Overview
- Headquarters
- Auburn, CA
- Total Firm Assets
- $121 million
- Average High-Net-Worth Client Portfolio Size
- $1.6 million
Fee Structure
Primary Fee Schedule (ADV PART 2A/2B SEC)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $500,000 | 1.45% |
| $500,001 | $1,000,000 | 1.25% |
| $1,000,001 | $5,000,000 | 1.00% |
| $5,000,001 | and above | 0.75% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $13,500 | 1.35% |
| $5 million | $53,500 | 1.07% |
| $10 million | $91,000 | 0.91% |
| $50 million | $391,000 | 0.78% |
| $100 million | $766,000 | 0.77% |
Clients
- High-Net-Worth Share of Firm Assets
- 56.27%
- Number of High-Net-Worth Clients
- 44
- Total Client Accounts
- 516
- Discretionary Accounts
- 516
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting, Investment Advisor Selection
Regulatory Filings
- SEC CRD Number
- 290853
Primary Brochure: ADV PART 2A/2B SEC (2026-06-22)
View Document Text
F O R M A D V P A R T 2 A
D I S C L O S U R E B R O C H U R E
Arrow Wealth Advisors, Inc.
California Office Address:
10831 Combine Rd.
Suite A
Auburn, CA 95602
Texas Office Address:
400 N Loop 1604 E
Suite 280
San Antonio, TX 78232
Tel: 210-541-9967
Fax: 210-541-9967
Dan@ArrowWealthAdvisors.com
Website:
www.ArrowWealthAdvisors.com
J U N E 2 2 , 2 0 2 6
This brochure provides information about the qualifications and business practices of Arrow
Wealth Advisors, Inc. Being registered as a registered investment adviser does not imply a
certain level of skill or training. If you have any questions about the contents of this brochure,
please contact us at 210-541-9967. The information in this brochure has not been approved or
verified by the United States Securities and Exchange Commission, or by any state securities
authority.
Additional information about Arrow Wealth Advisors, Inc. (CRD #290853) is available on the
SEC’s website at www.adviserinfo.sec.gov
i
Item 2: Material Changes
Annual Update
The Material Changes section of this brochure will be updated annually or when material
changes occur since the previous release of the Firm Brochure.
Material Changes since the Last Update
Since the last filing on February 19, 2026, the following is being updated:
• The entire brochure for SEC Registration.
Full Brochure Available
This Firm Brochure being delivered is the complete brochure for the Firm.
ii
Item 3: Table of Contents
Form ADV – Part 2A – Firm Brochure
Item 1: Cover Page
Item 2: Material Changes .................................................................................................................... ii
Annual Update ................................................................................................................................................................... ii
Material Changes since the Last Update.................................................................................................................. ii
Full Brochure Available .................................................................................................................................................. ii
Item 3: Table of Contents ................................................................................................................... iii
Item 4: Advisory Business .................................................................................................................. 1
Firm Description ............................................................................................................................................................... 1
Types of Advisory Services ........................................................................................................................................... 1
Client Tailored Services and Client Imposed Restrictions ............................................................................... 3
Wrap Fee Programs ......................................................................................................................................................... 3
Client Assets Under Management .............................................................................................................................. 3
Item 5: Fees and Compensation ....................................................................................................... 3
Method of Compensation and Fee Schedule .......................................................................................................... 3
Client Payment of Fees ................................................................................................................................................... 6
Additional Client Fees Charged ................................................................................................................................... 6
Prepayment of Client Fees ............................................................................................................................................ 6
External Compensation for the Sale of Securities to Clients ........................................................................... 6
Item 6: Performance-Based Fees and Side-by-Side Management ........................................ 6
Sharing of Capital Gains ................................................................................................................................................. 6
Item 7: Types of Clients ....................................................................................................................... 7
Description .......................................................................................................................................................................... 7
Account Minimums .......................................................................................................................................................... 7
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................ 7
Methods of Analysis ......................................................................................................................................................... 7
Investment Strategy ........................................................................................................................................................ 8
Security Specific Material Risks .................................................................................................................................. 8
Item 9: Disciplinary Information ..................................................................................................... 9
Criminal or Civil Actions ................................................................................................................................................ 9
Administrative Enforcement Proceedings .......................................................................................................... 10
Self- Regulatory Organization Enforcement Proceedings ............................................................................ 10
iii
Item 10: Other Financial Industry Activities and Affiliations ............................................. 10
Broker-Dealer or Representative Registration ................................................................................................. 10
Futures or Commodity Registration ...................................................................................................................... 10
Material Relationships Maintained by this Advisory Business and Conflicts of Interest ................ 10
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ............. 10
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading ................................................................................................................................................... 10
Code of Ethics Description ......................................................................................................................................... 10
Investment Recommendations Involving a Material Financial Interest and Conflict of Interest. 11
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest 11
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities
Transactions and Conflicts of Interest .................................................................................................................. 11
Item 12: Brokerage Practices ......................................................................................................... 12
Factors Used to Select Broker-Dealers for Client Transactions ................................................................. 12
Aggregating Securities Transactions for Client Accounts ............................................................................. 15
Item 13: Review of Accounts ........................................................................................................... 15
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons
Involved ............................................................................................................................................................................. 15
Review of Client Accounts on Non-Periodic Basis ........................................................................................... 16
Content of Client Provided Reports and Frequency ........................................................................................ 16
Item 14: Client Referrals and Other Compensation ................................................................ 16
Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of
Interest ............................................................................................................................................................................... 16
Advisory Firm Payments for Client Referrals .................................................................................................... 16
Item 15: Custody .................................................................................................................................. 16
Account Statements ...................................................................................................................................................... 16
Item 16: Investment Discretion ..................................................................................................... 17
Discretionary Authority for Trading...................................................................................................................... 17
Item 17: Voting Client Securities ................................................................................................... 17
Proxy Votes ...................................................................................................................................................................... 17
Item 18: Financial Information ...................................................................................................... 17
Balance Sheet .................................................................................................................................................................. 17
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments
to Clients ............................................................................................................................................................................ 17
Bankruptcy Petitions during the Past Ten Years .............................................................................................. 17
iv
Brochure Supplement (Part 2B of Form ADV) .......................................................................... 19
Principal Executive Officer – Daniel Seltzer, CFP® ........................................................................................... 19
Item 2 - Educational Background and Business Experience ....................................................................... 19
Item 3 - Disciplinary Information ........................................................................................................................... 20
Item 4 - Other Business Activities Engaged In ................................................................................................... 21
Item 5 - Additional Compensation .......................................................................................................................... 21
Item 6 - Supervision ..................................................................................................................................................... 21
v
Item 4: Advisory Business
Firm Description
Arrow Wealth Advisors, Inc. (“Arrow Wealth”) was founded in 2014 and became a
Registered Investment Advisor in 2017. Daniel Seltzer is 100% owner. Arrow Wealth, its
representatives or any of its employees will disclose to Clients all material conflicts of
interest.
