A. Description of the Advisory Firm
B. Types of Advisory Services
platforms in any way and receive no compensation from them for using their platform. A
link will be provided to the client allowing them to connect an account(s) to one or both
of the platforms. Once client account(s) is connected to the platform, BWCM will review
the current account allocations. ByAllAccounts is used for non-discretionary
management, meaning we can recommend trades to the client, but the client bears the
responsibility of performing the trades. FeeX is used for discretionary management,
where BWCM, when deemed necessary, will rebalance the account considering client
investment goals, risk tolerance, and current economic and market trends.
BWCM may use DPL Financial Partners, LLC (“DPL”) for insurance product analysis and
recommendations. The client is under no obligation to use DPL's service, and may seek
insurance advice from any licensed agent. The insurance products and lower-cost fee
structures available from DPL may differ from those available from other third-party
insurance agents. BWCM does NOT receive compensation for insurance products selected
by the client, whether secured through DPL or any other agent.
Financial Planning
Financial plans and financial planning may include, but are not limited to: investment
planning; life insurance; tax concerns; retirement planning; college planning; and
debt/credit planning.
In offering financial planning, a conflict exists between the interests of the investment
adviser and the interests of the client. The client is under no obligation to act upon the
investment adviser’s recommendation, and, if the client elects to act on any of the
recommendations, the client is under no obligation to affect the transaction through the
investment adviser. This statement is required by California Code of Regulations, 10 CCR
Section 260.235.2.
Subscription Service
BWCM has a subscription service where clients can pay $25/month to have ongoing
access to their online financial plan. The fee also covers any data updates. It does not cover
ongoing advice.
Services Limited to Specific Types
of Investments
BWCM generally limits its investment advice to mutual funds, fixed income securities,
real estate funds (including REITs), insurance products including annuities, equities,
hedge funds, private equity funds, ETFs (including ETFs in the gold and precious metal
sectors), treasury inflation protected/inflation linked bonds, commodities, non-U.S.
securities, venture capital funds and private placements, although BWCM primarily
recommends portfolio of ETFs and mutual funds. BWCM may use other securities as well
to help diversify a portfolio when applicable.
BWCM will tailor a program for each individual client. This will include an interview
session to get to know the client’s specific needs and requirements as well as a plan that
will be executed by BWCM on behalf of the client. BWCM may use model allocations
together with a specific set of recommendations for each client based on their personal
restrictions, needs, and targets. Clients may impose restrictions in investing in certain
securities or types of securities in accordance with their values or beliefs. However, if the
restrictions prevent BWCM from properly servicing the client account, or if the restrictions
would require BWCM to significantly deviate from its standard suite of services, BWCM
reserves the right to end the relationship.
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees, transaction costs, fund expenses, and other administrative
fees. BWCM does NOT participate in any wrap fee programs.
BWCM has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$ 125,931,990 $ 2,078,429 April 5, 2024
Lower fees for comparable services may be available from other sources.
Portfolio Management Fees
Total Assets Under Management Annual Fees
$0 - $1,000,000 0.80%
$1,000,001 - $3,000,000 0.65%
$3,000,001 - $5,000,000 0.50%
$5,000,001 - $10,000,000 0.30%
$10,000,001 - And Up 0.15%
C. Client Tailored Services and Client Imposed Restrictions
D. Wrap Fee Programs
E. Assets Under Management