A. General Description
Dynasty Wealth Management, LLC (“DWM” or “Registrant”) is an investment adviser registered
with the U.S. Securities and Exchange Commission (“SEC”) under the Investment Advisers Act
of 1940, as amended (the “Advisers Act’). Dynasty Financial Partners, LLC (herein the “Parent,”
“Dynasty”, or “Company”), is a financial services company that previously served as the
investment adviser and registrant prior to DWM. As a limited liability company formed on March
2, 2010, in the State of Delaware, the Parent became registered as an investment adviser with the
SEC on April 7, 2010. The Parent officially transferred its registration to DWM in March 2013.
As a privately-owned company, the Parent’s core business is to offer middle and back office
operational support services to a network of independent registered investment advisers in the
investment adviser community (each herein a “Network Adviser”). The Parent’s subsidiary, DWM
(and Registrant) operates the following distinct businesses: 1) Investment Management Platform,
and 2) Investment Programs/Model Portfolios/OCIO Services. Each business is described below.
This brochure provides important information about DWM, its services and compensation, the
costs of participation in its programs, and situations where conflicts exist between the interests of its
clients and the interests of the Company and Registrant. Clients should pay particular attention to
these conflicts of interest because they can affect certain aspects of DWM’s decision–making, in
recommending a custodian, choosing a broker-dealer for the account, and in making investment
recommendations among other important considerations.
B. Advisory Services Offered
Investment Management Platform
DWM sponsors an investment management platform (the “Platform”), also known as Dynasty
TAMP Services (a turnkey asset management program) (“TAMP” or “Program”) that is available
to the Network Advisers supported by the Parent. This Platform provides certain technology,
administrative, operations and advisory support services that allow Network Advisers to manage
their own portfolios and access independent third-party managers that provide discretionary
services in the form of traditional managed accounts and through investment models. Network
Advisers can allocate all or a portion of their client assets among the different independent
investment sub-managers in the Program. Network Advisers may also use the overlay management
feature of the TAMP by creating their own asset allocation model and underlying investments that
comprise the model. Through the overlay feature, trade orders are implemented, and periodic
rebalancing of the model is performed.
Network Advisers may engage DWM through a sub-advisory program agreement or Terms of
Service for TAMP Services, also referred to as the “Program Agreement,” to provide access to
unaffiliated investment sub-managers for their clients and other services. In this Program, DWM
is appointed as a sub-adviser to perform all or some of the services for program clients as specified
in the agreements with Network Advisers who participate in the Program. The Network Adviser
will have the direct contractual relationship with each of their clients. DWM engages unaffiliated
investment managers to perform discretionary investment management services and to manage,
invest and reinvest program client assets in the strategy as designated by the Network Adviser.
The Network Adviser delegates discretionary trading authority to DWM to effect investment and
reinvestment of program client assets with the ability to buy, sell or otherwise effect investment
transactions and or allocate client assets in the client’s name or for client accounts. DWM or the
designated manager, where applicable, is also authorized without prior consultation of the Network
Adviser or the client to buy, sell trade or allocate client assets in accordance with the client’s
designated portfolio model and to deliver instructions to the designated broker-dealer and or
custodian of client assets.
In providing investment advice and portfolio management services to clients, the Network Adviser
acts as an investment adviser and fiduciary to and on behalf of each client and not as an agent of
DWM. The Network Adviser maintains responsibility for the initial and ongoing client
relationship, including the initial and ongoing suitability determination. Network Advisers retain
the sole authority and responsibility for providing customized investment advice and portfolio
management services to clients and for implementing client investment recommendations in
accordance with the Network Adviser’s own judgement and exercise of investment discretion.
Network Advisers are responsible for obtaining and furnishing to DWM information pertaining to
client manager selection, account guidelines and applicable restrictions, which enable DWM to
perform applicable overlay services or other services.
Overlay or other services may include:
● Investment model administration
● Manager facilitation services
● Account administration, billing and reconciliation
● Account aggregation and reporting
● Client account reporting
● Business management reporting
● Technology services
● Proposal generation
Dynasty assesses a program fee, which covers Dynasty’s services in maintaining and administering
the program which can be paid by the Network Adviser or passed on to their client. The TAMP
platform facilitates both the provision of advisory services by DWM through the TAMP as well
as non-advisory accommodation services that allow Network Advisers to leverage the technology
to manage their own discretionary models and access third party managers not recommended by
DWM. The non-advisory accommodation services are more fully described in Item 10.