Types of Advisory Services
FINANCIAL PLANNING AND CONSULTING
If financial planning services are applicable, a thorough review of all applicable topics
including but not limited to, Wills, Estate Plans and Trusts, Investments, Taxes, Qualified
Plans, Insurance, Retirement Income, Social Security, Divorce Planning, and College Planning
will be reviewed. If a conflict of interest exists between the interests of Arrow Wealth and
the interests of the Client, the Client is under no obligation to act upon Arrow Wealth’s
recommendation. If the Client elects to act on any of the recommendations, the Client is
under no obligation to effect the transaction through Arrow Wealth. Financial plans will be
completed and delivered inside of ninety (90) days contingent upon timely delivery of all
required documentation.
ERISA PLAN SERVICES
Arrow Wealth provides service to qualified retirement plans including 401(k) plans, 403(b)
plans, pension and profit-sharing plans, cash balance plans, and deferred compensation
plans. Arrow Wealth may act as a 3(21) advisor:
Limited Scope ERISA 3(21) Fiduciary. Arrow Wealth may serve as a limited scope ERISA
3(21) fiduciary that can advise, help and assist plan sponsors with their investment decisions
on a non-discretionary basis. As an investment advisor Arrow Wealth has a fiduciary duty to
act in the best interest of the Client. The plan sponsor is still ultimately responsible for the
decisions made in their plan, though using Arrow Wealth can help the plan sponsor delegate
liability by following a diligent process.
1. Fiduciary Services are:
• Provide non-discretionary investment advice to the Client about asset classes and
investment alternatives available for the Plan in accordance with the Plan’s investment
policies and objectives. Client will make the final decision regarding the initial selection,
retention, removal and addition of investment options. Arrow Wealth acknowledges that
it is a fiduciary as defined in ERISA section 3 (21) (A) (ii).
• Assist the Client in the development of an investment policy statement (“IPS”). The IPS
establishes the investment policies and objectives for the Plan. Client shall have the
ultimate responsibility and authority to establish such policies and objectives and to
adopt and amend the IPS.
• Provide non-discretionary investment advice to the Plan Sponsor with respect to the
selection of a qualified default investment alternative for participants who are
automatically enrolled in the Plan or who have otherwise failed to make investment
elections. The Client retains the sole responsibility to provide all notices to the Plan
participants required under ERISA Section 404(c) (5) and 404(a)-5.
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• Assist in monitoring investment options by preparing periodic investment reports that
document investment performance, consistency of fund management and conformance
to the guidelines set forth in the IPS and make recommendations to maintain, remove or
replace investment options.
• Meet with Client on a periodic basis to discuss the reports and the investment
recommendations.
2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and the
investment alternatives available to them under the Plan. Client understands Arrow
Wealth’s assistance in education of the Plan participants shall be consistent with and
within the scope of the Department of Labor’s definition of investment education
(Department of Labor Interpretive Bulletin 96-1). As such, Arrow Wealth does not
provide fiduciary advice as defined by ERISA 3(21)(A)(ii) to the Plan participants.
Advisor will not provide investment advice concerning the prudence of any investment
option or combination of investment options for a particular participant or beneficiary
under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan
participation among the employees and investment and financial understanding by the
employees.
Arrow Wealth may provide these services or, alternatively, may arrange for the Plan’s other
providers to offer these services, as agreed upon between Arrow Wealth and Client.
3. Arrow Wealth has no responsibility to provide services related to the following types of
assets (“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and similar
vehicles); or
• Other hard-to-value or illiquid securities or property.
Excluded Assets will not be included in calculation of Fees paid to Arrow Wealth on the
ERISA Agreement.
Specific services will be outlined in detail to each plan in the 408(b)2 disclosure.
ASSET MANAGEMENT
Arrow Wealth offers discretionary asset management services to advisory Clients. Arrow
Wealth will offer Clients ongoing asset management services through determining individual
investment goals, time horizons, objectives, and risk tolerance. Investment strategies,
investment selection, asset allocation, portfolio monitoring and the overall investment
program will be based on the above factors. The Client will authorize Arrow Wealth
discretionary authority to execute selected investment program transactions as stated
within the Investment Advisory Agreement.
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Arrow Wealth also offers discretionary direct asset management services to advisory Clients
depending on the one of the programs below:
Betterment Platform
For Advisory Clients with accounts that fall below the minimum investment requirements
associated with other investment strategies, Arrow Wealth may offer discretionary direct
asset management services utilizing The Betterment for Advisors platform for digital
services. On this platform, Arrow Wealth has the discretion to delegate the management of
all or part of the Assets to one or more independent investment managers or independent
investment management programs (“Independent Managers”). To the extent utilized,
Independent Managers will have limited power-of-attorney and trading authority over those
assets Arrow Wealth directs to them for management. Arrow Wealth will supervise the
Independent Managers and monitor and review asset allocation and asset performance.
Arrow Wealth may terminate or change Independent Managers when, in Arrow Wealth’s
sole discretion, Arrow Wealth believes such termination or changes is in your best interest.
Client Tailored Services and Client Imposed Restrictions
The goals and objectives for each Client are documented in our Client files. Investment
strategies are created that reflect the stated goals and objectives. Clients may impose
restrictions on investing in certain securities or types of securities. Agreements may not be
assigned without written Client consent.
Wrap Fee Programs
Arrow Wealth does not sponsor or participate in any wrap fee programs.
Client Assets Under Management
Arrow Wealth has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts:
$121,234,291
$0
Date Calculated:
May 31, 2026
Item 5: Fees and Compensation
Method of Compensation and Fee Schedule
FINANCIAL PLANNING AND CONSULTING
Arrow Wealth charges a fixed or hourly fee for financial planning. The fixed fee charge is
based on the complexity and unique Client needs for financial planning services. Prior to the
planning process the Client will be provided an estimated plan fee. Services are completed
and delivered inside of ninety (90) days contingent upon timely delivery of all required
documentation. Client may cancel within five (5) business days of signing Agreement with
no obligation and without penalty. If the Client cancels after five (5) business days, any
unearned fees will be refunded to the Client, or any unpaid earned fees will be due to Arrow
Wealth. Arrow Wealth reserves the right to waive the fee should the Client implement the
plan through Arrow Wealth. Client will agree to the fee schedule before signing Agreement.
