A. Firm Information
Wealth Management Advisors, LLC (“WMA”) also does business as Wagner Wealth
Management, LLC. WMA was formed in 2014, and provides financial planning, portfolio
management, retirement plan advice and general consulting services to our clients.
Wagner Wealth Management, LLC is the principal owner of WMA. DEW Holdings, LLC owns
90% of Wagner Wealth Management, LLC, and Osgood LLC owns the remaining 10%. Mr. Dan
Wagner owns 100% of DEW Holdings, LLC, and Jennifer Osgood owns 100% of Osgood LLC.
As of December 31, 2023, WMA managed $ 465, 312, 216 on a discretionary basis, and did not
manage any assets on a non-discretionary basis.
B. Advisory Business Offered
Investment Management Services
WMA provides customized investment advisory solutions for its clients. This is achieved
through continuous personal Client contact and interaction while providing discretionary
investment management and related advisory services. Most accounts are managed on a
discretionary basis, meaning that the advisor has discretion over what securities to buy and
sell. However, clients may elect to have their account managed on a non-discretionary basis,
meaning that the client must consent to each trade in the account. This trading discretion and
any limitations on it will be set forth in the client agreement. The services provided are the
same regardless of the account structure selected.
At the beginning of our relationship, we meet with you, gather information, and perform
research and analysis as necessary to develop your Investment Plan. The Investment Plan will
be updated from time to time when requested by you, or when determined to be necessary or
advisable by us based on updates to your financial or other circumstances. We spend time with
you, asking questions, discussing your investment experience and financial circumstances, and
broadly identifying your major goals.
WMA works with each Client to identify their investment goals and objectives as well as risk
tolerance and financial situation in order to create a portfolio strategy. WMA’s investment
strategy is primarily long-term focused, but the Adviser may buy, sell, or re-allocate positions
that have been held less than one year for reasons that include, but are not limited to: changes
in Client objectives; account inflows/outflows; security fundamentals and/or market
conditions. The first step of the WMA investment process is to determine the strategic asset
allocation targets. Once WMA establishes the long-term framework, it’s determined if the
Adviser should tactically adjust the allocation targets based on the current market
environment and short-term economic outlook. WMA will construct, implement, and monitor
the portfolio in connection with 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 acceptance by the
Adviser.
Notwithstanding the foregoing, you may impose certain written restrictions on us in the
management of your investment portfolio, such as prohibiting the inclusion of certain types of
investments in an investment portfolio or prohibiting the sale of certain investments held in the
account at the commencement of the relationship. You should note, however, that restrictions
imposed by you may adversely affect the composition and performance of your investment
portfolio. You should also note that your investment portfolio is treated individually by giving
consideration to each purchase or sale for your account. For these and other reasons,
performance of your investment portfolio(s) within the same investment objectives, goals and/or
risk tolerance may differ, and you should not expect that the composition or performance of your
investment portfolio(s) would necessarily be consistent with similar clients of ours.
WMA will provide investment advisory services and portfolio management services and will
not provide securities, custodial or other administrative services. At no time will WMA accept
or maintain custody of a Client’s funds or securities, except for authorized deduction of the
Adviser’s fees. All Client assets will be managed within their designated account at the
Custodian, pursuant to the terms of the investment advisory agreement. Portfolio Management
accounts may be custodied at Charles Schwab & Co.
Wrap Fee Program
Our Firm offers the WMA Wrap Fee account to our clients. A wrap fee account generally
involves an investment account where you are charged a single, bundled, or “wrap” fee for
investment advice, brokerage services, administrative expenses, and other fees and expenses.
While wrap fee programs may be called different names—such as asset allocation program,
asset management program, investment management program, mini-account, uniform
managed account, or separately managed account—the defining feature is that they offer
bundled investment management and brokerage services for one fee. There is typically a
"sponsor" for a wrap fee program, i.e., the person that, for a portion of the fee, sponsors,
organizes, or administers the program or selects, or provides advice to clients regarding the
selection of, other investment advisers in the program. Our Firm is a sponsor to the wrap
program (the “WMA Wrap Program” or the “Program”) and is the sole portfolio manager for
the wrap fee program.