Investment Programs / Model Portfolios and OCIO Services
As noted above, the Parent (Dynasty) offers operational and back-office support to existing
independent registered investment advisers and investment advisers seeking to go independent
through third party service providers and additional services it provides directly to the investment
adviser. These services are typically funded through the fees charged by the investment adviser to
its clients. As part of these services to the investment adviser community, DWM provides the
investment advisers with access to a range of investment advisory services for use by advisers with
their clients, including Separately Managed Accounts (“SMA’s”), Unified Managed Accounts
(“UMA’s”), Model Management Overlay, (“MMO”), Fund Strategist Portfolios (“FSP”), Advisor
as Portfolio Manager (“APM"), Mutual fund and ETF models (“Model Select”), and Outsourced
Chief Investment Officer (“OCIO”) (each an “Investment Program” and collectively, the
“Investment Programs”). The Investment Programs are generally made available by Dynasty
(through DWM) to the independent advisers in the Dynasty Network (also referred to herein as
“Network Advisers”), who may recommend one or more Investment Programs to their clients. The
Network Adviser determines which services and Investment Programs of DWM to use with its
clients and may use the services of other third- party service providers in conjunction with the
Investment Programs. Clients of the Network Advisers should therefore consult the advisers’ Form
ADV Part 2A – Disclosure Brochure for a full description of that investment adviser’s specific
uses of the Investment Programs.
Fund Strategist Portfolios (“FSPs”)
In connection with the above Investment Program, Dynasty’s Investment Committee works
in conjunction with Envestnet PMC to create and make available Fund Strategist Portfolios
(“FSPs”) to the Network Advisers. These FSPs are offered in the form of investment models
(i.e., third-party models whereby DWM, in its capacity as a Model Provider constructs an
asset allocation and selects the underlying investments for each portfolio). DWM uses a
third-party provider to perform overlay management of the models by implementing trade
orders and periodically updating and rebalancing each model pursuant to DWM’s direction.
Capital Growth: The Capital Growth segment is designed to contain exposure to global
equity investments. Capital Growth investments are expected to be correlated to global
economic cycles. Investments in this segment typically include both domestic and
international allocations. Furthermore, the Capital Growth segment seeks to be an effective
hedge against long term inflation.
Opportunistic Income: The Income segment looks to provide current income to the
portfolio and serve to manage volatility. The income segment seeks to be a hedge against
deflationary environments. Income investments seek
to provide current income and
reasonable stability of principal. Investments in this segment are fixed income oriented and
include instruments across the credit quality spectrum as well as both domestic and non-US
exposures. The primary drivers of returns for Income investments include interest rates,
credit spreads, and global currency fluctuations.
Macro Thematic: The Macro Thematic segment is designed to provide global exposure to
both short-and long-term thematic ideas. It is constructed to be a diversified, absolute-
return strategy that provides alpha based on where we see opportunities in the market.
Dynasty Select: ETF Model Portfolios: The ETF models are intended for accounts where
investors seek an efficient and lower cost diversified asset allocation solution backed by
the same research as the aforementioned models. The ETF models allocate to a selection of
underlying ETFs selected based upon cost, trading volume and tracking error
characteristics.
Model Select
DWM is offering a series of multi-manager models with strategic allocations that reflect
DWM’s long-term strategic views, while allowing for tactical dynamic tilts in response to
changes in credit and market cycles. Investment vehicle selections will have a balance
between active and passive management in order to optimize and diversify the portfolio
while simultaneously keeping in mind cost and efficiency. These models will also leverage
Aladdin risk analytics tool, offered through BlackRock, Inc., to monitor portfolio risk and
manage the whole portfolio within a proprietary risk framework. There are 4 suites of
models:
Dynasty Managed Core
Dynasty Managed Core with Alts
Dynasty Managed Core Tax-Aware
Dynasty Long Horizon ETF
DWM has contracted with BlackRock Customer Solutions to construct the models and 55
Institutional Partners LLC to handle trading, rebalancing and tax management overlay.
Clients who participate in the DWM Managed Model Platform program shall also pay
advisory fees to certain independent third party managers who manage underlying client
assets on a sub-advisory basis. Fees paid to the independent third party managers are in
addition to the platform and administrative fees charged by DWM and the advisory fee
charged by your investment adviser as a Dynasty Network Adviser. Independent Manager
fees are billed and collected in the same manner as the DWM Administration Fee.
Advisory Firms that participate on the DWM advisory platform as third party sub-advisors,
strategists or model managers pay a fee to DWM to participate, which fee is in the form of
a marketing fee or revenue share as described below.
Conflict of Interest in Model Select
If any of the multi-manager models contain securities managed by FCF Advisors LLC
(“FCF”), a SEC registered investment adviser, a conflict of interest exists because DWM’s
affiliate has a revenue sharing agreement with FCF and will receive compensation from
being part of these models. In addition, as set forth in Item 10, DWM’s Parent (Dynasty)
has a minority, non-controlling ownership interest in FCF. The inclusion of any securities
managed by FCF into these models will be presented to the DWM Investment Committee
and voted on by its members.