Fees for financial plans may be billed 50% in advance with the balance due upon plan
delivery or may be due, in full, at the commencement of the contract.
FIXED FEES
Financial Planning Services are offered based on a flat fee between $1,250 and $8,000.
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HOURLY FEES
Financial Planning Services are also offered based on an hourly rate of $225 per
hour.
ERISA PLAN SERVICES
The annual fees are based on the market value of the Included Assets and will not exceed
1%. The annual fee is negotiable and may be charged as a percentage of the Included Assets
or as a flat fee. Fees may be charged quarterly or monthly in arrears or in advance based on
the assets as calculated by the custodian or record keeper of the Included Assets (without
adjustments for anticipated withdrawals by Plan participants or other anticipated or
scheduled transfers or distribution of assets) on the last business day of the previous quarter
or month. If the services to be provided start any time other than the first day of a quarter or
month, the fee will be prorated based on the number of days remaining in the quarter or
month. If this Agreement is terminated prior to the end of the fee period, Arrow Wealth shall
be entitled to a prorated fee based on the number of days during the fee period services were
provided or Client will be due a prorated refund of fees for days services were not provided
in the billing cycle.
The fee schedule, which includes compensation of Arrow Wealth for the services is described
in detail in Schedule A of the ERISA Plan Agreement. The Plan is obligated to pay the fees;
however, the Plan Sponsor may elect to pay the fees. Client may elect to be billed directly or
have fees deducted from Plan Assets. Arrow Wealth does not reasonably expect to receive
any additional compensation, directly or indirectly, for its services under this Agreement. If
additional compensation is received, Arrow Wealth will disclose this compensation, the
services rendered, and the payer of compensation. Arrow Wealth will offset the
compensation against the fees agreed upon under this Agreement.
ASSET MANAGEMENT
Arrow Wealth offers direct asset management services to advisory Clients. Arrow Wealth
charges a maximum annual investment advisory fee based on the total assets under
management. Total fees to Client will never exceed the safe harbor threshold of 3% of assets
under management per year.
The table below illustrates the maximum client fee schedule.
Annual Fee
1.45%
1.25%
Quarterly Fee
0.3625%
03125%
1.00%
0.2500%
Assets Under Management
For the first amount $500,000
For the next amount from $500,001 -
$1,000,000
For the next amount from $1,000,001 -
$5,000,000
For the amount above $5,000,000+
0.75%
0.1875%
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This is a blended fee schedule; the asset management fee is calculated by applying different
rates to different portions of the portfolio. Arrow Wealth may group certain related Client
accounts for the purposes of achieving the minimum account size and determining the
annualized fee.
For example, a Client with $1,000,000 under management would pay $13,500 on an annual
basis.
First $500,000 x .0145 = $7,250
Next $500,000 x .0125 = $6,250
The annual fee may be negotiable 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, negotiations with
Clients, etc.).
Fees are billed quarterly in advance based on the amount of assets managed as of the close
of business on the last business day of the previous quarter. Lower fees for comparable
services may be available from other sources. Clients may terminate their account within
five (5) business days of signing the Investment Advisory Agreement with no obligation and
without penalty. Clients may terminate advisory services with thirty (30) days written
notice. For accounts opened or closed mid-billing period, unearned fees will be refunded to
the Client. Client shall be given thirty (30) days prior written notice of any increase in fees.
Any increase in fees will be acknowledged in writing by both parties before any increase in
said fees occurs.
Betterment Platform
When utilizing the Betterment Investment platform, Arrow Wealth’s fee will be prorated and
billed quarterly in arrears, based on the Client’s average daily balance for the prior quarter
multiplied by the annual percentage rate of no more than 1.50% of Assets charge. Fees are
negotiable and will be automatically deducted from your account. Betterment for Advisors
will make quarterly adjustments for deposits and withdrawals in Client accounts. As part of
this process, you understand and acknowledge the following:
• Betterment Securities as the custodian will send statements at least quarterly to
Clients showing all disbursements for their account, including the amount of the
advisory fees paid to Arrow Wealth;
• The Client has provided authorization permitting fees to be directly paid by these
terms;
• Betterment Institution calculates the advisory fees and deducts them from the
Client’s account. The fees are based on a Client’s average balance of their entire
account. Client will see the total fee of no more than 1.50% (to include the Betterment
for Advisors platform fee of 0.25% in addition to the annual percentage of assets
charge by Arrow Wealth)
The investment advisory fee will be billed directly to the Custodian, with an informational
copy of the invoice sent by the Custodian to the Client. The Custodian will deduct the fee for
the Account upon receipt of the invoice, or shortly thereafter. Arrow Wealth will not be
- 5 -
compensated based on the basis of a share of capital gains or capital appreciation of the
assets in the Account.
Client Payment of Fees
Investment management fees may be billed quarterly in advance, meaning that we bill you
before the billing period has begun. Fees are usually deducted from a designated Client
account to facilitate billing. The Client must consent in advance to direct debiting of their
investment account.
Fees for financial plans are billed 50% in advance with the balance due upon plan delivery
or may be due upon commencement of the Advisory Agreement.
Arrow Wealth, 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, negotiations with
Clients, etc.).
Additional Client Fees Charged
Custodians may charge transaction fees on purchases or sales of certain mutual funds,
equities, and exchange-traded funds. These charges may include mutual fund transaction
fees, postage and handling and miscellaneous fees. For more details on the brokerage
practices, see Item 12 of this brochure.
Prepayment of Client Fees
Arrow Wealth does not require any prepayment of fees of more than $1,200 per Client and
six months or more in advance.
Fees for financial plans may be billed 50% in advance with the balance due upon plan
delivery or may be due, in full, at the commencement of the contract.
Investment management fees may be billed quarterly in advance.
Fees for ERISA 3(21) services may be billed in advance.
If the Client cancels after five (5) business days, any unearned fees will be refunded to the
Client, or any unpaid earned fees will be due to Arrow Wealth.
External Compensation for the Sale of Securities to Clients
Arrow Wealth does not receive any external compensation for the sale of securities to
Clients, nor do any of the investment advisor representatives of Arrow Wealth.
Item 6: Performance-Based Fees and Side-by-Side Management
Sharing of Capital Gains
Fees are not based on a share of the capital gains or capital appreciation of managed
securities.
Arrow Wealth does not use a performance-based fee structure because of the conflict of
interest. Performance based compensation may create an incentive for Arrow Wealth to
recommend an investment that may carry a higher degree of risk to the Client.
