Registration Status – Registered with the SEC (Securities and Exchange Commission)
in January
20101
Owners – Kirk M. Ludwig
Matthew F. Taddei
Diane McCracken
Meghan M. Hyland
Nicholas F. Safrit
Assets Under Management – Discretionary Assets – $ 577,162,361
(as of December 31, 2023) Non-discretionary Assets- $11,6,02,156
Total Assets - $ 588,764,546
Assets Under Administration – $ 303,391,752 (as of December 31, 2023)
ADVISORY SERVICES
WestHill Financial Advisors, Inc. (hereafter, “WH” the “Firm” or “Advisor”) is an independent
registered investment adviso
r2 providing personalized confidential financial planning, financial
consulting and investment management services to individuals, trusts, estates, small- to mid-size
businesses, non-profits, and endowments. In addition, the Firm provides comprehensive
investment management and pension consulting services to pension and profit-sharing plans,
defined benefit plans and non-qualified plans.
Depending upon the nature of the engagement, our services include, among others, financial
goal setting, risk assessment, strategic asset allocation and the selection and management of
securities and investments, cash flow management, tax planning, insurance review, investment
management, education funding, retirement planning, and estate planning. We offer our services
on both a discretionary basis or when appropriate for specialized assets, on a nondiscretionary
basis.
Typically, WH’s individually managed clients retain the Firm to provide comprehensive financial
planning and investment management services in a single engagement. We do offer separate
financial planning, financial consulting and/or investment management services on a stand-
alone basis in which case the client will execute an agreement restricted to those specific services
required.
Fiduciary Status
When WH provides investment advice to you regarding your investment accounts, including your
retirement plan account or individual retirement account, we are fiduciaries within the meaning
of certain state and federal laws such as the Employee Retirement Income Security Act and/or
the Internal Revenue Code and the regulations of the U.S. Securities and Exchange Commission,
as applicable. These regulations require us to act in your best interest and not put our interests
ahead of yours.
1 WestHill Financial Advisors, Inc., (WH) was founded in 1989, incorporated in 2007 and previously offered
advisory services as Taddei, Ludwig & Associates, Inc. (2010-2020) and Cambridge Investment Research Inc.
(2007-2010) and AXA Advisors (1989-2007).
2 “Registration” means only that the Firm meets the minimum requirements for registration as an investment
advisor and does not imply a certain level of skill or training or that the SEC or other regulator guarantees the
quality of our services or recommends them.
FINANCIAL PLANNING AND FINANCIAL CONSULTING SERVICES
WH provides comprehensive financial planning or project-specific financial consultations services
on either a fixed fee basis or an hourly fee basis. WH’s financial planning/consulting services may
include a financial review and analysis of some or all of the following areas:
• Determining Current Net Worth
• Determining Financial Goals and Objectives
• Cash Flow Management Review
• Review of Current Investments and Asset Allocation Review
• Cost Audit of Current Investments
• Strategic Tax Analysis
• Retirement Plan Analysis
• Estate Plan Review or Development
• Review of Insurance Needs
• Education Funding Analysis
• Compensation benefits analysis of company options, warrants, restricted stock
• Major Purchase Analysis Mortgage and Refinance Evaluation
• Charitable (or social capital) Planning
• Opinion on Current Investment Strategy/Advisors
• Other financial or investment analysis
Detailed investment advice and specific recommendations are provided as part of a financial
plan. Implementation of any financial plan or investment strategy recommendations is at the
client's discretion. After delivery of a financial plan, future face-to-face meetings may be
scheduled as necessary for up to six months. Follow-up implementation of financial plan
recommendations is billed separately at the Firm’s current rate.
In performing its services, WH is not required to verify any information received from the client or
from the client’s other professionals (e.g., attorney, accountant, etc.) and is authorized to rely on
such information as provided. Clients must promptly notify us of any change in their financial
situation or investment objectives that would necessitate a review or revision by our advisors of the
client’s portfolio and/or financial plan.
