A. Firm Information
One Wealth Advisors, LLC (“One Wealth” or the “Advisor”) is a registered investment advisor
with the U.S. Securities and Exchange Commission (“SEC”) based in San Francisco, California.
One Wealth is organized as a limited liability company (“LLC”) under the laws of the State of
Delaware in September 2015. One Wealth is owned by David Steele Family Living Trust and
Steele and Villena Trust. The Advisor is operated by David Steele (Managing Partner) and
Jonathan Steele (Managing Partner and Chief Investment Officer), and Kevin Cohen (Director of
Operations and Chief Compliance Officer). This Disclosure Brochure provides information
regarding the qualifications, business practices, and the advisory services provided by One
Wealth.
B. Advisory Services Offered
One Wealth offers holistic investment advisory services to individuals, high net worth individuals, trusts, estates,
charitable organizations, businesses and their retirement plans (each referred to as a “Client”). One Wealth
provides comprehensive investment management, financial planning and consulting services by offering
individually tailored comprehensive financial solutions that deliver specific, long-term results to the individual
needs of each Client.
The Advisor serves as a fiduciary to its Clients, as defined under the applicable laws and regulations. As a
fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate
potential conflicts of interest. Our fiduciary commitment is further described in the Advisor’s Code of Ethics. For
more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in
Client Transactions and Personal Trading.
Investment and Wealth Management Services
One Wealth provides customized, holistic investment advisory solutions for its Clients. We collaborate closely
with a team of vetted third parties to create, implement, and maintain customized financial life plans that include;
asset allocation, portfolio management, private and public concentrated stock strategies, cash flow analysis, risk
management and insurance, retirement planning, charitable and philanthropic planning, tax, trust, and estate
planning, and any other services based on the Client’s needs and objectives. One Wealth works with each Client
to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create
a financial life plan. One Wealth will then develop an overarching, holistic, strategic life plan by constructing a
portfolio, consisting of diversified mutual funds, exchange-traded funds (“ETFs”), bonds and/or independent
investment managers (“Independent Managers”) attempting to achieve the Client’s financial life plan. The
Advisor, depending on Client needs and objectives, also utilizes individual stocks, alternative investments, ESG
securities, and other types of securities, as appropriate, to meet the needs of particular Clients. The Advisor
retains certain legacy investments based on portfolio fit and/or tax considerations.
For certain Clients, One Wealth will manage and/or advise on certain investments that are not maintained at the
Client’s primary Custodian. These investments for the Client’s financial life plan includes, but are not limited to,
asset allocation, portfolio management, private and public concentrated stock strategies, cash flow analysis, risk
management and insurance, retirement planning, charitable and philanthropic planning, tax, trust, and estate
planning and any services based on the Client’s needs and objectives. In these situations, One Wealth directs or
recommends the allocation of Client assets among the various investment options available with these held-away
accounts. These assets are generally maintained at the underwriting insurance company or the custodian
designated by the Client. For accounts where the Advisor does not have the authority to execute transactions in
these accounts and, as a result, is not responsible for the ongoing monitoring of these accounts.
One Wealth’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate
positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. One Wealth will construct, implement and monitor the financial life plan to ensure it meets the goals,
objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to
place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to
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acceptance by the Advisor.
One Wealth seeks to develop a personalized strategy that is detailed and easy to understand. One Wealth may
recommend, on occasion, redistributing investment allocations to diversify the portfolio. One Wealth may
recommend specific positions to increase sector or asset class weightings. The Advisor will only recommend the
holding of mutual funds in share classes that have higher expense ratios than an equivalent share class if the
investment amount does not meet the fund’s required minimum investment or if there are material tax
considerations. The Advisor may recommend employing cash positions as a possible hedge against market
movement. One Wealth may recommend selling positions for reasons that include, but are not limited to,
harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities,
overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating
cash to meet the Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the terms of the
agreement, please see Item 12 – Brokerage Practices.
Use of Independent Managers - One Wealth will recommend that Clients utilize one or more unaffiliated
investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a
Client’s financial life plan portfolio. In such instances, One Wealth shall select the Independent Managers through
the use of the Advisors discretionary authority. One Wealth assists in the development of the initial policy
recommendations and managing the ongoing Client relationship. One Wealth will perform initial and ongoing
oversight and due diligence over the selected Independent Manager[s] as part of its holistic approach and
ongoing investment supervisory services. The Independent Manager may provide holistic investment
management services, as well as any other related services, at the direction of One Wealth. The Client will be
provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes
the appropriate disclosures).
Betterment Institutional Platform - One Wealth may recommend that certain Clients implement their investment
portfolios through Betterment Institutional, a division of Betterment LLC (herein “Betterment Institutional” or the
“Investment Platform”). Betterment Institutional is what is often termed a “robo-advisor”, an online wealth
management service that provides automated, algorithm-based portfolio management advice. Robo-advisors use
technology to deliver similar services as traditional advisors, but generally only offer portfolio management and
do not get involved in a Client’s personal situation, such as taxes and retirement or estate planning. One Wealth
chose to affiliate with Betterment Institutional due to the Investment Platform’s customized portfolio allocations,
automated rebalancing, and competitive fees. One Wealth utilizes Betterment Institutional as a complement to its
comprehensive financial planning services to provide cost effective investing coupled with personalized financial
planning.