- 6 -
Item 7: Types of Clients
Description
Arrow Wealth generally provides investment advice to individuals, high net worth
individuals, charities, and corporations or business entities. Client relationships vary in
scope and length of service.
Account Minimums
Arrow Wealth does not require a minimum to open an account. However, Betterment may
require account minimums to invest in their platform.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Our approach to investing begins with an understanding of financial science and the power
of free market economies. Rather than attempting to predict the future or rely on
outguessing other market participants, we draw information about expected returns from
the market itself; leveraging the collective knowledge of millions of buyers and sellers as
they set security prices through their buying and selling decisions.
We trust markets to efficiently drive information into security prices. Embracing this
investment philosophy frees our team to spend time on areas where we believe we have an
advantage. These areas include how we interpret decades of research, the design,
construction and management of client portfolios, and adding value, when possible, through
tax efficient investing. We take a less subjective, more systematic approach to investing that
can be implemented consistently. This is an approach that investors can understand and
stick with, even in challenging market environments.
Investing in securities involves the risk of loss that our clients should be prepared to bear.
We believe this preparation comes from setting realistic expectations about market risk and
providing ongoing client education. These are the hallmarks of a successful investing
experience. Past performance is not a guarantee of future returns, but an understanding of
what has happened in the past can be a helpful tool in preparing investors for what lies
ahead. Moreover, embracing an investment approach grounded in economic theory backed
by decades of research can bring financial peace of mind in times of uncertainty.
When it comes to selecting securities, research has shown that securities offering higher
expected returns share certain characteristics. We help our client’s structure broadly
diversified portfolios that emphasize these characteristics while addressing the tradeoffs
that arise when executing these portfolios. We are convinced that investing should always
be a means to an end; namely the pursuit of clearly defined financial goals laid forth in a
client’s financial plan.
When developing financials plans for clients, Arrow Wealth bases their analysis on the
client’s cashflow, risk capacity, risk tolerance, tax obligations, and estate planning
considerations. The plan is based on information gathered in client meetings, and a detailed
strategy is tailored to each client’s specific situation. The main sources of information for a
client’s analysis include the client’s tax returns, risk profile, cashflow statements, annual
reports, prospectuses, and filings with the Securities and Exchange Commission.
- 7 -
Investment Strategy
The investment strategy for a specific Client is based upon the objectives stated by the Client
during consultations. The Client may change these objectives at any time by providing
written notice to Arrow Wealth. Each Client executes a Client profile form or similar form
that documents their objectives and their desired investment strategy.
Arrow Wealth will not recommend any particular type of security to clients. Arrow Wealth
will review the client's risk tolerance, investment objectives, and investment time horizon in
order to determine which investments are in the client's best interest. Arrow Wealth's
recommendations may include any public security available on the custodian’s platform.
Security Specific Material Risks
All investment programs have certain risks that are borne by the investor. Our investment
approach constantly keeps the risk of loss in mind. Investing in securities involves risk of
loss that clients should be prepared to bear. Investors face the following investment risks
and should discuss these risks with Arrow Wealth:
• Market Risk: The prices of securities held by mutual funds in which Clients invest may
decline in response to certain events taking place around the world, including those
directly involving the companies whose securities are owned by a fund; conditions
affecting the general economy; overall market changes; local, regional or global
political, social or economic instability; and currency, interest rate and commodity
price fluctuations. Investors should have a long-term perspective and be able to
tolerate potentially sharp declines in market value.
•
Interest-rate Risk: Fluctuations in interest rates may cause investment prices to
fluctuate. For example, when interest rates rise, yields on existing bonds become less
attractive, causing their market values to decline.
•
Inflation Risk: When any type of inflation is present, a dollar today will buy more than
a dollar next year, because purchasing power is eroding at the rate of inflation.
• Currency Risk: Overseas investments are subject to fluctuations in the value of the
dollar against the currency of the investment’s originating country. This is also
referred to as exchange rate risk.
• Reinvestment Risk: This is the risk that future proceeds from investments may have
to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily
relates to fixed income securities.
• Liquidity Risk: Liquidity is the ability to readily convert an investment into cash.
Generally, assets are more liquid if many traders are interested in a standardized
product. For example, Treasury Bills are highly liquid, while real estate properties are
not.
• Management Risk: The advisor’s investment approach may fail to produce the
intended results. If the advisor’s assumptions regarding the performance of a specific
asset class or fund are not realized in the expected time frame, the overall
performance of the Client’s portfolio may suffer.
• Equity Risk: Equity securities tend to be more volatile than other investment choices.
The value of an individual mutual fund or ETF can be more volatile than the market
- 8 -
as a whole. This volatility affects the value of the Client’s overall portfolio. Small- and
mid-cap companies are subject to additional risks. Smaller companies may
experience greater volatility, higher failure rates, more limited markets, product
lines, financial resources, and less management experience than larger companies.
Smaller companies may also have a
lower trading volume, which may
disproportionately affect their market price, tending to make them fall more in
response to selling pressure than is the case with larger companies.
• Fixed Income Risk: The issuer of a fixed income security may not be able to make
interest and principal payments when due. Generally, the lower the credit rating of a
security, the greater the risk that the issuer will default on its obligation. If a rating
agency gives a debt security a lower rating, the value of the debt security will decline
because investors will demand a higher rate of return. As nominal interest rates rise,
the value of fixed income securities held by a fund is likely to decrease. A nominal
interest rate is the sum of a real interest rate and an expected inflation rate.
• Long-term purchases: Long-term investments are those vehicles purchased with the
intension of being held for more than one year. Typically, the expectation of the
investment is to increase in value so that it can eventually be sold for a profit. In
addition, there may be an expectation for the investment to provide income. One of
the biggest risks associated with long-term investments is volatility, the fluctuations
in the financial markets that can cause investments to lose value.
• Short-term purchases: Short-term investments are typically held for one year or less.
Generally, there is not a high expectation for a return or an increase in value.
Typically, short-term investments are purchased for the relatively greater degree of
principal protection they are designed to provide. Short-term investment vehicles
may be subject to purchasing power risk — the risk that your investment’s return will
not keep up with inflation.
• Trading risk: Investing involves risk, including possible loss of principal. There is no
assurance that the investment objective of any fund or investment will be achieved.
The risks associated with utilizing third party money managers include:
• Manager Risk
o Third party money manager fails to execute the stated investment strategy
• Business Risk
o Third party money manager has financial or regulatory problems
• The specific risks associated with the portfolios of the third party money manager’s
which is disclosed in the third party money manager’s Form ADV Part 2.