INVESTMENT MANAGEMENT SERVICES
Our investment management services are tailored to each client’s specific risk tolerance, time
horizon, liquidity requirements, and resilience to market volatility. While we strive to create
sustainable long-term investment strategies, we review and adjust asset allocations and risk
exposure as required by changes in market and client circumstances. The Firm’s portfolio manager
gathers information about each client’s individual financial condition and investment goals
through personal consultations, questionnaires, and document review. On the basis of this
information, the Firm designs an individualized asset allocation strategy based on a client’s
earning capacity, savings, investment history, tax issues, retirement horizon, education and legacy
planning, and any other matters that a client deems important.
Depending upon the client’s preferences, we offer the following investment management services:
• Creation of an asset allocation strategy;
• Recommendation of specific securities for investment;
• Execution of securities transactions on behalf of clients through designated custodians and
executing broker-dealers;
• Monitoring and rebalancing client account holdings; and
• Periodic account performance reporting.
A client may make additions to and withdrawals from the client’s custodial account at any time,
subject to the Firm’s right to terminate an account if the amount of assets drops below our
account size minimum. Clients may withdraw account assets with notice to the Firm, subject to
the usual and customary securities settlement procedures. However, we design client portfolios as
long-term investments and caution our clients that asset withdrawals may impair the achievement
of the client’s investment objectives.
Additions to an account may be in cash or securities provided that our portfolio managers may
decline to accept particular securities into a client’s account or may recommend that the security be
liquidated if it is inconsistent with the Firm’s investment strategy or the client’s investment
objectives. Clients are advised that when transferred securities are liquidated, they may be
subject to transaction fees, fees assessed at the mutual fund level (i.e. contingent deferred sales
charge) and/or tax ramifications.
Unless provided in connection with the financial planning services described above, clients
engaging WH to provide investment management services will generally be required to enter into
a separate written agreement with WH setting forth the terms and conditions of the engagement
and describing the scope of the services to be provided.
Advisor Does Not Provide Comprehensive Tax or Accounting Services
In providing investment management services, WH’s decisions and recommendations may
include the consideration of the possible alternative tax consequences incidental to such
decisions and recommendations. However, the Firm does not undertake to provide
comprehensive tax or accounting services. Although we may prepare reports to assist our clients
with the preparation of tax returns, such reports do not represent the advice or approval of tax
professionals. We advise clients to consult a tax professional in order to determine the tax and
accounting consequences of investments in their accounts.
BUSINESS CONSULTING SERVICES
WH consults with business owners on areas of their business such as key employee retention,
succession planning, legacy planning, how to transition the business to family or key employees
and how to protect the business against the risk of the owner’s premature death or disability. WH
also provides financial and insurance consultation for family law attorneys and individuals in pre-
divorce, trial, and post-divorce situations. Scope of services includes financial modeling and
projections, analysis and advice on life, disability, and long-term care insurance, and general
financial planning advice.
PENSION AND PROFIT-SHARING PLAN AND PENSION CONSULTING SERVICES
WH provides comprehensive qualified and non-qualified retirement plan consulting, investment
advice and fiduciary due diligence services, employee and investment education, asset
allocation services, plan service provider proposal and vendor research and analysis, and plan
design guidance to individuals, qualified and non-qualified retirement plan sponsors, and business
entities. We offer pension consulting services and investment management services designed to
assist plan sponsors in meeting their management and fiduciary obligations to participants under
the Employee Retirement Income Securities Act (“ERISA”) under either Section 3(21) of ERISA or
Section 3(38) of ERISA. Pursuant to adopted regulations of the U.S. Department of Labor under
ERISA Section 408(b)(2), we provide the plan representative(the person who has the authority to
engage us as an investment adviser to the plan) with a written statement of the services we
provide, the compensation we receive for providing those services, and our status as either a 3(21)
or 3(38) fiduciary.
Employer Sponsored Plan Services include:
Investment Advice (Plan Level)
WH provides research and analysis with regard to investment advice and fiduciary due
diligence services for the client plan. We also provide research and analysis that covers the
investment products of several qualified and non-qualified retirement plan providers. The goal of
the investment due diligence process is to establish a logical, technical, and comprehensive
process that is consistently employed in the selection and ongoing monitoring of funds for plan
sponsors and individuals, accompanied by an investment policy statement (for plan sponsors
only), that defines
the process utilized to recommend the investments to plan sponsors and
individuals.