To establish accounts with Betterment Institutional, the Client will also enter into one or more agreements with
Betterment that provides the authority for discretionary investment management by the Investment Platform. One
Wealth remains the Client’s primary advisor and relationship contact and will select or construct a portfolio of
ETFs and/or cash equivalents from the universe of investments included on the Investment Platform.
One Wealth will have the discretionary authority to instruct Betterment Institutional with
respect to portfolio
construction, asset allocation and other investment decisions, subject to the limitations described herein.
Betterment Institutional will implement the portfolio and be responsible for the discretionary trading of the ETFs in
the Client’s portfolio, including the purchase and sale of investments and the automatic rebalancing back to
targets.
Betterment Institutional utilizes between ten to twelve different ETF’s, representing various asset classes for the
construction of investment portfolios. As discussed above, One Wealth will work with each Client to
select/construct a portfolio to meets the needs of the Client. The Client has limited ability to put restrictions on its
accounts. The account[s] cannot contain investments that are not included in the Betterment Institutional
universe of ETFs and cash equivalents.
In the absence of a contrary direction, Betterment periodically rebalances Client portfolios so that in the face of
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fluctuating market prices each Client’s portfolio remains within a range of the target allocation. Betterment also
offers optional tax loss harvesting and automated asset location services. Clients will have fewer opportunities to
harvest tax losses if the Advisor elects a Custom Portfolio strategy with fewer asset classes than are included in
the Betterment portfolio strategy for that Client.
The Advisor’s investment philosophy is long-term, but the Advisor may make such tactical overrides to take
advantage of market pricing anomalies or strong market sectors. The Advisor does not actively trade in the
Client’s account[s] and is also limited to a enter one allocation change per account per trading day through
Betterment Institutional, the Client should be aware of these potential disadvantages.
For its services, Betterment Institutional will charge an asset-based fee that is in addition to the Advisor’s fee.
Betterment Institutional’s fee includes the securities transaction fees for all trades. The Advisor will only receive
its investment advisory fees as detailed in Item 5.A. below and does not share in any fees earned by Betterment
Institutional.
The Client, prior to entering into an agreement with the Investment Platform, will be provided with the Investment
Platform's Form ADV Part 2A (or a brochure that makes the appropriate disclosures).
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over
the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based
account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a
new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll
over a retirement account to an account managed by the Advisor.
Financial Planning and Consulting Services
One Wealth provides a variety of financial planning services to Clients as a part of the Advisor’s wealth
management services. Clients may engage the Advisor separately for financial planning services, pursuant to a
written agreement or as a part of One Wealth’s wealth management services. Services are offered in several
areas of a Client’s financial situation, depending on their goals and objectives.
Generally, such financial planning services will involve preparing a financial plan or rendering a financial
consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass
one or more areas of need, including but not limited to, investment planning, retirement planning, personal
savings, education savings, trust and estate planning, insurance needs, charitable giving, small business
planning and other areas of a Client’s financial situation.
A financial plan developed for a financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs.
One Wealth may also refer Clients to an accountant, attorney or other specialist, as appropriate for their unique
situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s
financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may
not provide a written summary. Plans or consultations are typically completed within six (6) months of contract
date, assuming all information and documents requested are provided promptly.
Financial planning and consulting recommendations poses a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor
for investment management services or to increase the level of investment assets with the Advisor would pose a
conflict, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to
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implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If
the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to
implement the transaction through the Advisor.
Retirement Plan Advisory Services
One Wealth offers 3(21) retirement plan advisory services on behalf of company retirement plans (each a “Plan”)
and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist
the Plan Sponsor in meeting its fiduciary obligations to the Plan. Each engagement is customized to the needs of
the Plan and Plan Sponsor. Services generally include:
• Plan Design and Strategy
• Plan Review and Evaluation
• Executive Planning & Benefits
• Investment Oversight
• Plan Fee and Cost Analysis
• Plan Committee Consultation
• Fiduciary and Compliance
• Plan Participant Education
These services are provided by One Wealth serving in the capacity as a fiduciary under the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2),
the Plan Sponsor is provided with a written description of One Wealth’s fiduciary status, the specific services to
be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement.
C. Client Account Management
Prior to engaging One Wealth to provide advisory services, each Client is required to enter into one or more
agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and
the Client. These services include:
• Establishing an Investment Strategy – One Wealth, in connection with the Client, will develop a strategy
that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – One Wealth will develop a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – One Wealth will develop a portfolio for the Client that is intended to meet the
stated goals and objectives of the Client.
• Investment Management and Supervision – One Wealth will provide investment management and
ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
One Wealth does not manage or place Client assets into a wrap fee program. Investment management services
are provided directly by One Wealth.
E. Assets Under Management
As of December 31, 2023, One Wealth manages $841,603,392 in Client assets, all of which are managed on a
discretionary basis. Clients may request more current information at any time by contacting the Advisor.