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Item 1: Cover Page
Part 2A of Form ADV: Firm Brochure
February 2026
Ashworth Wealth, LLC
897 W. Baxter Dr.
South Jordan, Utah 84095
www.ashworthwealth.com
Firm Contact:
Todd McChesney
Chief Compliance Officer
This brochure provides information about the qualifications and business practices of Ashworth
Wealth, LLC. If clients have any questions about the contents of this brochure, please contact us at
(801) 364-4400 or todd@ashworthwealth.com. 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 our firm is also available on the SEC’s website at
www.adviserinfo.sec.gov by searching CRD #116950.
Please note that the use of the term “registered investment adviser” and description of our firm
and/or our associates as “registered” does not imply a certain level of skill or training. Clients are
encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise
clients for more information on the qualifications of our firm and our employees.
Item 2: Material Changes
Ashworth Wealth, LLC is required to make clients aware of information that has changed since the
last annual update to the Firm Brochure (“Brochure”) and that may be important to them. Clients can
then determine whether to review the brochure in its entirety or to contact us with questions about
the changes.
Since the last annual amendment filed on 02/24/2025, there are no material changes to disclose.
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Item 3: Table of Contents
Item 1: Cover Page .................................................................................................................................................................. 1
Item 2: Material Changes ...................................................................................................................................................... 2
Item 3: Table of Contents ..................................................................................................................................................... 3
Item 4: Advisory Business.................................................................................................................................................... 4
Item 5: Fees & Compensation ............................................................................................................................................. 6
Item 6: Performance-Based Fees & Side-By-Side Management ........................................................................... 9
Item 7: Types of Clients & Account Requirements .................................................................................................... 9
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ................................................................... 9
Item 9: Disciplinary Information .................................................................................................................................... 12
Item 10: Other Financial Industry Activities & Affiliations .................................................................................. 12
Item 11: Code of Ethics, Participation or Interest in ............................................................................................... 12
Client Transactions & Personal Trading ...................................................................................................................... 12
Item 12: Brokerage Practices ........................................................................................................................................... 13
Item 13: Review of Accounts or Financial Plans ....................................................................................................... 13
Item 14: Client Referrals & Other Compensation ..................................................................................................... 14
Item 15: Custody .................................................................................................................................................................... 15
Item 16: Investment Discretion ....................................................................................................................................... 15
Item 17: Voting Client Securities ..................................................................................................................................... 15
Item 18: Financial Information ........................................................................................................................................ 16
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Item 4: Advisory Business
Our firm is dedicated to providing individuals and other types of clients with a wide array of
investment advisory services. Our firm is a limited liability company
formed under the laws of the
State of Utah in 2008 and has been in business as an investment adviser since that time. Our firm is
owned by Todd P. McChesney Financial, Inc. (33.33%), RST Consulting, Inc. (33.33%), and Robert M.
Woods Financial, LLC (33.33%).
The purpose of this Brochure is to disclose the conflicts of interest associated with the investment
transactions, compensation and any other matters related to investment decisions made by our firm
or its representatives. As a fiduciary, it is our duty to always act in the client’s best interest. This is
accomplished in part by knowing our client. Our firm has established a service-oriented advisory
practice with open lines of communication for many different types of clients to help meet their
financial goals while remaining sensitive to risk tolerance and time horizons. Working with clients to
understand their investment objectives while educating them about our process, facilitates the kind
of working relationship we value.
Types of Advisory Services Offered
Comprehensive Wealth Management:
Our Comprehensive Wealth Management service encompasses asset management as well as
providing financial planning and/or financial consulting to clients. This service is designed to assist
clients in meeting their financial goals through the use of a financial plan or consultation. Our firm
conducts client meetings to understand their current financial situation, existing resources, financial
goals, tolerance for risk, and any reasonable restrictions they wish to be imposed on the management
of their account(s). Based on what is learned, an investment approach is presented to the client. This
Platform
approach may consist of the use of a third-party platform manager on the Osaic Wealth, Inc.
(“Platform Manager”) or the use of a direct third-party money manager (“Asset Manager”) (referred
together herein as “Third-Party Money Manager”).
It is important for clients to understand that all investment advice and trading of securities will only
be offered by or through a Third-Party Money Manager. Our firm will not offer advice on any specific
securities or other investments in connection with this service.
The Third-Party Money Manager we ultimately recommend to the client will invest primarily in
individual stocks, no-load or low-load mutual funds and exchange-traded funds, usually through
discount brokers or fund companies. The Fund companies charge each fund shareholder an investment
management fee that is disclosed in the fund prospectus while the discount brokerages may charge a
transaction fee for the purchase of some funds. Stocks and bonds may be purchased or sold through a
brokerage account for clients by the Third-Party Money Manager when appropriate. The brokerage firm
may charge a fee for stock and bond trades. Clients may also be invested in equities, warrants, corporate
debt securities, commercial paper, certificates of deposit, municipal securities, investment company
securities (variable life insurance, variable annuities, and mutual funds shares), U.S. government
securities, options contracts, ETFs, futures contracts, interests in partnerships, hedge funds and futures.