Financial Planning Services
WMA will typically provide a variety of financial planning services to Clients, pursuant to a
written financial planning agreement. Services are offered in a variety of areas and are often
tailored to the Client’s needs, goals, and financial situation. This service may be provided as a
stand-alone service or may be coupled with ongoing portfolio management.
At the outset of each client relationship, we spend time with you, asking questions, discussing
your investment experience and financial circumstances, and broadly identifying your major
goals. You may elect to retain us to prepare a full financial plan. This written report is presented
to you for consideration. In most cases, clients subsequently retain us to manage the investment
portfolio on an ongoing basis.
For those financial planning clients making this election, and for other clients who do not need
financial planning but retain us for portfolio management services, based on all the information
initially gathered, we generally develop:
• a financial outline for you based on your financial circumstances and goals, and your risk
tolerance level (the “Financial Profile” or “Profile”); and
• your investment objectives and guidelines (the “Investment Plan” or “Plan”).
The Financial Profile is a reflection of your current financial picture and a look to your future
goals. The Investment Plan outlines the types of investments we will make on your behalf to
meet those goals. The Profile and the Plan are discussed regularly with you but are not
necessarily written documents.
Financial planning may include advice that addresses one or more areas of your financial
situation, such as estate planning, risk management, budgeting and cash flow controls,
retirement planning, education funding, and investment portfolio design. Depending on your
particular situation, financial planning may include some or all of the following:
• Gathering information concerning your personal and financial situation.
• Assisting you in establishing financial goals and objectives.
• Analyzing your present situation and anticipated future activities in light of your financial
goals and objectives.
• Identifying problems foreseen in the accomplishment of these financial goals and
objectives and offering alternative solutions to the problems
• Making recommendations to help achieve retirement plan goals and objectives.
• Designing an investment portfolio to help meet your goals and objectives.
• Providing estate planning
• Assessing risk and reviewing basic health, life, and disability insurance needs; or
• Reviewing goals and objectives and measuring progress toward these goals.
Once financial planning advice is given, you may choose to have us implement your financial
plan and manage your investment portfolio on an ongoing basis. However, you are under no
obligation to act
upon any of the recommendations made by us under a financial planning
engagement and/or to engage the services of any recommended professional.
Finally, where we provide only limited financial planning or general consulting services, we will
work with you to prepare an appropriate summary of the specific project(s) to the extent
necessary or advisable under the circumstances.
Separately Managed Accounts
When appropriate and in accordance with the Investment Plan for a client, we may recommend
the use of one or more Separate Account Managers, each a “Manager”. Having access to various
Managers offers a wide variety of manager styles and offers you the opportunity to utilize more
than one Manager if necessary to meet your needs and investment objectives. We will select
or recommend the Manager(s) we deem most appropriate for you. Factors that we consider in
recommending/selecting Managers generally include your stated investment objective(s),
management style, performance, risk level, reputation, financial strength, reporting, pricing,
and research.
The Manager(s) will generally be granted discretionary trading authority to provide
investment supervisory services for the portfolio. Under certain circumstances, we retain the
authority to terminate the Manager’s relationship or to add new Managers without your specific
consent. In other cases, you will ultimately select one or more Managers recommended by us.
Fees paid to such Manager(s) are separate from and in addition to the fee assessed by us.
In any case, with respect to assets managed by a manager, our role will be to monitor your
overall financial situation, to monitor the investment approach and performance of the
Manager(s), and to assist you in understanding the investments of the portfolio.
General Consulting
In addition to the foregoing services, we may provide general consulting services to clients.
These services are generally included as part of our advisory services for a specified number of
hours. If the scope of the consulting services exceeds that previously specified number of hours, a
separate stand-alone plan will be negotiated. These services may include without limitation,
minimal cash flow planning for certain events such as education expenses or retirement, estate
planning analysis, income tax planning analysis and review of your insurance portfolio, as well
as other matters specific to you as and when requested by you and agreed to by us. The scope
and fees for consulting services will be negotiated with each client at the time of engagement
for the applicable project.
