NWM is registered with the U.S. Securities and Exchange Commission (“SEC”) and makes counseling, including
financial planning, investment management and retirement plan advisory services available to a wide variety
of clients. NWM has been registered as an investment adviser since 2010. NWM is wholly owned by
Northwest Financial Corp. Northwest Financial Corp. is owned by Dwight Conover and Cornelius B. Conover IV.
NWM does not control any other firm.
As of December 31, 2023, NWM managed $717,763,545 on a discretionary basis, $0 on a non-discretionary
basis and advised on $85,667,950 of self-directed retirement account assets.
NWM’s Investment Adviser Representatives, Wealth Advisors, and Personal Banking Specialists (herein NWM
Representatives) begin each advisory service by carefully examining the client’s investment objectives and
financial circumstances. During this stage, time is taken to educate clients about the various features of
different types of NWM counseling or investment management services that would benefit the client. Clients
are also informed about investment alternatives and investment risks to make them aware that attempting to
attain a higher rate of return entails accepting higher levels of risk and the potential for loss. Once this initial
evaluation is complete, NWM Representatives recommend one or more of the advisory services described
below that will be provided in a manner aimed at achieving the Client’s investment or other objectives. Clients
are free to contact their NWM Representative at any time.
Wealth Management Services
NWM offers clients portfolio management and reporting services by means of its Wealth Management
Services program. Through the program, clients receive investment analysis, allocation recommendations,
monthly or quarterly statements reflecting holdings and transactions, quarterly performance reports, and
ongoing account monitoring services for a portfolio which may include stocks, bonds, mutual funds, exchange-
traded funds, private placements, and convertible securities. NWM will exercise discretionary trading
authority while providing these services. This means that NWM Representatives will have authority to
purchase and sell any securities at their discretion in the amounts and at the times they deem suitable for a
client’s account. NWM may also recommend the use of third-party investment managers to manage all, or a
portion of the assets. Such managers will be granted limited discretionary trading authority. For more
information regarding third-party investment managers, please see Item 10 - Other Financial Industry
Activities and Affiliations.
The initial asset allocation recommendations are based on the financial information gathered from each client
at the onset of the relationship. This includes information on net worth, risk tolerance, financial goals and
objectives, investment restrictions and overall financial conditions. Based on this information, the client is
provided with investment recommendations designed to provide an appropriate asset mix consistent with the
client’s objectives. The client’s portfolio and its performance are monitored by the client’s Representative
considering the client’s stated goals, objectives and investment restrictions. The frequency of these reviews is
determined by the Representative and will be at least annually. NWM Representatives meet with the client on
an as needed basis to discuss the portfolio and other aspects of the service.
NWM typically recommends that investment management clients use the custody and transaction services of
Charles Schwab. Charles Schwab provides custody services, processes transaction orders for client accounts,
prepares monthly or quarterly account activity statements, and facilitates the payment of advisory fees due to
NWM and any retained third-party managers. Clients should be aware that Representatives may make
different recommendations and effect different trades with respect to the same securities and insurance to
different advisory clients. While these costs may not be better than the commissions or execution available if
the client used another brokerage firm, NWM Believes that the overall level of services and support provided
to the client by recommended custodians and broker-dealers outweighs the potentially lower costs that may
be available from other brokerage services providers.
As a general rule, NWM believes that investing is best suited to those who believe in a long-term buy-and-hold
policy. Therefore, clients should not expect frequent investment changes in the portfolio. However, as a result
of monitoring the account, portfolio modifications may be advisable and made accordingly. Brokerage
commissions will be charged for transactions by the brokerage firm processing the transactions.
Selection of Independent Managers
NWM may retain third-party investment advisers to manage a portion of the clients’ assets. Pursuant to the
terms of the investment advisory agreement, NWM will have the discretion to hire and terminate these third-
party advisers. NWM will provide independent managers objective and background information about the
client at account inception, and thereafter as changes to such information is provided to NWM by a client.
Pursuant to its discretionary authority granted by the client in the Investment Advisory Agreement, NWM may
retain a fixed income securities manager. The fixed income securities manager will be provided with the
discretionary authority to invest client assets in fixed income securities consistent with the client’s Fixed
Income Investment Policy Statement. The fixed income manager will also monitor the account for changes in
credit ratings, security call provisions, and tax loss harvesting opportunities (to the extent that the manager is
provided with cost basis information). The fixed income manager will obtain NWM’s consent prior to the sale
of any client securities.
Additionally, NWM may allocate a portion of a portfolio to an independent third-party investment advisor
(“Independent Manager”) for separate account management based upon individual client circumstances and
objectives, including, but not limited to, client account size and tax circumstances. Pursuant to the terms of
the investment advisory agreement, NWM shall have the discretion to appoint and terminate these third-
party advisers. The specific terms and conditions under which a client engages an Independent Manager may
also be set forth in a separate written agreement with the designated Independent Manager. However, not all
Independent Managers require a separate advisory agreement with the designated Independent Manager.
Disclosure of the use of an Independent Manager and their additional fees will be provided to clients.
Independent Managers utilized by NWM include BSP, Dimensional Funds Advisors and Parametric.
