A. Firm Information
Eagle Bluffs Wealth Management LLC (“Eagle Bluffs” or the “Advisor”) is a registered investment advisor with the
SEC, located in the state of Missouri. The Advisor is organized as a Limited Liability Company (LLC) under the
laws of the State of Missouri. Eagle Bluffs was founded in October 2019, and is owned and operated by Nicholas
J. Thurwanger (Founder and Chief Investment Officer). This Disclosure Brochure provides information regarding
the qualifications, business practices, and the advisory services provided by Eagle Bluffs.
B. Advisory Services Offered
Eagle Bluffs offers investment advisory services to individuals, families trusts, estates, foundations and
businesses (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. Eagle Bluffs’ 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
Eagle Bluffs provides wealth management services for its Clients. These services generally include
discretionary investment management services in connection with a broad range of financial planning services.
These services are described below.
Investment management services – Eagle Bluffs provides customized wealth management solutions for its
Clients. The Advisor believes in investing to meet client's goals. This is achieved through continuous personal
Client contact and interaction while providing discretionary investment management and related advisory
services. Eagle Bluffs works closely with each Client to identify their investment goals and objectives as well as
risk tolerance and financial situation in order to create a custom portfolio strategy.
The Advisor is a long-term focused investor and primarily invests in assets the Advisor believes to be
undervalued by the markets at this time, but over time the markets will allow additional value to pick up. The
Advisor employs a top down-approach first in selecting areas to invest in at a high level. Once those specific
areas are identified, Eagle Bluffs employs a bottom-up approach to select the specific assets that the Advisor
believes will help best meet the Client’s needs.
Eagle Bluffs will construct investment portfolios utilizing exchange-listed equity securities, or exchange-traded
funds (“ETFs”), active mutual funds, passive mutual funds, individual bonds, and other types of investment, as
appropriate for the Client. In certain circumstances, the Advisor may utilize options, leveraged or inverse ETFs.
The Advisor may retain certain legacy investments based on portfolio fit and/or tax considerations.
Eagle Bluffs’ 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. Eagle Bluffs 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.
Eagle Bluffs evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. Eagle Bluffs may recommend, on occasion, redistributing investment allocations to diversify
the portfolio. Eagle Bluffs 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. Eagle Bluffs
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
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overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet
Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
At no time will Eagle Bluffs accept or maintain custody of a Client’s funds or securities, except for the limited
authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at
the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
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 Services – Eagle Bluffs will provide a variety of financial planning and consulting services to
Clients as part of its wealth management services. Services are offered in several areas of a Client’s financial
situation, depending on their goals and objectives. 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, personal savings, education savings, and other areas of a Client’s financial
situation.
A financial plan developed for, or financial consultation rendered to the Client will 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.
Eagle Bluffs 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.
C. Client Account Management
Prior to engaging Eagle Bluffs to provide wealth management services, each Client is required to enter into an
agreement with the Advisor that defines the terms, conditions, authority and responsibilities of the Advisor and
the Client. These services may include:
• Establishing an Investment Strategy – Eagle Bluffs, in connection with the Client, will develop a strategy
that seeks to achieve the Client’s goals and objectives.
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• Asset Allocation – Eagle Bluffs 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 – Eagle Bluffs will develop a portfolio for the Client that is intended to meet the
stated goals and objectives of the Client.
• Investment Management and Supervision – Eagle Bluffs will provide investment management and
ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Eagle Bluffs does not manage or place Client assets into a wrap fee program. Investment management services
are provided directly by Eagle Bluffs.
E. Assets Under Management
As of December 31,2022, Eagle Bluffs manages $173,521,203 in Client assets, $170,801,681 of which are
managed on a discretionary basis and $2,719,522 on a non-discretionary basis. Clients may request more
current information at any time by contacting the Advisor.