Item 9: Disciplinary Information
Criminal or Civil Actions
Arrow Wealth and its management have not been involved in any criminal or civil action in
a domestic, foreign or military court of competent jurisdiction.
- 9 -
Administrative Enforcement Proceedings
Arrow Wealth and its management have not been involved in administrative enforcement
proceedings before the SEC, any other federal regulatory agency, any state regulatory
agency, or any foreign financial regulatory authority.
Self- Regulatory Organization Enforcement Proceedings
Arrow Wealth and its management have not been involved in any self-regulatory
organizational proceedings that are material to a Client’s or prospective Client’s evaluation
of Arrow Wealth or the integrity of its management.
Item 10: Other Financial Industry Activities and Affiliations
Broker-Dealer or Representative Registration
Neither Arrow Wealth nor its affiliated representatives are registered or have an application
pending to register with a broker-dealer. Arrow Wealth is not registered as a broker-dealer.
Futures or Commodity Registration
Neither Arrow Wealth nor its affiliated representatives are registered or have an application
pending to register as a futures commission merchant, commodity pool operator, or a
commodity trading advisor.
Material Relationships Maintained by this Advisory Business and Conflicts of Interest
President Daniel Seltzer is the only management person for Arrow Wealth, and he has no
financially affiliated businesses or conflicts of interests to disclose.
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest
As part of our relationship with Betterment and Betterment Securities, Betterment may
offer us services intended to help us manage and further develop our business enterprise,
such as access to webinars and advice about using the Betterment for Advisors platform to
grow our business. Betterment may offer different or expanded services in the future. These
services could create an incentive for us to recommend that our Clients invest through the
Betterment for Advisors platform. This is a potential conflict given that our interest in
recommending Betterment could be influenced by our receipt of Betterment’s and
Betterment Securities’ services to our business. Other potential conflicts may exist regarding
our use of the Betterment for Advisors platform.
Arrow Wealth ensures that before selecting other advisors for Client that the other advisors
are properly licensed or registered as an investment advisor.
Item 11: Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
Code of Ethics Description
include employees and/or
The affiliated persons (affiliated persons
independent
contractors) of Arrow Wealth have committed to a Code of Ethics (“Code”). The purpose of
our Code is to set forth standards of conduct expected of Arrow Wealth affiliated persons
and addresses conflicts that may arise. The Code defines acceptable behavior for affiliated
persons of Arrow Wealth. The Code reflects Arrow Wealth and its supervised persons’
responsibility to act in the best interest of their Client.
One area which the Code addresses is when affiliated persons buy or sell securities for their
personal accounts and how to mitigate any conflict of interest with our Clients. We do not
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allow any affiliated persons to use non-public material information for their personal profit
or to use internal research for their personal benefit in conflict with the benefit to our Clients.
Arrow Wealth’s policy prohibits any person from acting upon or otherwise misusing non-
public or inside information. No advisory representative or other affiliated person, officer or
director of Arrow Wealth may recommend any transaction in a security or its derivative to
advisory Clients or engage in personal securities transactions for a security or its derivatives
if the advisory representative possesses material, non-public information regarding the
security.
Arrow Wealth’s Code is based on the guiding principle that the interests of the Client are our
top priority. Arrow Wealth’s officers, directors, advisors, and other affiliated persons have a
fiduciary duty to our Clients and must diligently perform that duty to maintain the complete
trust and confidence of our Clients. When a conflict arises, it is our obligation to put the
Client’s interests over the interests of either affiliated persons or the company.
The Code applies to “access” persons. “Access” persons are affiliated persons who have
access to non-public information regarding any Clients' purchase or sale of securities, or
non-public information regarding the portfolio holdings of any reportable fund, who are
involved in making securities recommendations to Clients, or who have access to such
recommendations that are non-public.
Arrow Wealth will provide a copy of the Code of Ethics to any Client or prospective Client
upon request.
Investment Recommendations Involving a Material Financial Interest and Conflict of
Interest
Arrow Wealth and its affiliated persons do not recommend to Clients securities in which we
have a material financial interest. Because Arrow Wealth does not recommend Client
securities in which we have a material interest, there is no conflict of interest.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
Interest
Arrow Wealth and its affiliated persons may buy or sell securities that are also held by
Clients. In order to mitigate conflicts of interest such as trading ahead of Client transactions,
affiliated persons are required to disclose all reportable securities transactions as well as
provide Arrow Wealth with copies of their brokerage statements.
The Chief Compliance Officer of Arrow Wealth is Daniel Seltzer. He reviews all trades of the
affiliated persons each quarter. The personal trading reviews ensure that the personal
trading of affiliated persons does not affect the markets and that Clients of the firm receive
preferential treatment over associated persons’ transactions.
Client Securities Recommendations or Trades and Concurrent Advisory Firm
Securities Transactions and Conflicts of Interest
Arrow Wealth does not maintain a firm proprietary trading account and does not have a
material financial interest in any securities being recommended and therefore no conflicts
of interest exist. However, affiliated persons may buy or sell securities at the same time they
buy or sell securities for Clients. In order to mitigate conflicts of interest such as front
running, affiliated persons are required to disclose all reportable securities transactions as
well as provide Arrow Wealth with copies of their brokerage statements.
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The Chief Compliance Officer of Arrow Wealth is Daniel Seltzer. He reviews all employee
trades each quarter. The personal trading reviews ensure that the personal trading of
affiliated persons does not affect the markets and that Clients of the firm receive preferential
treatment over associated persons’ transactions.
Item 12: Brokerage Practices
Factors Used to Select Broker-Dealers for Client Transactions
Arrow Wealth will recommend the use of a particular custodian to custody Client assets.
Arrow Wealth receives a benefit because it does not have to pay for the research, services,
or product and it may have an incentive to recommend a custodian based on its interest
rather than the Clients. Arrow Wealth will select appropriate custodians based on a number
of factors including but not limited to their relatively low transaction fees and reporting
ability. Arrow Wealth relies on its custodian to provide its execution services at the best
prices available. Lower fees for comparable services may be available from other sources.
Clients pay for any and all custodial fees in addition to the advisory fee charged by Arrow
Wealth.
Arrow Wealth will recommend the use of Charles Schwab, Pershing, or Betterment
Securities.
• Directed Brokerage
Arrow Wealth does not allow Clients to use directed brokerage.
With respect to the Betterment Platform, Arrow Wealth does not maintain custody of
your assets, although we may be deemed to have custody of your assets if you give us
authority to withdraw advisory fees from your account. Client assets must be
maintained in an account at a “qualified custodian,” generally a broker-dealer or bank.