Counseling and Financial Planning Services
In designing a project or comprehensive financial plan, regardless of the complexity, Representatives will:
Interview the client, analyze the client’s financial needs and assist the client in developing realistic
goals and objectives based on information provided by the client. The Representative may also clarify
planning problems and outline strategies designed to meet the client’s goals. A client may retain NWM
to perform a single nonrecurring project, such as basic investment research or specific investment
advice, retirement planning or insurance analysis, or a comprehensive plan covering these and other
financial subjects. A client may also engage a Representative for projects that may require annual or
more frequent reviews if more complex long-term planning is needed.
Prepare an initial written project or comprehensive plan in the scope requested by a client based on
the information gathered during the client interview and needs evaluation. This plan may include
establishing a clear set of objectives, an outline of resources, a written investment policy statement, an
asset allocation model, strategy recommendations, retirement, estate, education, or insurance
planning, product recommendations, and steps to take for implementing advice provided.
Help the client implement the plan, including purchasing and/or selling securities and/or insurance
products.
Review the plan periodically in the scope and frequency agreed upon with the client.
The Representative may also, as needed, recommend changes to the client’s investment portfolio or Plan,
either in writing or verbally. Changes in the client’s financial condition, personal circumstances, goals, or
general economic conditions may trigger changes in the plan. To the extent material changes have occurred to
a client’s circumstances or goals, or to the extent a client requests a new project, the client will be asked to
sign a new Service Agreement. The client may initiate contact with the client’s Representative as often as
needed and the Representative will schedule conferences as needed, usually no less than annually.
All planning is based on information provided by the client. It is the client’s responsibility to be certain NWM
has current and accurate information for the initial plan and it is the client’s responsibility to inform the
Representative of material changes affecting the investments and planning strategies implemented.
Retirement Plan Advisory Services
NWM may enter into agreements with employers that provide qualified retirement plans (“Plans”) with
various advisory services in a 3(21) fiduciary capacity.
NWM will act in a 3(21) fiduciary capacity and typically provides the following services:
1. Provide investment advice to the Employer at a Plan Level.
2. Deliver a report at least annually to the Plan which includes a review of the Plan’s Investment Policy
Statement, including assessing the following:
a. The criteria for selecting money managers and the due diligence procedures that the Plan
followed in selecting its money managers and/or mutual funds;
b. The basis for asset mix and rebalancing limits;
c. The performance measurement criteria;
d. Monitoring procedures of money managers and other investment-related venders;
e. Composition and relevancy of quarterly performance reports;
f. Composition of custodial reports; and
g. Termination procedures for money managers.
3. Review of providers (custodians and recordkeeping) available to the Plan including:
a. The capabilities of various providers;
b. The performance record of various providers;
c. The scope of investment choices at various providers; and
d. The cost of various providers.
4. Review of the Plan’s overall investment activities for possible conflicts of interests or prohibited
transactions by the fiduciary, money managers and/or consultants.
5. Advise Plan about mutual funds and other investment alternatives that are consistent with the
investment categories allowable under the Plan;
6. Meet with representatives of Plan, at intervals mutually acceptable to Plan and NWM, to discuss the
Plan's investment performance and investment selections;
7. Monitor investments in the Plan’s accounts with account custodians (each, an "Account”) and change
investment selections as NWM deems appropriate. Client hereby grants NWM limited discretionary
authority and appoints NWM as agent and attorney-in-fact with respect to each Account. Pursuant to
such authorization, NWM may, in its sole discretion and at Plan’s risk, open brokerage and custodial
accounts and accounts with third-party investment managers, purchase, sell, exchange, convert and
otherwise trade in the securities and other investments in an Account on such markets, at such prices
and at such commission as NWM believes to be in the best interest of the Account. NWM shall also
have authority to arrange for delivery and payment in connection with transactions for each Account,
and act on behalf of Client and in all other matters necessary or incidental to the handling of the
Account. This authorization does not grant NWM or any third-party manager permission to take
delivery or possession of Plan’s funds or securities except for fees due NWM;
8. Prepare written performance and other reports in the scope and at the times mutually agreed upon
between Plan and NWM;
9. Conduct informational/educational group meetings with Plan participants at initial installation of the
Plan, and periodically thereafter in the scope and frequency mutually agreed upon between Client and
NWM regarding:
a. General investment concepts;
b. Investment objectives and performance of selected investments; and
c. Investment allocations and strategies available to meet various investment objectives;
10. Provide individual counseling to Plan participants in the scope and at the times mutually agreed upon
between Client and NWM. Such counseling shall not include specific investment recommendations to
any participant
For certain retirement plans, NWM mainly works in coordination and support with other retirement plan
platforms (collectively “platforms”). Retirement plan clients will engage both NWM and platforms. Platforms
will provide to the client additional discretionary investment management services and will exercise
discretionary authority to select the plan investments made available to the plans’ participants by selecting
and maintaining the plans’ investments according to the goals and investment objectives of the plan.
All advice provided by NWM and NWM Representatives is based upon the reliability of the information
provided to NWM by the Plan and its participants.
Either the client or NWM may at any time request an audit of the Plan by an independent certified public
accountant, the fee for such audit will be paid by the party making the audit request.