The Firm may employ many different calculations, processes, and screening techniques to
arrive at specific recommended individual investments within the array of investments offered
by each investment provider that is being analyzed, including but not limited to the following:
• Investment analysis by asset class (domestic equity, international equity, income,
hybrid/managed accounts), including market capitalization (small, medium, and large),
and investment objective (value, blend, and growth orientation);
• Performance relative to other investments in the same asset class;
• Investment performance relative to benchmark performance for the same asset class;
• Percentile ranking of investment performance for the same asset class;
• Style-based analysis to determine the impact of an investment being managed differently
than its stated investment objective (which is usually a combination of the stated market
capitalization category and investment objective category);
• Macro screens to eliminate long term underperforming investments, funds with total
managed assets of less than the minimum threshold deemed to be adequate by WH;
• Review of Upside and Downside capture, to estimate upside potential and downside risk
of each investment;
• Common objective risk and return statistical measurements, such as Sharpe ratio, Treynor
ratio, standard deviation, alpha, and betas;
• Common statistically relevant manager value measurements such as information ratio and
tracking error;
• R-squared, correlation coefficients, and other statistically relevant information;
• Short- and long-term historical analysis with any of the above measurements;
• Financial strength, stability, and reputation of the investment provider, and individual
investments offered by and through the investment provider;
• Tenure and experience of investment management personnel;
• Investment philosophy, process, and style; and
• Investment fees.
The Firm evaluates the client’s existing Investment Policy Statement and provides
recommendations that are consistent with the client’s fiduciary obligations, if applicable,
under ERISA Section 404(c).
Employee (Participant) Investment Education. WH provides group employee enrollment, re-
enrollment, and investment education support. The goal of this process is to help employees
make educated and informed choices about the plan and investment allocation under the
investment education guidelines set forth by the U.S. Department of Labor. Meetings are
offered on an annual, semi-annual, quarterly, or as requested.
Employee (Participant) Investment Advice and/or Asset Allocation Models. WH assists plan
participants in finding the asset mix which is most likely to meet their investment objectives
within acceptable risk parameters. Asset class sub-types can include domestic large cap
value equity, domestic large cap growth equity, domestic mid-cap value equity, domestic
mid-cap growth equity, domestic small cap value equity, domestic small cap growth equity,
international equity, core fixed income, short term fixed income, high yield fixed income,
and other appropriate asset classes and investments.
Qualified/ Non-Qualified Plan Design Review. The Firm provides in-depth plan reviews that
include an analysis of relevant design features, including: age and length of service eligibility
requirements; vesting; forfeitures; employer matching contribution formulas; entry and re-entry
dates; and other pertinent design features.
Qualified/Non-Qualified Retirement Plan Proposal Vendor Research and Analysis. WH assists
clients with the selection of a plan provider, or providers based on detailed research and
analysis of several vendors. The vendor review process includes an evaluation of
administrative, recordkeeping, compliance, and employee communications services,
administrative and investment-related fees, and an investment overview that incorporates a
very similar analysis to the investment due diligence process described above.
Newsletters. Periodic employer newsletters may include industry and marketplace updates,
plan design and compliance suggestions, and legislative updates.
Management of Conversion Process. WH offers to help facilitate plan conversion. Included in
this process is providing sample letters and correspondence related to the plan conversion and
monitoring the action items identified in the Plan Sponsor Conversion Checklist.
Fiduciary Plan Review. The Fiduciary Plan Review™ includes a compliance checklist, plan
design analysis, and other related analysis designed to address plan compliance and
efficiency. This document typically includes a list of action items and suggestions, based on
plan demographics and a discussion between the client’s plan fiduciaries and any 401(k)
advisors.
404(c) Audit. WH provides a comprehensive checklist of the latest industry accepted
standards with respect to 404(c) compliance and works with each client to facilitate
completion of the checklist. The responsible party for addressing and verifying each item will
either be the plan provider, the client, or in some instances WH will provide the research and
analysis.
