Garrett Wealth Advisory Group "GWAG" offers a variety of advisory services, which include
financial forth the relevant terms and conditions of the advisory relationship (the “Advisory
Agreement planning, consulting, and investment management services.) Prior to GWAG
rendering any of the foregoing advisory services, clients are required to enter into one or more
written agreements with GWAG setting.
GWAG was formed in 2014 and is owned by David Wayne Garrett (60%) and Brandon Garrett
(40%). As of December 2023, the firm has $472,998,528 in discretionary assets under
management and $26,040,248 in assets under advisement. Garrett Wealth Advisory Group,
LLC "GWAG" is the entity name for the RIA. GWAG does business as BentOak Capital "BOC"
and the brand BentOak Capital was established in 2020.
While this brochure generally describes the business of GWAG, certain sections also discuss
the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or
other persons occupying a similar status or performing similar functions), employees or any
other person who provides investment advice on GWAG’s behalf and is subject to the Firm’s
supervision or control.
FINANCIAL PLANNING AND CONSULTING SERVICES
GWAG offers clients a broad range of financial planning and consulting services, which may
include any or all of the following functions:
While each of these services is available on a stand-alone basis, certain of them may also be
rendered in conjunction with investment portfolio management as part of a comprehensive
wealth management engagement (described in more detail below).
In performing these services, GWAG is not required to verify any information received from the
client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly
authorized to rely on such information. GWAG may recommend clients engage the Firm for
additional related services, its Supervised Persons in their individual capacities as insurance
agents or registered representatives of a broker-dealer and/or other professionals to
implement its recommendations. Clients are advised that a conflict of interest exists if clients
engage GWAG or its affiliates to provide additional services for compensation. Clients retain
absolute discretion over all decisions regarding implementation and are under no obligation
to act upon any of the recommendations made by GWAG under a financial planning or
consulting engagement. The recommendations and observations provided in the financial
plan are based upon information provided to GWAG. Due to the variable included in GWAG’s
planning assumptions including: returns, inflation, fiscal and monetary policy, economic data,
etc., GWAG’s recommendations and opinions are subject to change when warranted. Outside
Business Financial Planning Education Planning Personal Financial Planning
Cash Flow Analysis Estate Planning Personal Tax Planning
Charitable Planning Insurance Analysis Real Estate Analysis
Corporate Structure Investment Planning Retirement Planning
Corporate Tax Planning Lines of Credit Analysis Manager Due Diligence
Cost Segregation Study Mortgage/Debt Analysis
pg. 4
of economic and financial assumptions, clients are advised that it remains their responsibility
to promptly notify the Firm of changes in their financial situation, investment objective, goals,
life changing events, and/or any other pertinent information for the purpose of reviewing,
evaluating or revising GWAG’s recommendations or services.
INVESTMENT AND WEALTH MANAGEMENT SERVICES
GWAG manages client investment portfolios on a fully discretionary basis (please see our Wrap
Fee Brochure). In addition, GWAG may provide clients with wealth management services
which generally include a broad range of comprehensive financial planning and consulting
services as well as discretionary management of investment portfolios.
GWAG primarily allocates client assets among various mutual funds, exchange-traded funds
(“ETFs”), individual debt and equity securities, and independent investment managers
(“Independent Managers”) in accordance with their stated investment objectives.
Where appropriate, the Firm may also provide advice about any type of legacy position or other
investment held in client portfolios. Clients may engage GWAG to manage and/or advise on
certain investment products that are not maintained at their primary custodian, such as
variable life insurance and annuity contracts and assets held in employer sponsored
retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, GWAG directs
or recommends the allocation of client assets among the various investment options available
with the product. These assets are generally maintained at the underwriting insurance
company or the custodian designated by the product’s provider.
GWAG tailors its advisory services to meet the needs of its individual clients and seeks to
ensure, on a continuous basis, that client portfolios are managed in a manner consistent with
those needs and objectives. GWAG consults with clients on an initial and ongoing basis to
assess their specific risk tolerance, time horizon, liquidity constraints and other related factors
relevant to the management of their portfolios. Clients are advised to promptly notify GWAG
if there are changes in their financial situation or if they wish to place any limitations on the
management of their portfolios. Clients may impose reasonable restrictions or mandates on
the management of their accounts if GWAG determines, in its sole discretion, the conditions
would not materially impact the performance of a management strategy or prove overly
burdensome to the Firm’s management efforts. For more information about this service,
please refer to our Wrap Fee Brochure.
USE OF INDEPENDENT MANAGERS
As mentioned above, GWAG may select certain Independent Managers to actively manage a
portion of its clients’ assets. The specific terms and conditions under which a client engages
an Independent Manager may be set forth in a separate written agreement with the
designated Independent Manager. In addition to this brochure, clients may also receive the
written disclosure documents of the respective Independent Managers engaged to manage
their assets.
