funds is matched with
an additional $1 of invested debt. As a result, if that leveraged fund’s benchmark index returns
1% then the fund would show a 2% gross return. That 2% gross would be reduced by management
fees and transaction costs to yield a net return of less than the 2%. Conversely, if the index drops
by 1%, the fund would show a gross loss of 2%.
Small Account Models
Independent Solutions also offers small account models for the convenience of our clients and
advisors/solicitors to allow clients to consolidate assets as they grow their portfolios to the minimal
balances which may be required for other management options. This option is provided through
the direct investment of individual client assets in select mutual funds, including the Neiman Large
Cap Value Fund. Clients are allowed to purchase shares in these funds on a load-waived basis. In
addition, since Independent Solutions and Neiman Funds Management LLC have mutual owners,
our Firm’s standard investment advisory fee is waived as well.
To qualify for smaller account models, clients need to have other accounts at Independent
Solutions where the total of all accounts invested with us for their households is at least $50,000
in total assets. Under some circumstances, Independent Solutions may waive this requirement at
its discretion. Small account portfolios require a minimum of $3000 initial investment to establish
the portfolio. Once the account value reaches $50,000 by either additional contributions or market
appreciation, we require a transition into one of our standard portfolio management options, with
all related fees applicable to the portfolio selected. This requirement may also be waived at the
discretion of the Firm.
While the Firm may elect to waive some fees for its small accounts, clients introduced to
Independent Solutions through a solicitor for our Firm may charge a separate solicitor fee of up to
2.50% of assets invested in these funds. More detail on this point is disclosed later in Item 10 of
this document. While we will bill and collect these fees from our clients, Independent Solutions
does not share in any portion of these solicitor fees.
Types of Investments
We offer advice about a wide variety of investment types, including individual stocks, mutual
funds, index funds, exchange-traded funds, and fixed and variable annuities. With respect to these
investments, you should be aware of the following:
Mutual Funds, Index Funds and Exchange-Traded Funds: Mutual funds of all types charge
their shareholders various advisory fees and expenses associated with the establishment and
operation of the funds. These fees and expenses are described in each fund’s prospectus. These
fees will generally include a management fee, shareholder servicing, other fund expenses, and
sometimes a distribution fee. If the fund also imposes sales charges, you may pay an initial or
deferred sales charge. These separate mutual fund fees are disclosed in each fund’s current
prospectus, which is available from the mutual fund and, upon request, can be provided by our
firm.
Consequently, for any type of mutual fund investment, it is important for you to understand that
you are directly and indirectly paying two levels of advisory fees and expenses: one layer of fees
at the fund level and one layer of advisory fees and expenses to us. Generally speaking, most
mutual funds may be purchased directly, without using our services, without incurring our advisory
fees. Moreover, many mutual funds pay shareholder servicing fees (12b-1 fees) to brokerage firms
in consideration of their services to the fund’s shareholders.
Most mutual funds offer several “classes” of their shares which may be purchased by different
types of investors or investors with different investment objectives. These are also described in
the mutual funds’ prospectuses. Depending on your investable assets, investment objectives, and
time horizon, different classes may be more appropriate for your circumstances. In most cases,
Independent Solutions purchases funds that are load-waived or no-load funds to save expenses for
the client. We would be happy to discuss the benefits and alternatives with you if you desire.
Variable Annuities: Variable annuities are highly complex financial products offered by
insurance companies. Your investment in a variable annuity contract is subject to both general
market risk and the insurance company’s credit risk. These and other risks are described in the
variable annuities’ prospectuses. Variable annuities are regulated under both securities and
insurance laws and related rules and regulations. Variable annuities offer various benefits and
features which may or may not have value to you depending on your circumstances and we would
be pleased to discuss them with you. Like other types of investments, commissions are paid for
the purchase of variable annuities and there may be substantial surrender charges. These
commissions, surrender charges and other expenses are disclosed in the prospectus.
Like mutual funds, insurance companies charge a variety of fees and charges against the assets
invested in the separate accounts of their policy holders. As noted above, this means that there are
two layers of advisory fees incurred – one layer by the insurance company and one layer to our
firm for our advisory services.
Private Placements: Publicly-traded companies often seek to raise capital through the offering
of unregistered securities of stock, bonds or warrants to a limited number of qualified or accredited
investors, as defined by the SEC. These offerings are handled outside normal public market trading
venues by select brokers or advisors and are referred to as private placements. Effective in 2021,
Independent Solutions offers to serve as a private placement broker for accredited clients of the
Firm.
Account Minimums and Criteria
Our minimum account size varies depending on the type of model and portfolio and ranges from
$3,000 up to $100,000. We may waive minimum account requirements for any reason including,
but not limited to a client that has additional or related accounts that together exceed the minimum
requirements.
Also, certain Third-Party Manager(s) may impose more restrictive account requirements. In such
instances, we may alter our corresponding account requirements to accommodate those of the
Third-Party Manager(s).
Other Firm Information
As of December 31, 2023, the Firm’s total assets under management for advisory clients was
approximately $953,830,582 within 5,873 advisory client accounts. All assets under the Firm’s
direct management as of that date were being managed on a discretionary basis only.
Clients of Independent Solutions may elect to utilize the services of Plan Confidence, an unrelated
independent registered investment advisory firm which may provide qualified retirement plan
allocation advice to clients of our Firm through an on-line venue. For clients utilizing their services,
our Firm acts only in the capacity of a co-advisor with Plan Confidence and will execute Plan
Confidence’s recommendations for clients on a non-discretionary basis. Plan Confidence charges
each client’s monthly fee for their service directly to the client’s credit card and remits a portion
of this charge to Independent Solutions. Clients hold the ability to engage or terminate their
relationship with Plan Confidence directly on-line at any time, without Independent Solutions’
involvement.
At this time, Independent Solutions does not participate in any wrap fee programs but may serve
as asset manager for advisory assets held by its clients in outside wrap programs.