Fiduciary Role under ERISA. For those services stated under Investment Advice (Plan Level), WH
acknowledges that it is a fiduciary with respect to the Plan under Section 3(21)(A)(ii) of ERISA
as amended and, as such, is a co- fiduciary with the trustees(s) of the client’s plan solely with
respect to (a) the provision of investment education to the employer and/or plan participants
(depending on the specific advisory services provided); (b)the periodic reporting on, and
analysis of, the investment options available under the plan; and (c) the provision of advice
to the trustee(s) regarding the elimination or addition of investment options available under
the plan; provided, however, that the trustee(s) acknowledge and agree that the trustee(s)
have the final and conclusive responsibility for the investment options selected to be available
under the plan. WH is not responsible for investment decisions made by the plan participants
with respect to the investment of their accounts.
Reports to Client. For those services stated under Employee (Participant) Investment
Education, Employee (Participant) Investment Advice, and Other Investment Advisory Services
(Third Party Money Managers) based on the results of the periodic (quarterly or semi- annual)
analysis, WH may recommend changes to the core group of investment recommendations
offered by one or more of the investment managers included in the analysis. As such, WH will
provide plan fiduciaries with a periodic report that includes fund rankings in each category.
Custody of Plan and Participant Assets. All assets in Client’s account shall be held for
safekeeping with a designated custodian as selected by the Client. WH shall not act as
Custodian for any assets in the Client’s account and shall not take possession of cash and/or
securities of the Client’s account. WH shall not be liable to Client for any act, conduct or
omission by Custodian. WH is only authorized or empowered to issue instructions to Custodian
or to request information about the Account from Custodian for the limited purpose of
managing the asset allocation of the Models. WH has no other discretion or control in regard
to Custodian instructions.
SELECTION OF OTHER ADVISERS / USE OF INDEPDENDENT MANAGERS
WH may recommend that a client utilize one or more unaffiliated investment managers or
investment platforms (collectively “Independent Managers”) available through Schwab, for all or
apportion of a client’s investment portfolio, based on the client’s needs and objectives. (See
additional information in Item 8, below.) In such instances, the client may be required to authorize
and enter into an investment management agreement with an Independent Manager that defines
the terms in which Schwab and/or the Independent Manager will provide its services. WH will
perform initial and ongoing oversight and due diligence over each Independent Manager to ensure
the strategy remains aligned with client’s investment objectives and overall best interests. WH will
also assist the client in the development of the initial policy recommendations and managing the
ongoing client relationship. WH will offer discretionary services and may assist in the selection of
investment managers or investment platforms without the client’s permission. The client, prior to
entering into an agreement with an Investment Manager or investment platform, will be provided
with the Independent Manager's Form ADV 2A (or a brochure that makes the appropriate
disclosures).
TERMINATION OF AGREEMENT
Clients or the Firm may terminate the relationship upon written notice to the other party. The Firm
does not assess any fees related to termination but will be entitled to all management fees earned
up to the date of termination. Any earned investment management fees owed to the Firm will be
billed to the client, or where authorized, deducted from the client’s account, on a pro rata basis
determined on the amount of time expired in the billing period. Any unearned prepaid
management fees will be refunded to the client. Any unearned prepaid financial planning or
financial consultation fees will be refunded to the client. Any unpaid financial planning or
consultation fees will be billed to the client for immediate payment or deducted from the client’s
retainer.
WH reserves the right to stop work on any account that is more than 60 days overdue. In addition,
WH reserves the right to terminate any financial planning engagement where a client has willfully
concealed or has refused to provide pertinent information about financial situations when
necessary and appropriate, in WH’s judgment, to providing proper financial advice. Any unused
portion of fees collected in advance will be refunded within 60 days.
For new clients of the Firm, if a copy of this Form ADV Part 2A disclosure statement was not
delivered to the client 48 hours or more before the client enters into a written advisory contract
with Advisor, then the client has the right to terminate the contract without penalty within five (5)
business days after entering into the contract. A contract is considered entered into when all
parties to the contract have signed the contract. If the client terminates the contract on this basis, all
fees paid by the client will be refunded however, any transaction costs imposed by an executing
broker or custodian for establishing the custodial account or for trades occurring during those five
days are non-refundable.