We generally provide advisory services through programs sponsored by LPL Financial, LLC (“LPL
Financial”), a registered investment adviser and broker-dealer. LPL Financial is independently
owned and operated and not affiliated with us or Northwest Federal Credit Union. LPL Financial
offers wrap-fee programs and non-wrap fee programs to clients.
Our firm sponsors a wrap fee program, which allows clients to pay a single fee for investment
advisory services and associated custodial transaction costs. Transaction fees will be paid by our firm
via individual transaction charges. Because our firm absorbs client transaction fees, a financial
incentive exists to recommend transactions in securities that carry lower fees (e.g., transactions
involving equity securities may be recommended over fixed income securities because of the lower
transaction charge) or to limit trading activities in client accounts. Custodial transaction costs,
however, are not included in the advisory fee charged by our firm for non-wrap services, and are to
be paid by the client to LPL Financial. Depending on the client’s account or portfolio trading activity,
clients may pay more for using our wrap fee services than they would for using our non-wrap
services.
The advisory fee we charge may take the payment of transaction charges into consideration. That is,
the advisory fee we charge to other accounts may be lower than the advisory fee we charge to
accounts for which we are paying the transaction charges. You should also understand that engaging
in a “buy and hold” strategy would not capitalize on any higher advisory fee being charged in light of
our paying for the transaction charges in certain securities. In addition, these conflicts may also have
an impact on the performance of your account. By participating in a wrap fee program, you may end
up paying more or less than you would through a non-wrap fee program where a lower advisory fee
is charged, but trade execution costs are passed directly through to you by LPL Financial.
Our wrap program offers clients an asset management account that is directly managed by our firm’s
investment adviser representatives. Clients pay a single wrap fee for advisory services and associated
custodial transaction costs. Clients participating in our non-wrap account pay an asset-based
management fee and separate transaction costs. Please see our Firm Brochure for more information
regarding our asset management services.
Our Wrap Advisory Services
Strategic Wealth Management Program (“SWM”):
As part of our SWM wrap program service, a portfolio is created, consisting of individual stocks, bonds,
exchange traded funds (“ETFs”), options, mutual funds and/or other investments. The client’s individual
investment strategy is tailored to their specific needs and may include some or all of the previously
mentioned securities. Portfolios will be designed to meet a particular investment goal, determined to be
suitable to the client’s circumstances. Once the appropriate portfolio has been determined, portfolios
are continuously and regularly monitored, and if necessary, rebalanced based upon the client’s
individual needs, stated goals and objectives.
ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 5 NWFA
Fees:
The maximum annual fee to be charged to the client’s account(s) will not exceed 1.50%. The fee to be
assessed to each account will be detailed in the client’s signed advisory agreement or LPL Financial
Account Application. Fees are billed on a pro-rata basis quarterly in advance based on the value of
the account(s) on the last day of the previous quarter. Fees are negotiable and will be deducted from
the account(s). Please note that fees will be adjusted for deposits and withdrawals made during the
quarter. If accounts are opened during the quarter, the pro-rata advisory fees will be deducted during
the next regularly scheduled billing cycle. As part of this process, Clients understand the following:
a) LPL Financial as the client’s custodian sends statements at least quarterly, showing all
disbursements for each account, including the amount of the advisory fees paid to our firm;
b) Clients provide authorization permitting LPL Financial to deduct these fees;
c) LPL Financial calculates the advisory fees for all fee schedules and deducts them from the
client’s account.
Other Types of Fees & Expenses:
In addition to our advisory fees above, clients may also pay holdings charges imposed by the chosen
custodian for certain investments, charges imposed directly by a mutual fund, index fund, or
exchange traded fund, which shall be disclosed in the fund’s prospectus, mark-ups and mark-downs,
spreads paid to market makers, fees for trades executed away from custodian, wire transfer fees and
other fees and taxes on brokerage accounts and securities transactions. Our firm does not receive a
portion of these fees.
When providing services, we use mutual funds that the custodian makes available. Mutual funds
offer multiple share classes which can be titled, for example, as Class A, Class I, institutional, fee-
based, investor, retail, service, administrative or platform share classes. The mutual funds are no-
load or load-waived share classes and therefore not subject to any upfront sales charge. However,
different mutual fund share classes have different expense structures (i.e., some higher and some
lower) and in some cases the mutual fund share classes pay a 12b-1 fee, administrative fee,
recordkeeping fee, and/or revenue sharing fee to the custodian. You should understand that the
mutual fund share class we select for purchase in your account in some cases will not be the least
expensive share class that the mutual fund makes available. We select mutual fund share classes
based on a variety of different considerations, including but not limited to: the advisory fee that is
charged; the amount of the transaction charges applied to the purchase or sale of the mutual fund;
the anticipated frequency of transactions; the holding period for the mutual funds; the overall cost
structure of the advisory program; share class eligibility requirements; and potential tax
consequences. You should understand that another financial services firm may offer the same mutual
fund at a lower overall cost to the investor than is available through accounts.
Termination and Refunds
Either party may terminate the signed advisory agreement at any time. Upon receipt of your notice
of termination, LPL Financial will process a pro-rated refund of the unearned portion of the advisory
fees charged in advance at the beginning of the quarter.
ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 6 NWFA
ERISA and Retirement Accounts
If the client is a qualified plan subject to the Employee Retirement Income Security Act of 1974
(ERISA) or a plan within the meaning of Section 4975(e) of the Internal Revenue Code of 1986 (the
Code), NWFA is acting as a fiduciary under ERISA as defined in Section (21) of ERISA or Section 4975
of the Code with respect to services listed in Item 4 of the Brochure.
There is a conflict of interest for individuals that currently invest in an employer-sponsored
retirement plan or individual retirement account that are considering a rollout of assets from the
retirement plan or account. A conflict of interest exists because we will be compensated only if the
individual rolls over the proceeds into an IRA that we then manage. As a result, it can be construed
that we have a financial incentive to recommend one option over another. The individual considering
the roll out of assets into an IRA should understand that certain IARs associated with NWFA maintain
an education-only policy with respect to rollovers and certain other IARs will make a
recommendation with respect to a rollover. To the extent the IAR maintains an education-only
policy, NWFA and its IAR will not make a recommendation and the individual is solely responsible
for considering all relevant services, fees, and conflicts of interest applicable to the management
services by NWFA. To the extent an IAR makes a rollover recommendation, the recommendation to
roll out assets into an IRA will only be made if it is determined to be in the individual’s best interest.
Regardless, we encourage each individual to include in his/her decision making process, a thorough
review of all options available; for example (i) remain invested in the current retirement plan or
account (if available), (ii) transfer assets to a new employer-sponsored retirement plan (if available),
(iii) transfer assets to an IRA with a financial institution, or (iv) withdraw assets directly, which
would be subject to federal and applicable state and local taxes and possibly subject to the IRS penalty
of 10% depending upon the age of the individual. When considering these options, NWFA encourages
individuals to consider the advantages and disadvantages of each option, including any applicable
fees and all features of each option. A decision to roll over assets should reflect consideration of
various factors, the importance of which will depend on the individual’s needs and circumstances.
Wrap Fee Program Recommendations:
Effective, January 1, 2019, NWFA discontinued the SWM Wrap Program for new clients.
ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 7 NWFA