GWAG evaluates a variety of information about Independent Managers, which may include
the Independent Managers’ public disclosure documents, materials supplied by the
Independent Managers themselves and other third-party analyses it believes are reputable.
To the extent possible, the Firm seeks to assess the Independent Managers’ investment
strategies, past performance and risk results in relation to its clients’ individual portfolio
allocations and risk exposure. GWAG also takes into consideration each Independent
Manager’s management style, returns, reputation, financial strength, reporting, pricing and
research capabilities, among other factors.
pg. 5
GWAG continues to provide services relative to the discretionary selection of the Independent
Managers. On an ongoing basis, the Firm monitors the performance of those accounts being
managed by Independent Managers. GWAG seeks to ensure the Independent Managers’
strategies and target allocations remain aligned with its clients’ investment objectives and
overall best interests.
LPL SPONSORED PROGRAMS
GWAG may provide advisory services through certain programs sponsored by LPL Financial
LLC (LPL), a registered investment advisor and broker-dealer. Below is a brief description of
each LPL advisory program available to GWAG. For more information regarding the LPL
programs, including more information on the advisory services and fees that apply, the types
of investments available in the programs and the potential conflicts of interest presented by
the programs please see the program account packet (which includes the account agreement
and LPL Form ADV program brochure) and the Form ADV, Part 2A of LPL or the applicable
program.
PERSONAL WEALTH PORTFOLIOS PROGRAM (PWP)
PWP offers clients an asset management account using asset allocation model portfolios
designed by LPL. Advisor will have discretion for selecting the asset allocation model portfolio
based on client’s investment objective. Advisor will also have discretion for selecting third
party money managers (PWP Advisors), mutual funds and ETFs within each asset class of the
model portfolio. LPL will act as the overlay portfolio manager on all PWP accounts and will be
authorized to purchase and sell on a discretionary basis mutual funds, ETFs and equity and
fixed income securities.
A minimum account value of $250,000 is required for PWP. In certain instances, LPL will
permit a lower minimum account size.
MODEL WEALTH PORTFOLIOS PROGRAM (MWP)
MWP offers clients a professionally managed mutual fund asset allocation program. GWAG
will obtain the necessary financial data from the client, assist the client in determining the
suitability of the MWP program and assist the client in setting an appropriate
investment
objective. The Advisor will initiate the steps necessary to open an MWP account and have
discretion to select a model portfolio designed by LPL’s Research Department consistent with
the client’s stated investment objective. LPL’s Research Department or third-party portfolio
strategists are responsible for selecting the mutual funds or ETFs within a model portfolio and
for making changes to the mutual funds or ETFs selected.
GUIDED WEALTH PORTFOLIOS (GWP)
GWP offers clients the ability to participate in a centrally managed, algorithm-based
investment program, which is made available to users and clients through a web-based,
interactive account management portal (“Investor Portal”). Investment recommendations to
buy and sell open-end mutual funds and exchange-traded funds are generated through
proprietary, automated, computer algorithms (collectively, the “Algorithm”) of Xulu, Inc., doing
business as FutureAdvisor (“FutureAdvisor”), based upon model portfolios constructed by LPL
and selected for the account as described below (such model portfolio selected for the
account, the “Model Portfolio”). Communications concerning GWP are intended to occur
primarily through electronic means (including but not limited to, through email
communications or through the Investor Portal), although GWAG will be available to discuss
investment strategies, objectives or the account in general in person or via telephone.
A preview of the Program (the “Educational Tool”) is provided for a period of up to forty-five
pg. 6
(45) days to help users determine whether they would like to become advisory clients and
receive ongoing financial advice from LPL, FutureAdvisor and GWAG by enrolling in the
advisory service (the “Managed Service”). The Educational Tool and Managed Service are
described in more detail in the GWP Program Brochure. Users of the Educational Tool are not
considered to be advisory clients of LPL, FutureAdvisor or GWAG, do not enter into an advisory
agreement with LPL, FutureAdvisor or GWAG, do not receive ongoing investment advice or
supervisions of their assets, and do not receive any trading services.
A minimum account value of $5,000 is required to enroll in the Managed Service.
MANAGER ACCESS SELECT (MAS)
Manager Access Select provides clients access to the investment advisory services of
professional portfolio management firms for the individual management of client accounts.
GWAG will assist client in identifying a third-party portfolio manager (Portfolio Manager) from
a list of Portfolio Managers made available by LPL. The Portfolio Manager manages client’s
assets on a discretionary basis. GWAG will provide initial and ongoing assistance regarding
the Portfolio Manager selection process.
A minimum account value of $100,000 is required for Manager Access Select, however, in
certain instances, the minimum account size may be lower or higher.
