A. Firm Information
Willow Financial LLC (“Willow Financial” or the “Advisor”) is a registered investment advisor located in the State of
Arkansas and is organized as a Limited Liability Company (“LLC”) under the laws of the State of Arkansas. Willow
Financial was founded in June 2023 and is owned and operated by Steven M. Schmitt, CFP® (Principal and Wealth
Advisor) and Philip A. Kapler (Principal and Wealth Advisor / Chief Compliance Officer).
This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory
services provided by Willow Financial. For information regarding this Disclosure Brochure, please contact Philip A.
Kapler (Chief Compliance Officer) at (479) 709-3949.
B. Advisory Services Offered
Willow Financial offers wealth management and financial planning services to individuals, high net worth individuals,
trusts, and estates (each referred to as a “Client”).
The Advisor serves as a fiduciary to 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. Willow Financial's 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.
Wealth Management Services
Willow Financial provides tailored wealth management solutions for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary investment management services and financial
planning services. Willow Financial 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. Willow Financial will then construct an
investment portfolio either through its internal investment management and/or the use of unaffiliated money
managers (herein “Independent Managers” – see below).
Internal Investment Management – When constructing portfolios for internal investment management, the Advisor
will typically utilize exchange-traded funds (“ETFs”) or mutual funds. The Advisor will evaluate legacy holding for
portfolio fit and tax considerations.
Willow Financial’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. Willow Financial will construct, implement and monitor the portfolio 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 acceptance by
the Advisor. Willow Financial evaluates and selects investments for inclusion in Client portfolios only after applying
its internal due diligence process. Willow Financial may recommend, on occasion, redistributing investment
allocations to diversify the portfolio. Willow Financial may recommend specific positions to increase sector or asset
class weightings. The Advisor may recommend employing cash positions as a possible hedge against market
movement. Willow Financial may recommend
At no time, will Willow Financial accept or maintain custody of a Client’s funds or securities, except for authorized
deduction of the Advisor’s fees. All Client assets will be managed within their designated account[s] at the
Custodian, pursuant to the Client investment advisory agreement.
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
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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 Services – Willow Financial will provide a variety of financial planning and consulting services to
Clients as part of its overall wealth management services. Willow Financial will also provide standalone financial
planning pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s
financial situation, depending on their goals and objectives. Generally, such financial planning services involve
preparing a formal financial plan or rendering a specific 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, estate planning, personal savings, education savings, insurance needs
and other areas of a Client’s financial situation.
A financial plan developed for, or 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.
Willow Financial may also refer Clients to an accountant, attorney or other specialists, as appropriate for their
unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the
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 pose 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, as it would
increase the amount of advisory fees paid to the Advisor. Clients are not obligated to 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.
Use of Independent Managers - Willow Financial will often 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
investment portfolio, based on the Client’s needs and objectives. The Advisor will perform initial and ongoing
oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with Clients
investment objectives and overall best interests. The Advisor will also assist the Client in the development of the
initial policy recommendations and managing the ongoing Client relationship. The Client will be provided with the
Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate
disclosures).
C. Client Account Management
Prior to engaging Willow Financial to provide investment 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 may include:
• Establishing an Investment Strategy – Willow Financial, in connection with the Client, will develop a strategy
that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Willow Financial 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 – Willow Financial will develop a portfolio for the Client that is intended to meet the
stated goals and objectives of the Client.
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• Investment Management and Supervision – Willow Financial will provide investment management and
ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Willow Financial does not manage or place Client assets into a wrap fee program. Investment management
services are provided directly by Willow Financial.
E. Assets Under Management
As of September 11, 2023, Willow Financial manages $32,012,872 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.