We may recommend that our Clients use MTG, LLC dba Betterment Securities
(“Betterment Securities”), a registered broker-dealer and member of the SIPC, as the
qualified custodian. Arrow Wealth is not affiliated with Betterment Securities.
Betterment Securities will hold your assets in a brokerage account and buy and sell
securities when Arrow Wealth and/or you instruct them to. While Arrow Wealth
recommends that you use Betterment Securities as custodian/broker, you will decide
whether to do so and will open your account with Betterment Securities by entering
into an account agreement directly with them. Arrow Wealth does not open the
account for you, although we may assist you in doing so. If you do not wish to place
your assets with Betterment Securities, then Arrow Wealth cannot manage your
account on Betterment for Advisors.
• Best Execution
Investment advisors who manage or supervise Client portfolios have a fiduciary
obligation of best execution. The determination of what may constitute best
execution and price in the execution of a securities transaction by a custodian
involves a number of considerations and is subjective. Factors affecting custodian
selection include the overall direct net economic result to the portfolios, the efficiency
with which the transaction is effected, the ability to effect the transaction where a
large block is involved, the operational facilities of the custodian, the value of an
ongoing relationship with such custodian and the financial strength and stability of
the custodian. Arrow Wealth does not receive any portion of the trading fees.
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For Arrow Wealth’s Client accounts that Betterment Securities maintains, Betterment
Securities does not charge you separately for custody/brokerage services but is
compensated as part of the Betterment for Advisors platform fee, which is charged
for a suite of platform services, including custody, brokerage, and sub-advisory
services provided by Betterment and access to the Betterment for Advisors platform.
The platform fee is an asset-based fee charged as a percentage of assets in your
Betterment account. Clients utilizing the Betterment for Advisors platform may pay a
higher aggregate fee than if the investment management, brokerage and other
platform services are purchased separately. Nonetheless, for those Clients
participating in the Betterment for Advisors platform, Arrow Wealth has determined
that having Betterment Securities execute trades is consistent with our duty to seek
best execution of your trades.
• Brokerage for Client Referrals
Arrow Wealth has a relationship with an unaffiliated custodian wherein Arrow
Wealth receives client referrals. This results in a conflict of interest with the client
since Arrow Wealth has an incentive to select or recommend a broker-dealer based
on receiving these referrals rather than selecting the broker with the most favorable
execution. This conflict is mitigated by the fact that Arrow Wealth has a fiduciary
responsibility to act in the best interest of its Clients and the services received are
beneficial to all Clients. Additionally, Arrow Wealth does not make commitments to
any broker-dealer to compensate that broker-dealer through brokerage transactions
for client referrals.
• Soft Dollar Arrangements
The Securities and Exchange Commission defines soft dollar practices as
arrangement under which products or services other than execution services are
obtained by Arrow Wealth from or through a custodian in exchange for directing
Client transactions to the custodian. As permitted by Section 28(e) of the Securities
Exchange Act of 1934, Arrow Wealth receives economic benefits as a result of
commissions generated from securities transactions by the custodian from the
accounts of Arrow Wealth. These benefits include both proprietary research from the
custodian and other research written by third parties. Arrow Wealth does not cause
clients to pay commissions (or markups or markdowns) higher than those charged
by the custodian in return for soft dollar benefits.
Arrow Wealth utilizes the services of custodians. Economic benefits are received by
Arrow Wealth which would not be received if Arrow Wealth did not give investment
advice to Clients. These benefits include: A dedicated trading desk, a dedicated service
group and an account services manager dedicated to Arrow Wealth's accounts, ability
to conduct "block" Client trades, electronic download of trades, balances and
positions, duplicate and batched Client statements, and the ability to have advisory
fees directly deducted from Client accounts. A conflict of interest exists when Arrow
Wealth receives soft dollars. This conflict is mitigated by the fact that Arrow Wealth
has a fiduciary responsibility to act in the best interest of its Clients and the services
received are beneficial to all Clients. Soft dollar benefits are used to service all clients’
accounts. There were no products or services any related persons acquired with
client brokerage commissions (or markups or markdowns) within our last fiscal year.
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With respect to the Betterment Platform, Betterment Securities serves as broker-
dealer to Betterment for Advisors, an investment and advice platform serving
independent investment advisory firms like us (“Betterment for Advisors”).
Betterment for Advisors also makes available various support services which may not
be available to Betterment’s retail customers. Some of those services help us manage
or administer our Clients’ accounts, while others help us manage and grow our
business. Betterment for Advisors’ support services are generally available on an
unsolicited basis (we don’t have to request them) and at no charge to Arrow Wealth.
Following is a more detailed description of Betterment for Advisors’ support services:
1. SERVICES THAT BENEFIT YOU. Betterment for Advisors includes access to a
low-cost portfolio of ETFs, execution of securities
globally diversified,
transactions, and custody of Client assets through Betterment Securities. In
addition, a series of model portfolios created by third-party providers are also
available on the platform. Betterment Securities’ services described in this
paragraph generally benefit you and your account.
2. SERVICES THAT MAY NOT DIRECTLY BENEFIT YOU. Betterment for Advisors also
makes available to us other products and services that benefit us but may not
directly benefit you or your account. These products and services assist us in
managing and administering our Clients’ accounts, such as software and
technology that may:
•
Assist with back-office functions, recordkeeping, and Client reporting of our
Clients’ accounts.
•
Provide access to Client account data (such as duplicate trade confirmations
and account statements).
•
Provide pricing and other market data.
3. SERVICES THAT GENERALLY BENEFIT ONLY US. By using Betterment for
Advisors, we may be offered other services intended to help us manage and
further develop our business enterprise. These services include:
•
Consulting (including through webinars) on technology and business needs.
•
Access to publications and conferences on practice management and business
succession.
The availability of these services from Betterment for Advisors benefits us because we do
not have to produce or purchase them. In addition, we do not have to pay for Betterment
Securities’ services. Arrow Wealth may have an incentive to recommend that you maintain
your account with Betterment Securities, based on our interest in receiving Betterment for
Advisors and Betterment Securities’ services that benefit our business rather than based on
your interest in receiving the best value in custody services and the most favorable execution
of your transactions. This is a potential conflict of interest. We believe, however, that our
selection of Betterment Securities as custodian and broker is in the best interests of our
Clients. Our selection is primarily supported by the scope, quality, and price of Betterment
Securities’ services (see “How we select brokers/custodians”) and not Betterment for
Advisors and Betterment Securities’ services that benefit only us or that may not directly
benefit you.