Brokerage Account Services
For those clients with legacy positions in investment products that must be held at a
broker/dealer with a registered representative assigned to it, or who wish to invest in products
that are not available at Schwab, we have established a relationship with Arkadios Capital, LLC
(“Arkadios”), a FINRA and SIPC member, and registered broker/dealer. Some of our staff
members are registered representatives of Arkadios and are thus able to provide the services
requested. Arkadios is not affiliated with WMA.
Retirement Plan Advisory Services
The Employee Retirement Income Security Act of 1974 (“ERISA”) sets forth rules under
which Plan Fiduciaries may retain investment advisers for various types of services with
respect to Plan assets. For certain services, we will be considered a fiduciary under ERISA.
For example, WMA will act as an ERISA § 3(21) fiduciary when providing non-discretionary
investment advice to the Plan Fiduciaries by recommending a suite of investments as choices
among which Plan Participants may select. Also, to the extent that the Plan Fiduciaries retain
WMA to act as an investment manager within the meaning of ERISA § 3(38), WMA will
provide discretionary investment management services to the Plan.
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 of 1974 (“ERISA”) 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 interests ahead of yours. Additional disclosure
may be found elsewhere in this Brochure or in the written agreement between you and WMA.
Establishing a sound fiduciary governance process is vital to good decision-making and to
ensuring that prudent procedural steps are followed in making investment decisions. We will
provide Retirement Plan consulting services to Plans and Plan Fiduciaries as described
below. The particular services provided will be detailed in the consulting agreement. The
appropriate Plan Fiduciary(ies) designated in the Plan documents (e.g., the Plan sponsor or
named fiduciary) will (i) make the decision to retain our firm; (ii) agree to the scope of the
services that we will provide; and (iii) make the ultimate decision as to accepting any of the
recommendations that we may provide. The Plan Fiduciaries are free to seek independent
advice about the appropriateness of any recommended services for the Plan. Retirement Plan
consulting services may be offered individually or as part of a comprehensive suite of services.
Discretionary Management Services
When retained as an investment manager within the meaning of ERISA § 3(38), we provide
continuous and ongoing supervision over the designated retirement plan assets. We will
actively monitor the designated retirement plan assets and provide ongoing management of the
assets. When applicable, we will have discretionary authority to make all decisions to buy, sell
or hold securities, cash or other investments for the designated retirement plan assets in our
sole discretion without first consulting with the Plan Fiduciaries. We also have the power and
authority to carry out these decisions by giving instructions, on your behalf, to brokers and
dealers and the qualified custodian(s) of the Plan for our management of the designated
retirement plan assets.
Discretionary Investment Selection Services
We will monitor the investment options of the Plan and add or remove investment options for
the Plan without prior consultation with the Plan Fiduciaries. We will have discretionary
authority to make and implement all decisions regarding the investment options that are
available to Plan Participants.
Retirement Plan Rollover Recommendations
To the extent we recommend you roll over your account from a current retirement plan to an
individual retirement account (“Rollover IRA”), managed by WMA please know that WMA and
our investment adviser representatives may have a conflict of interest. We can earn increased
investment advisory fees by recommending that you roll over your account at the retirement
plan to a Rollover IRA managed by WMA. We will earn fewer investment advisory fees if you do
not roll over the funds in the retirement plan to a Rollover IRA managed by WMA. Thus, our
investment adviser representatives have an economic incentive to recommend a rollover of
funds from a retirement plan to a Rollover IRA which is a conflict of interest because our
recommendation that you open an IRA account to be managed by our Firm can be based on our
economic incentive and not based exclusively on whether or not moving the IRA to our
management program is in your overall best interest.
We have taken steps to manage this conflict of interest. We have adopted an impartial conduct
standard whereby our investment adviser representatives will (i) provide investment advice to
a retirement plan participant regarding a rollover of funds from the retirement plan in
accordance with the fiduciary status described below, (ii) not recommend investments which
result in WMA receiving unreasonable compensation related to the rollover of funds from the
retirement plan to a Rollover IRA, and (iii) fully disclose compensation received by WMA and
all persons associated with WMA(our “Supervised Persons”) and any material conflicts of
interest related to recommending the rollover of funds from the retirement plan to a Rollover
IRA and refrain from making any materially misleading statements regarding such rollover.