Pensionmark Financial Group, LLC (“Pensionmark” or “Adviser”) was established in March 2015.
Pensionmark is a wholly owned subsidiary of WIA Holdings, LLC.
Pensionmark sponsors a wrap fee program (“Pensionmark Portfolio”) that is custodied with Schwab
Institutional (“Schwab”), a division of Charles Schwab & Co, Inc. Pensionmark provides advisory services,
giving continuous advice based on the client’s individual needs. Through personal discussions in which
goals and objectives based upon the client’s personal objectives are established, the firm will develop a
personal investment policy based upon the Pensionmark Client Profile and manage the portfolio according
to the criteria.
Through Pensionmark Portfolio, Pensionmark provides investment recommendations based upon a
review of the client’s investment goals, financial situation and risk tolerance. Pensionmark Portfolio
accounts may be managed on a discretionary or non-discretionary basis, as specified in the written
advisory agreement (“Agreement”). Clients have the option of accepting Pensionmark’s
recommendations or selecting alternative investments for their accounts. Pensionmark offers periodic
rebalancing of the securities or upon the client’s direction. We may also provide monitoring and reporting
of portfolio performance to clients on a periodic basis.
Third-Party Money Management
Pensionmark has access to a wide range of non-affiliated investment advisors (“third-party money
managers”) via the Envestnet ENV2 platform to offer asset allocation and asset management services to
Pensionmark advisory clients. Each IAR shall assist their client in formulating a strategic investment
portfolio based on the client's investment objectives. Once formulated, if appropriate for the client, a
suitable third-party money manager is selected to implement and continually manage the portfolio. In
preparing the portfolio, each IAR may set restrictions or limitations on the management of the account
and will explain to the client the continual account activity transacted by the third-party money manager.
Also, Pensionmark will periodically review the current and historical performance record of each third-
party money manager.
Pensionmark has also entered into additional agreements with various non-affiliated investment advisors
(“third-party money managers”) not available on the Envestnet platform to offer asset allocation and
asset management services to Pensionmark advisory clients. In the same way as mentioned above, each
IAR shall assist their client in formulating a strategic investment portfolio based on the client's investment
objectives. Once formulated, a suitable third-party money manager is selected to implement and
continually manage the portfolio. In preparing the portfolio, each IAR may set restrictions or limitations
on the management of the account and will explain to the client the continual account activity transacted
by the third-party money manager. Also, Pensionmark will periodically review the current and historical
performance record of each third-party money manager.
The relationship of Pensionmark with any third-party money manager will be clearly communicated to all
clients in the third-party money manager’s Client Services Agreement and/or other similar
documentation. Each third-party money manager is required to provide Pensionmark and the IAR with a
disclosure document statement, typically a copy of their Form ADV 2A. The third-party money manager’s
Form ADV 2A will be provided to the client by IAR.
Additionally, Pensionmark advisors may recommend the use of WealthPath models to Clients. These
models are managed by WealthPath Advisors, LLC. WealthPath advisors are registered as investment
advisor representatives of Pensionmark. When offered to their own clients there are no additional fees;
however, when offered to the client of other advisors (including other Pensionmark advisors), a portion
of the total advisory fee charged is paid to WealthPath in exchange for their investment management
services. This may create a conflict of interest, because although the fee paid by the Client is not
impacted, Pensionmark may receive additional remuneration when WealthPath is selected as the
manager of the Clients’ assets because WealthPath is not an outsourced third-party money manager.
Pensionmark’s fiduciary responsibility is to always choose the manager or portfolio that is in the best
interest of the client, and Pensionmark does not promote the exclusive use of WealthPath as a third-party
manager alternative.
Pensionmark may recommend stocks, bonds, mutual funds, or other assets of any kind, consistent with
the client’s investment objectives. Most types of securities are eligible for purchases in the Pensionmark
Portfolio account including but not limited to, common and preferred stocks, exchange traded funds,
closed end funds, unit investment trusts, corporate and government bonds, certificate of deposit, mutual
funds, and certain wrap class alternative investments, such as hedge funds.
Pensionmark also offers a non-wrap program, Pensionmark Wealth, which is described in the firm’s ADV
Part 2A. In a wrap fee program, clients are charged an all-inclusive wrap fee on Program Assets that covers
advisory, execution, custodial and reporting services on Eligible Assets. A portion of these fees will be paid
to Pensionmark for advisory services. Clients may incur certain charges imposed by custodians, brokers,
and other third parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot
differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage
accounts and securities transactions. Mutual funds and exchange traded funds also charge internal
management fees, which are disclosed in the fund’s prospectus. Such charges, fees and commissions are
exclusive of and in addition to Pensionmark’s fee, and Pensionmark shall not receive any portion of these
commissions, fees, and costs.