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When using the Betterment for Advisors platform, Arrow Wealth and Clients are subject to
the trading policies and procedures established by Betterment. These policies and
procedures limit our ability to control, among other things, the timing of the execution of
certain trades (including in response to withdrawals, deposits, or asset allocation changes)
within your account. You should not expect that trading on Betterment is instant, and,
accordingly, you should be aware that Betterment does not permit you or us to control the
specific time during a day that securities are bought or sold in your account (i.e., to “time the
market”). Betterment describes its trading policies in Betterment LLC’s Form ADV Part 2A.
As detailed in that document, Betterment generally trades on the same business day as it
receives instructions from you or us. However, transactions will be subject to processing
delays in certain circumstances. In particular, orders initiated on non-business days and
after markets close generally will not transact until the next business day. Betterment also
maintains a general approach of not placing securities orders during approximately the first
thirty minutes after the opening of any market session. Betterment also generally stops
placing orders arising from allocation changes in existing portfolios approximately thirty
minutes before the close of any market session. Betterment continues placing orders
associated with deposit and withdrawal requests until market close. Betterment maintains
a general approach of not placing orders around the time of scheduled Federal Reserve
interest rate announcements. Furthermore, Betterment may delay or manage trading in
response to market instability. For further information, please consult Betterment LLC’s
Form ADV Part 2A.
Aggregating Securities Transactions for Client Accounts
Arrow Wealth is authorized in its discretion to aggregate purchases and sales and other
transactions made for the account with purchases and sales and transactions in the same
securities for other Clients of Arrow Wealth. All Clients participating in the aggregated order
shall receive an average share price with all other transaction costs shared on a pro-rated
basis. If aggregation is not allowed or infeasible and individual transactions occur (e.g.,
withdrawal or liquidation requests, odd-lot trades, etc.) an account may potentially be
assessed higher costs or less favorable prices than those where aggregation has occurred.
Item 13: Review of Accounts
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory
Persons Involved
While the underlying investment accounts are continually monitored (whether the
investments are managed by a TPM or by Arrow Wealth) account reviews for accounts
managed by Arrow Wealth and TPM or accounts delegated to additional third parties are
performed annually by Daniel Seltzer, the Chief Compliance Officer of Arrow Wealth.
Reviews of Client accounts include, but are not limited to, examination of account
performance against the investment policy established for each client, a review of Client
documented risk tolerance, adherence to account objectives, investment time horizon, and
suitability criteria, reviewing target bans of each asset class to identify if there is an
opportunity for rebalancing, and reviewing accounts for tax loss harvesting opportunities.
Additional account reviews for accounts managed by Arrow Wealth and/or TPM are
performed more frequently when market conditions dictate. Factors that may trigger
additional account review may be due to the client’s individual circumstances, economic
conditions, general factors affecting the stock market, etc.
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Financial plans generated are updated as requested by the Client and pursuant to a new or
amended agreement, Arrow Wealth suggests updating at least annually.
Review of Client Accounts on Non-Periodic Basis
Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws,
new investment information, and changes in a Client's own situation.
Content of Client Provided Reports and Frequency
Clients receive written account statements no less than quarterly for managed accounts.
Account statements are issued by Arrow Wealth’s custodian. Client receives written
confirmations of each transaction in account from Custodian and an additional written
statement during any month in which a transaction occurs.
Item 14: Client Referrals and Other Compensation
Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts
of Interest
With respect to the Betterment Platform, Arrow Wealth may receive a non-economic benefit
from Betterment for Advisors and Betterment Securities in the form of the support products
and services it makes available to us and other independent investment advisors whose
Clients maintain their accounts at Betterment Securities. These products and services, how
they benefit us, and the related conflicts of interest are described above in Item 12. The
availability to us of Betterment for Advisors’ and Betterment Securities’ products and
services is not based on us giving particular investment advice, such as buying particular
securities for our Clients.
Advisory Firm Payments for Client Referrals
Neither Arrow Wealth nor any related persons for the firm, directly or indirectly, receive
compensation for Client referrals. Neither Arrow Wealth nor any related persons for the
firm, directly or indirectly, compensate any person who is not a supervised person for Client
referrals.
Item 15: Custody
Account Statements
All assets are held at qualified custodians, which means the custodians provide account
statements directly to Clients at their address of record at least quarterly. Clients are urged
to compare the account statements received directly from their custodians to any
documentation or reports prepared by Arrow Wealth.
Arrow Wealth is deemed to have constructive custody solely because advisory fees are
directly deducted from Client’s accounts by the custodian on behalf of Arrow Wealth.
Arrow Wealth is not affiliated with the custodian. The custodian does not supervise Arrow
Wealth, its agents or activities.
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Item 16: Investment Discretion
Discretionary Authority for Trading
Arrow Wealth requires discretionary authority to manage securities accounts on behalf of
Clients. Arrow Wealth has the authority to determine, without obtaining specific Client
consent, the securities to be bought or sold, and the amount of the securities to be bought or
sold. The client will authorize Arrow Wealth discretionary authority to execute selected
investment program transactions as stated within the Investment Advisory Agreement.
Arrow Wealth allows Client’s to place certain restrictions, as outlined in the Client’s
Investment Policy Statement or similar document. Such restrictions could include only
allowing purchases of socially conscious investments. These restrictions must be provided
to Arrow Wealth in writing.
Arrow Wealth does not receive any portion of the transaction fees or commissions paid by
the Client to the custodian.
Item 17: Voting Client Securities
Proxy Votes
Arrow Wealth does not and will not vote proxies on securities. Clients are expected to vote
their own proxies. The Client will receive their proxies directly from the custodian of their
account or from a transfer agent.
When assistance on voting proxies
is requested, Arrow Wealth will provide
recommendations to the Client. If a conflict of interest exists, it will be disclosed to the Client.
Item 18: Financial Information
Balance Sheet
A balance sheet is not required to be provided because Arrow Wealth does not serve as a
custodian for Client funds or securities and Arrow Wealth does not require prepayment of
fees of more than $1,200 per Client and six months or more in advance.
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet
Commitments to Clients
Arrow Wealth has no condition that is reasonably likely to impair our ability to meet
contractual commitments to our Clients.
Bankruptcy Petitions during the Past Ten Years
Neither Arrow Wealth nor its management has had any bankruptcy petitions in the last ten
years.
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Item 1 Cover Page
S U P E R V I S E D P E R S O N B R O C H U R E
F O R M A D V P A R T 2 B
Daniel Seltzer, CFP®, MSFP
Arrow Wealth Advisors, Inc.