DWM has a financial incentive to add these securities managed by FCF in the models and
direct Network Advisers to use these model(s) because of this relationship. This conflict is
partially mitigated by utilizing an unrelated third party software risk analytics tool, Aladdin,
to determine the weighted allocation percentages of the securities in these models. Under
no circumstances will DWM increase the weighted allocation percentage of the securities
managed by FCF that is determined by Aladdin and may decrease the allocation as
determined by the DWM Investment Committee.
As always, Network Advisers are free to choose any investment models, strategies, or
programs offered by DWM and are not required to participate in any regard.
ARK 10 Portfolio
ARK’s strategy aims for long-term capital growth by actively managing a concentrated
portfolio of public equity securities of companies that are relevant to the theme of
disruptive innovation. Holdings include what ARK believes are the leaders, enablers,
and beneficiaries of disruptive technologies. The strategy is benchmark agnostic. It invests
in companies across multiple sectors and geographies. Portfolios will include issuers
across all market capitalizations with low overlap to traditional broad market indices.
Outsourced Chief Investment Officer (“OCIO”) Program
DWM also offers customized portfolio solutions to investment advisers through its OCIO
program. DWM outsources investment management capabilities offered through its Dynasty
Investment Committee, in concert with research furnished by Envestnet PMC and iCapital.
The OCIO approach is designed, to address specific adviser needs through the
implementation of a customized approach. OCIO strategies may entail active or passive
management strategies with the goal of creating portfolios focused on asset protection and
growth of capital. Passive portfolios typically employ lower cost, passive ETFs, while active
portfolios typically employ active third-party investment strategies, as appropriate. Portfolios
are constructed, implemented and monitored through an institutional due diligence program.
Dynasty, on behalf of its subsidiaries and for the benefit of the Dynasty Network, has
established research and due diligence services working in concert with professional due
diligence firms (collectively the “Research Partners”). The Investment Committee is
responsible for evaluating and selecting the appropriate Research Partners. Research Partners
are selected based on their expertise in the area of sub-manager research and their ability to
provide diligence from an investment, operations, compliance and overall risk management
perspective. The Investment Committee leverages these relationships and resources in its
development of its investment guidance to the Dynasty Network.
For each sub-manager recommended by Dynasty, a member of the Investment Committee
or its Research Partners will typically perform all or some of the following:
● perform regular on-site visits
● meet with senior personal to assess organizational and management stability
● review due diligence protocols
● review quarterly work product; and
● discuss specific sub-manager activity
Due to the dynamic nature of Dynasty’s services and affiliations, different due diligence
methodologies may be employed. The level of due diligence and the responsible party for
such due diligence shall vary depending on the source/need for review and the investment
program/platform.
DWM and Research Partners review many factors, in addition to performance, of a
portfolio sub-manager before approval including but not limited to:
● Operational functionality
● Safety of client assets
● Investment Review
● Track Record
● Compliance
Once the appropriate topics have been reviewed, DWM makes the determination whether to
recommend the sub-manager or not.
Other Matters
Valuation: In the event that Dynasty references private investment funds owned by the client on
any supplemental account reports, the value(s) for all such private investment funds shall reflect
either the initial purchase and/or the most recent valuation provided by the fund sponsor. If the
valuation reflects the initial purchase price (and/or a value as of a previous date), the current
value(s) (to the extent ascertainable) may be significantly more or less than the original purchase
price.
Conflict of Interest in ETF Selection: As described in Item 10 below, DWM’s affiliate, Dynasty
Securities, LLC (“Dynasty Securities”), a limited use broker–dealer, has entered a revenue sharing
agreement with FCF by which Dynasty Securities will receive compensation in connection with
including FCF managed exchange traded funds (“ETFs”) in DWM’s TAMP, and OCIO program.
While DWM does not receive a higher management fee if FCF managed ETFs are included in
TAMP and OCIO portfolios, a conflict of interest exists in that DWM has an incentive to
recommend ETFs managed by FCF and/or include such ETFs in its Model Portfolios and OCIO
Services as its affiliate will receive a portion of the revenue FCF receives. Further, the FCF ETFs
may not be the lowest cost ETF’s available. The firm will include FCF ETFs only to the extent it
is appropriate given the investment strategy of the portfolio and that the FCF ETF selection
undergoes a due diligence process.
C. Assets Under Management
As of December 31, 2023, DWM had $916,787,822 in assets under management on a discretionary
basis.