Reasonable Restrictions
Each client has the ability to impose reasonable restrictions on the management of his/her account,
including the designation of particular securities or types of securities that should not be purchased for
the account, or that should not be sold if held in the account. If a client’s instructions are unreasonable or
an investment advisor representative believes that the instructions are inappropriate for the client,
Pensionmark will notify the client that, unless the instructions are modified, it may cancel the instructions
in the client’s account. A client will not be able to provide instructions that prohibit or restrict the
Investment Adviser of an open-end or closed-end mutual fund or ETF with respect to the purchase or sale
of specific securities or types of securities within the fund.
Fees and Compensation
Fees for the Pensionmark Portfolio program will cover advisory services, performance measurement,
transaction costs, custody services, and trading. These fees do not cover the fees and expenses of any
underlying funds purchased in the account. Fees are based on the assets in the account and are generally
assessed monthly.
Pensionmark Portfolio accounts are charged an all-inclusive “wrap fee” on Program Assets that covers
advisory, execution, custodial and reporting services on Eligible Assets. Clients pay all Pensionmark
Portfolio’s usual and customary commissions, transaction fees and other charges for transactions on
Excluded Assets. Commissions and fees on Excluded Assets and other charges will be assessed against a
client’s account on or about the transaction date or such other date assessed by the Pensionmark Portfolio
Program. See the Program Fees and Account Minimums section below for details of fee exclusions,
calculations, refunds and other information. The imposition of the minimum fees may cause the effective
Program Fee rate (expressed as a percentage) to be greater than the fee rates specified in the table below.
The specific manner in which fees are charged by the Firm is established in a client’s written agreement. Fees
are generally based on a percentage of assets under management as of the last day in the previous billing
period, calculated at an annual rate, and billed in advance based on the number of days in that particular
period. In some instances, other methodologies for calculations of fees (i.e., fees payable in arrears or on a
quarterly basis) may be employed and will be specifically outlined in the client’s Agreement. Fees are usually
based on the assets in the account per the schedule below and in some instances, may be negotiated.
Pensionmark may also engage with clients under a flat-fee structure; however, the fees assessed will not
exceed the percentage fees outlined below.
Fee Schedule
Gross Market Value Maximum Annual Fee
$0 - $500,000 3.00%
$500,001 - $1,000,000 2.75%
$1,000,001 - $2,000,000 2.50%
$2,000,001 - $5,000,000 2.25%
Over $5,000,001 2.00%
A minimum annual fee of
$30 per quarter ($120 annually) will be charged. Accordingly, a client may pay an
effective rate greater than the rate specified in the fee schedule shown above. The firm, in its sole discretion,
may waive its minimum fee and/or charge a lesser investment advisory fee based upon certain criteria (e.g.,
historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets,
dollar amounts of assets to be managed, related accounts, account composition, client negotiations, etc.).
In addition to the fees outlined above, a separate fee of up to 0.05% (5 basis points) may be levied by Envestnet
or Tamarac, the firm's technology platforms used for billing and reporting (“platform fee”). This fee may be
levied in addition to the advisory fee assessed for investment management services and is not billed as a
separate line item. The annual Envestnet/Tamarac platform fee will not exceed 0.05% or a $100.00 minimum
annual fee, prorated monthly, whichever is greater. Accordingly, a client might pay an effective rate greater
than the rate specified in the fee schedule on their Advisory Agreement. The $100.00 fee resets annually based
on the month the account was originally opened. In the event a third-party money manager is implemented
in a client portfolio, the annual Envestnet/Tamarac platform fee will not exceed 0.15% or a $150.00 minimum
annual fee, prorated monthly, whichever is greater. This fee may be reduced based on the amount of investable
assets and is in addition to the advisory fee assessed by Pensionmark and the third-party asset manager for
investment management services.
If a client’s Agreement becomes effective as of a day other than the first day of a billing period or if a
termination of a client’s Agreement is effective on a day other than the last day of a billing period, the Fees for
that billing period shall be prorated (calculated on a per diem basis) and the applicable amount promptly paid
by Client to Pensionmark or refunded by Pensionmark to Client, as the case may be. Fees will be deducted from
the account directly unless the Client requests to be billed separately. Generally, no further proration is done
for additions or withdrawals made during the fee period.
A portion of the fees described herein will be paid to Pensionmark Financial Advisors in connection with
the provision of investment advice and/or client-related services within those programs. This
compensation may be more than Pensionmark’s Financial Advisors would receive if clients paid separately
for investment advice, brokerage, and other services and therefore, Pensionmark Financial Advisors may
have a financial incentive to recommend the program services over other programs or services.
Load and no-load mutual funds may pay annual distribution charges, sometimes referred to as 12b-1 fees.