SMALL MARKET SOLUTIONS (SMS)
SMS is a bundled Retirement Plan service offering designed specifically for small employer
plans. In this offering, LPL will serve as the 3(38) Investment Manager to the plan and discharge
a portion of the non-discretionary functions to GWAG. The client will receive both LPL and
GWAG’s Firm Brochures, and shall enter into an LPL specific agreement for the 3(38) services
and compensation paid to LPL, and a separate GWAG agreement delineating the specific
functions performed by and compensation due to GWAG.
POTENTIAL CONFLICTS OF INTEREST
Advisor receives compensation as a result of a client’s participation in an LPL program.
Depending on, among other things, the type and size of the account, type of securities held in
the account, changes in its value over time, the ability to negotiate fees or commissions, the
historical or expected size or number of transactions, and the number and range of
supplementary advisory and client-related services provided to the client, the amount of this
compensation may be more or less than what the GWAG would receive if the client
participated in other programs, whether through LPL or another sponsor, or paid separately
for investment advice, brokerage and other services.
The account fee may be higher than the fees charged by other investment advisors for similar
services. For instance, FutureAdvisor offers direct-to-consumer services similar to GWP.
Therefore, clients could generally pay a lower advisory fee for algorithm-driven, automated
(“robo”) investment advisory services through FutureAdvisor or other robo providers. However,
clients using such direct robo services will forgo opportunities to utilize LPL-constructed
model portfolios or to work directly with a financial advisor.
Clients should consider the level and complexity of the advisory services to be provided when
negotiating the account fee (or the advisor fee portion of the account fee, as applicable) with
GWAG. With regard to accounts utilizing third-party portfolio managers under aggregate, all-
in-one account fee structures (including MAS, PWP and the legacy MWP fee structure),
because the portion of the account fee retained by GWAG varies depending on the portfolio
strategist fee associated with a portfolio, GWAG has a financial incentive to select one portfolio
instead of another portfolio.
pg. 7
RETIREMENT PLAN CONSULTING:
Our firm provides retirement plan consulting services to employer plan sponsors on an
ongoing basis. Generally, such consulting services consist of assisting employer plan sponsors
in establishing, monitoring, and reviewing their company's participant-directed retirement
plan. GWAG may provide investment advisory and consulting services to participant directed
retirement plans per the terms and conditions of a Retirement Plan Services Agreement
between GWAG and the Plan Sponsor. For such engagements, GWAG shall assist the Plan
sponsor with the selection of an investment platform from which Plan participants shall make
their respective investment choices (which may include investment strategies devised and
managed by GWAG), and, to the extent engaged to do so, may also provide corresponding
education to assist the participants with their decision-making process. These services shall
generally be provided on an unbundled (non-wrap fee) percentage of Plan assets basis as
discussed in the Retirement Plan Services Agreement, but the GWAG, at its discretion, could
also provide certain Plan consulting services on an hourly or fixed fee basis.
As the needs of the plan sponsor dictate, areas of advising could include: investment options,
plan structure and participant education. Retirement Plan Consulting services may include:
• Establishing an Investment Policy Statement – Our firm will assist in the
development of a statement that summarizes the investment goals and objectives
along with the broad strategies to be employed to meet the objectives.
• Investment Options – Our firm will work with the Plan Sponsor to evaluate existing
investment options and make recommendations for appropriate changes.
• Asset Allocation and Portfolio Construction – Our firm will develop strategic asset
allocation models to aid Participants in developing strategies to meet their
investment objectives, time horizon, financial situation and tolerance for risk.
• Investment Monitoring – Our firm will monitor the performance of the
investments and notify the client in the event of over/underperformance and in
times of market volatility.
In providing services for retirement plan consulting, our firm does not provide any advisory
services with respect to the following types of assets: employer securities, real estate
(excluding real estate funds and publicly traded REITS), participant loans, non-publicly traded
securities or assets, other illiquid investments, or brokerage window programs (collectively,
“Excluded Assets”). All retirement plan consulting services shall be in compliance with the
applicable state laws regulating retirement consulting services. This applies to client accounts
that are retirement or other employee benefit plans (“Plan”) governed by the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”). If the client accounts are part
of a Plan, and our firm accepts appointment to provide services to such accounts, our firm
acknowledges its fiduciary standard within the meaning of Section 3(21) or 3(38) of ERISA as
designated by the Retirement Plan Consulting Agreement with respect to the provision of
services described therein. When providing investment advice to you regarding a retirement
plan account or individual retirement plan account, GWAG is a fiduciary with the meaning of
Title I of the Employee Retirement Security Act and/or the Internal Revenue Code, as
applicable, which are laws governing retirement accounts. The way GWAG is compensated
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.