General Information
Compass Wealth Management, LLC was formed in 2011 and provides financial planning and portfolio
management services to its clients. At the outset of each client relationship, Compass spends time with
the client, asking questions, discussing the client's investment experience and financial circumstances,
and reviewing options for the client. Based on its reviews, Compass generally develops with each
client:
•a financial outline for the client based on the client's financial circumstances and goals, and the
client's risk tolerance level (the "Financial Profile"); and
•the client's investment objectives and guidelines (the "Investment Plan").
The Financial Profile is a reflection of the client's current financial picture and a look to the future goals
of the client. The Investment Plan outlines the types of investments Compass will make on behalf of
the client in order to meet those goals. The Profile and the Plan are discussed regularly with each
client, but are not necessarily written documents.
Financial Planning
Compass offers financial planning services to those clients in need of such service in conjunction with
Portfolio Management services. Compass's financial planning services normally address areas such as
general cash flow planning, retirement planning, and insurance analysis. The goal of this service is to
assess the financial circumstances of the client in order to more effectively develop the client's
Investment Plan. Financial Planning is not offered as a stand-alone service or for a separate fee, but is
typically provided in conjunction with the management of the portfolio.
Portfolio Management
As described above, at the beginning of a client relationship, Compass meets with the client, gathers
information, and performs research and analysis as necessary to develop the client's Investment Plan.
The Investment Plan will be updated from time to time when requested by the client, or when
determined to be necessary or advisable by Compass based on updates to the client's financial or
other circumstances.
To implement the client's Investment Plan, Compass will manage the client's investment portfolio on a
discretionary basis. As a discretionary investment adviser, Compass will have the authority to
supervise and direct the portfolio without prior consultation with the client.
Notwithstanding the foregoing, clients can impose certain written restrictions on Compass in the
management of their investment portfolios, such as prohibiting the inclusion of certain types of
investments (e.g., "sin stocks") in an investment portfolio or prohibiting the sale of certain investments
held in the account at the commencement of the relationship. Each client should note, however, that
restrictions imposed by a client may adversely affect the composition and performance of the client's
investment portfolio. Each client should also note that his or her investment portfolio is treated
individually by giving consideration to each purchase or sale for the client's account. For these and
other reasons, performance of client investment portfolios within the same investment objectives, goals
and/or risk tolerance differ and clients should not expect that the composition or performance of their
investment portfolios would necessarily be consistent with similar clients of Compass. Since our
investment strategies and advice are based on each client's
specific financial situation, the investment advice we provide to you may be different or conflicting with
the advice we give to other clients regarding the same security or investment.
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Educational Seminars/Workshops
Our Advisory Representatives may conduct financial education seminars or workshops on topics such
as estate planning, investment strategies, and retirement needs. We may partner with attorneys and
other professionals to offer these seminars. Seminar participants may subsequently choose to
participate in a complimentary initial consultation with us. The consultation will consist of a general
review of your financial situation, issues, and concerns. We will also explain the services we offer.
IRA Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field
Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's
Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the
following acknowledgment to you. When we provide investment advice to you regarding your
retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I
of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable,
which are laws governing retirement accounts. The way we make money creates some conflicts with
your interests, so we operate under a special rule that requires us to act in your best interest and not
put our interest ahead of yours. Under this special rule's provisions, we must:
•Meet a professional standard of care when making investment recommendations (give prudent
advice);
•Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest.
We benefit financially from the rollover of your assets from a retirement account to an account that we
manage or provide investment advice, because the assets increase our assets under management
and, in turn, our advisory fees. As a fiduciary,
we only recommend a rollover when we believe it is in
your best interest.
IRA Rollover Considerations
As part of our consulting and advisory services, we provide you recommendations and advice
concerning your employer retirement plan or other qualified retirement account. Our recommendations
may include you consider withdrawing the assets from your employer's retirement plan or other
qualified retirement account and roll the assets over to an individual retirement account ("IRA").
Further, we offer our management services be applied to those funds and securities rolled into an IRA
or other account for which we will receive compensation. If you elect to roll the assets to an IRA that is
subject to our management, we will charge you an asset based fee as described above under Item 5.
This practice presents a conflict of interest because persons providing investment advice have an
incentive to recommend a rollover to you for the purpose of generating fee based compensation rather
than solely based on your needs. You are under no obligation, contractually or otherwise, to complete
the rollover. Furthermore, if you do complete the rollover, you are under no obligation to have the
assets in an IRA managed by us.
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It is important for you to understand many employers permit former employees to keep their retirement
assets in their company plan. Also, current employees can sometimes move assets out of their
company plan before they retire or change jobs. In determining whether to complete the rollover to an
IRA, and to the extent the following options are available, you should consider the costs and benefits of
each.
An employee will typically have four options:
1. Leave the funds in your employer's (former employer's) plan.
2. Move the funds to a new employer's retirement plan.
3. Cash out and taking a taxable distribution from the plan.
4. Roll the funds into an IRA rollover account.
Each of these options has advantages and disadvantages and before making a change we encourage
you to speak with your CPA and/or tax attorney.
If you are considering rolling over your retirement funds to an IRA for us to manage it is important you
understand the following:
1. Determine whether the investment options in your employer's retirement plan address your
needs or whether you might want to consider other types of investments.
a. Employer retirement plans generally have a more limited investment menu than IRAs.
b. Employer retirement plans may have unique investment options not available to the public
such as employer securities, or previously closed funds.
2. Your current plan may have lower fees than our fees.
a. If you are interested in investing only in mutual funds, you should understand the cost
structure of the share classes available in your employer's retirement plan and how the costs
of those share classes compare with those available in an IRA.
b. You should understand the various products and services you might take advantage of at
an IRA provider and the costs of those products and services.
c. It is likely you will not be charged a management fee and will not receive ongoing asset
management services unless you elect to have such services. In the event your plan offers
asset management or model management, there may be a fee associated with the services
that is more or less than our asset management fee.
3. Our strategy may have higher risk than the option(s) provided to you in your plan.
4. Your current plan may offer financial advice, guidance, and/or model management or portfolio
options at no additional cost.
5. If you keep your assets titled in a 401k or retirement account, you could delay your required
minimum distribution beyond age 73.
6. Your 401k may offer more liability protection than a rollover IRA; each state may vary.
a. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA
assets have been generally protected from creditors in bankruptcies. However, there can be
some exceptions to the general rules so you should consult an attorney if you are concerned
about protecting your retirement plan assets from creditors.
7. You may be able to take out a loan on your 401k, but not from an IRA.
8. IRA assets can be accessed any time; however, distributions are subject to ordinary income tax
and may also be subject to a 10% early distribution penalty unless they
qualify for an exception such as disability, higher education expenses or the purchase of a home.
9. If you own company stock in your plan, you may be able to liquidate those shares at a lower
capital gains tax rate.
10. Your plan may allow you to hire us as the manager and keep the assets titled in the plan name.
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It is important that you understand the differences between these types of accounts and to decide
whether a rollover is best for you. If you elect to roll the assets to an IRA that is subject to our
management, we will charge you and asset based fee as described below in Item 5. Prior to
proceeding, if you have questions contact your investment adviser representative, or call our main
number as listed on the cover page of this brochure.
Principal Owners
Robert A. Amato is the sole owner of Compass. Please see Brochure Supplements, Appendix A, for
more information on Robert and other individuals who formulate investment advice and have direct
contact with clients, or have discretionary authority over client accounts.
Type and Value of Assets Currently Managed
As of February 4, 2024, Compass managed approximately $225,280,749 assets on a discretionary
basis. We do not offer asset management services on a non-discretionary basis.