12b-1 fees come from fund assets, therefore, indirectly from client assets. Some mutual funds within this
program pay 12(b)-1 service fees (normally 0.25% per year) to the Custodian. For certain ERISA accounts,
12b-1 fees in whole or in part are credited back to the account to offset fees charged. The mutual funds
the Firm could purchase or recommend offer a variety of share classes, including some that do not charge
12(b)-1 fees and are, therefore, less expensive. Typically, Pensionmark does not recommend mutual funds
that charge 12(b)-1 fees when other share classes are available. However, there are instances in which
Pensionmark would recommend a mutual fund that carries a 12(b)-1 fee, even when a lower-cost share
class is available for the same fund. For example, a lower-cost class share may not be available to
Pensionmark due to investment minimums, or the custodian may make available certain funds which do
not carry a transaction fee. Pensionmark does not receive any part of the fees charged by Mutual Funds,
and as a fiduciary to your account, will select the most appropriate fund share class.
The wrap program may cost the client more or less than purchasing such services separately and will
depend on the trading activity in the client’s account. The cost of non-wrapped investment advisory
services may be lower than investment advisory services provided under the wrap program. Because
Pensionmark may receive more compensation from a client from the client’s participation in the Program
than if the client received advisory services and brokerage services separately, Pensionmark may have a
financial incentive to recommend the Program to clients over other types of advisory services.
Pensionmark may give advice to others that may be different from the advice given to Program clients.
Clients should consider the value of the additional consulting services when making such comparisons.
The combination of custodial, consulting, and brokerage services may not be available separately or may
require multiple accounts, documentation, and fees. In addition, certain advisors may not be available to
certain clients outside the consulting relationship because of minimum account sizes, fee schedules,
geographic availability, or other factors. A non-wrapped pricing arrangement may be more cost effective
for accounts that do not experience frequent trading activity. Because of the single fee charged to a
Program account, Pensionmark may be regarded as having a conflict of interest in that it may realize a
greater profit on a Program account with a relatively low rate of portfolio turnover compared to other
types of accounts, assuming the same level of fees. However, Pensionmark is constrained by fiduciary
principles to act in its clients’ best interests.
All fees may be subject to negotiation. When negotiating fees, factors considered include, but are not
limited to: (i) clients with multiple accounts; (ii) size of the account; (iii) a prior or existing relationship;
and (iv) a client’s particular needs or financial characteristics. Because fees may vary, clients with existing
accounts may be charged fees which differ from the foregoing fee schedules, or the fees paid by other
clients.
Other costs that may be assessed and that are not part of those outlined above include fees for portfolio
transactions executed away from the broker/custodian selected by the client, dealer mark-ups, electronic
fund and wire transfers, spreads paid to market-makers, and exchange fees, among others.
Brokers/custodians may charge clients certain additional and/or minimum fees.
The Program wrap fee does not include: (i) annual account fees or other administrative fees, such as wire
fees, charged by custodians (ii) certain odd-lot differentials, transfer taxes, transaction fees mandated by
the Securities Act of 1934, and charges imposed by law with regard to transactions in the client’s account;
and (iii) advisory fees, expenses or sales charges (loads) of mutual funds (including money market funds),
closed-end investment companies or other managed investments, if any, held in client’s account.
Account Termination
Client and/or the firm may initiate termination of the contract at any time by sending written notice to
the contra party and will be accepted the day that it is received by the contra party. Pensionmark does
not charge a fee for terminating the account, but the custodian may charge a termination fee.
Upon written receipt of notice to terminate its client Agreement, and unless specific transfer instructions are
received, Pensionmark and its representative(s) will cease advisory services. Should the client provide specific
instructions to liquidate, Pensionmark will proceed with liquidation of the client’s account in an orderly and
efficient manner. There will not be a charge by Pensionmark for such redemption; however, the client should
be aware that certain securities impose redemption fees as stated in each company’s prospectus. Additionally,
custodians may assess additional redemption fees for short-term liquidations. Clients must keep in mind that
the decision to liquidate security issues or mutual funds may result in tax consequences that should be
discussed with the client’s tax advisor. Factors that may affect the orderly and efficient manner would be size
and types of issues, liquidity of the markets, and market makers’ abilities. Should the necessary securities’
markets be unavailable, and trading suspended, efforts to trade will be done as soon as possible following their
reopening. Due to the administrative processing time needed to terminate client’s investment advisory
services and communicate the instructions to client’s Investment Advisor, termination orders received from
clients are not market orders; it may take several business days under normal market conditions to process the
client’s request. During this time, the client’s account is subject to market risk. Pensionmark and its
representative(s) are not responsible for market fluctuations of the client’s account from time of written notice
until complete liquidation. All efforts will be made to process the termination in an efficient and timely
manner.