California Office Address:
10831 Combine Rd.
Suite A
Auburn, CA 95602
Texas Office Address:
400 N Loop 1604 E
Suite 280
San Antonio, TX 78232
Tel: 210-541-9967
Fax: 210-541-9967
Dan@ArrowWealthAdvisors.com
Website:
www.ArrowWealthAdvisors.com
This brochure supplement provides information about Daniel Seltzer and supplements the Arrow
Wealth Advisors, Inc’s brochure. You should have received a copy of that brochure. Please contact
Daniel Seltzer if you did not receive the brochure or if you have any questions about the contents
of this supplement.
J U N E 2 2 , 2 0 2 6
Additional information about Daniel Seltzer (CRD #5962042) is available on the SEC’s website at
www.adviserinfo.sec.gov.
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Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Principal Executive Officer – Daniel Seltzer, CFP®
• Year of birth: 1983
Item 2 - Educational Background and Business Experience
Educational Background:
• Oklahoma State University; Bachelor of Science in Finance, 2010
• Bentley University; Master of Science in Financial Planning; 2011
Business Experience:
• Arrow Wealth Advisors, Inc.; President/Investment Advisor Representative;
10/2017 – Present
• LPL Financial LLC; Registered Representative; 09/2011 – 12/2017
• US Financial Advisor, LLC; Investment Advisor Representative; 01/2012 – 11/2017
• LPL Financial LLC; Investment Advisor Representative; 10/2011 – 03/2013
• Bentley University; Student; 01/2011 – 12/2011
• Oklahoma State University; Student; 05/2006 – 12/2010
• US Army; Airborne Infantryman; 02/2003 – 04/2006
Professional Designations:
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with flame
design) marks (collectively, the “CFP® marks”) are professional certification marks granted
in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation
requires financial planners to hold CFP® certification. It is recognized in the United States
and a number of other countries for its (1) high standard of professional education; (2)
stringent code of conduct and standards of practice; and (3) ethical requirements that
govern professional engagements with Clients.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the
following requirements:
• Education – Complete an advanced college-level course of study addressing the
financial planning subject areas that CFP Board’s studies have determined as
necessary for the competent and professional delivery of financial planning services,
and attain a Bachelor’s Degree from a regionally accredited United States college or
university (or its equivalent from a foreign university). CFP Board’s financial planning
subject areas include insurance planning and risk management, employee benefits
planning, investment planning, income tax planning, retirement planning, and estate
planning;
• Examination – Pass the comprehensive CFP® Certification Examination. The
examination, administered in 10 hours over a two-day period, includes case studies
and Client scenarios designed to test one’s ability to correctly diagnose financial
planning issues and apply one’s knowledge of financial planning to real world
circumstances;
• Experience – Complete at least three years of full-time financial planning-related
experience (or the equivalent, measured as 2,000 hours per year); and
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• Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of
documents outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics
requirements in order to maintain the right to continue to use the CFP® marks:
• Continuing Education – Complete 30 hours of continuing education hours every two
years, including two hours on the Code of Ethics and other parts of the Standards of
Professional Conduct, to maintain competence and keep up with developments in the
financial planning field; and
• Ethics – Renew an agreement to be bound by the Standards of Professional Conduct.
The Standards prominently require that CFP® professionals provide financial
planning services at a fiduciary standard of care. This means CFP® professionals must
provide financial planning services in the best interests of their Clients.
CFP® professionals who fail to comply with the above standards and requirements
may be subject to CFP Board’s enforcement process, which could result in suspension
or permanent revocation of their CFP® certification.
Item 3 - Disciplinary Information
A. Daniel Seltzer has never been involved in a criminal or civil action in a domestic, foreign
or military court of competent jurisdiction for which he:
a. Was convicted of, or pled guilty or nolo contender (“no contest”) to (a) any felony;
(b) misdemeanor that involved investments or an investment-related business,
fraud, false statement or omissions, wrongful taking of property, bribery, perjury,
counterfeiting, or extortion; or (c) a conspiracy to commit any of these offenses;
b. Is the named subject of a pending criminal proceeding that involves an
investment-related business, fraud, false statements or omissions, wrongful
taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a
conspiracy to commit any of these offenses;
c. Was found to have been involved in a violation of an investment-related statute
or regulation; or
d. Was the subject of any order, judgement or decree permanently or temporarily
enjoining, or otherwise limiting, him from engaging in any investment related
activity, or from violating any investment-related statute, rule, or order.
B. Daniel Seltzer never had an administrative proceeding before the SEC, any other federal
regulatory agency, any state regulatory agency, or any foreign financial regulatory
authority in which he:
a. Was found to have caused an investment-related business to lose its authorization to
do business; or the subject of an order by the agency or authority;
b. Was found to have been involved in a violation of an investment-related statute or
regulation or was the subject of an order by the agency or authority
a. (a)denying, suspending or revoking the authorization of the supervised person to
act in an investment-related business; (b) barring or suspending his association
with an investment-related business; (c) otherwise significantly limiting his
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investment-related activities; or (d) imposing a civil money penalty of more than
$2,500 on him.
C. Daniel Seltzer has never been the subject of a self-regulatory organization (SRO)
proceeding in which he:
a. Was found to have caused an investment-related business to lose its authorization
to do business; or
b. Was found to have been involved in a violation of the SRO’s rules and was: (a)
barred or suspended from membership or from association with other members
or was expelled from membership; (b) otherwise significantly limited from
investment-related activities; or (c) fined more than $2,500.
D. Daniel Seltzer has not been involved in any other hearing or formal adjudication in
which a professional attainment, designation, or license of the supervised person was
revoked or suspended because of a violation of rules relating to professional conduct.
Item 4 - Other Business Activities Engaged In
President Daniel Seltzer has no financially affiliated businesses or conflicts of interests to
disclose. Daniel Seltzer is not engaged in any investment-related business or occupation. He
has no application pending to register, as a broker-dealer, registered representative of a
broker-dealer, futures commission merchant, commodity pool operator, commodity trading
advisor, or an associated person of an FCM, CPO, or CTA.
Item 5 - Additional Compensation
Daniel Seltzer does not receive commissions nor receive any performance based fees and
does not receive any additional compensation for performing advisory services other than
what is disclosed in Item 5 of Part 2A.
Item 6 - Supervision
Daniel Seltzer is the sole owner of Arrow Wealth. He is solely responsible for all supervision
and formulation and monitoring of investment advice offered to Clients. He will adhere to
the policies and procedures described in the firm’s Compliance Manual. Daniel Seltzer can
be reached by email at dan@arrowwealthadvisors.com or by phone at 210-541-9967.
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