However, initial public offerings (IPOs) are not available through our firm.
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Prior to referring clients to the Third-Party Money Manager, our firm will conduct initial due diligence
on the Third-Party Money Manager and how they manage their client accounts to ensure it is a good fit.
Following our firm’s referral to the Third-Party Money Manager, clients will be provided with a copy
of the Third-Party Money Manager’s Form ADV documents (e.g., Form ADV 2A, Form ADV 2B, Form
CRS) as well as a solicitation disclosure statement detailing the fees to be paid to both firms and the
Third-Party Money Manager’s privacy policy.
Our firm will periodically review Third-Party Money Manager reports provided to the client at least
annually. Our firm will also contact clients from time to time in order to review their financial
situation and objectives, communicate any changes in information to the Third-Party Money
Manager, as warranted, and assist clients in understanding and evaluating the services provided by
the Third-Party Money Manager. Clients will be expected to notify our firm of any changes in their
financial situation, investment objectives, or account restrictions that could affect their financial
standing.
Financial Planning & Consulting:
A financial plan may be designed to help the client with all aspects of financial planning without
ongoing investment management after the financial plan is completed.
The financial plan may include, but is not limited to: net worth statement, cash flow statement, review
of investment accounts (including reviewing asset allocation and providing repositioning
recommendations), strategic tax planning, review of retirement accounts and plans including
recommendations, review of insurance policies and recommendations for changes (if necessary), one
or more retirement scenarios, and estate planning review and recommendations.
The scope of work and fee for a Financial Planning Agreement is provided to the client in writing
prior to the start of the relationship.
Retirement Plan Consulting:
•
Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing
basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing,
monitoring and reviewing their company's participant-directed retirement plan. As the needs of the
plan sponsor dictate, areas of advising could include: investment options, plan structure and
participant education. Retirement Plan Consulting services typically include:
•
•
•
Establishing an Investment Policy Statement – Our firm will assist in the development of a
statement that summarizes the investment goals and objectives along with the broad
strategies to be employed to meet the objectives.
Investment Options – Our firm will work with the Plan Sponsor to evaluate existing
investment options and make recommendations for appropriate changes.
Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation
models to aid Participants in developing strategies to meet their investment objectives, time
horizon, financial situation and tolerance for risk.
Investment Monitoring – Our firm will monitor the performance of the investments and
notify the client in the event of over/underperformance and in times of market volatility.
In providing services for retirement plan consulting, our firm does not provide any advisory services
with respect to the following types of assets: employer securities, real estate (excluding real estate
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Ashworth Wealth, LLC
funds and publicly traded REITS), participant loans, non-publicly traded securities or assets, other
illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement
plan consulting services shall be in compliance with the applicable state laws regulating retirement
consulting services. This applies to client accounts that are retirement or other employee benefit
plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended
(“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to provide
services to such accounts, our firm acknowledges its fiduciary standard within the meaning of Section
3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to
the provision of services described therein.
Tailoring of Advisory Services
Our firm offers general investment advice to our Comprehensive Wealth Management, Financial
Planning & Consulting, and Retirement Plan Consulting clients.
On more than an occasional basis, Ashworth Wealth, LLC furnishes advice to clients on matters not
involving securities, such as financial planning matters, taxation issues, and trust services that often
include estate planning.
Each Comprehensive Wealth Management client has the opportunity to place reasonable restrictions
on the types of investments to be held in the portfolio. Restrictions on investments in certain securities
or types of securities may not be possible due to the level of difficulty this would entail in managing
the account.
Participation in Wrap Fee Programs
Our firm does not offer or sponsor a wrap fee program.
Regulatory Assets Under Management
Our firm manages $0 on a discretionary basis and $377,751,050 on a non-discretionary basis as of
December 31, 2025.
Item 5: Fees & Compensation
Compensation for Our Advisory Services
Comprehensive Wealth Management:
The maximum total annual advisory fee for this service shall not exceed 2.00%. A portion of this fee
will be paid to our firm by the Third-Party Money Manager. The ultimate fee to be charged as well as
the billing cycle will be outlined in the Statement of Investment Selection (“SIS”) or the Investment
Advisory Agreement provided the Third-Party Money Manager.
Our firm’s portion of the advisory fee will never be more than 1.25% per annum and will be detailed
in the SIS or the Investment Advisory Agreement provided the Third-Party Money Manager.
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Annualized fees are billed on a pro-rata basis quarterly, either in advance or arrears, based on the
value of the account(s) on the last day of the previous quarter. Our firm bills on cash unless indicated
otherwise in writing. Clients will be billed in advance or arrears depending on the Third-Party Money
Manager selected. Fees are negotiable and will be deducted from client account(s) by the Third-Party
Money Manager. Our firm does not offer direct invoicing. As part of this process, clients understand
the following:
a)
b)
c)
d)
The client’s independent custodian sends statements at least quarterly showing the market
values for each security included in the Assets and all account disbursements, including the
amount of the advisory fees paid to our firm;
Clients will provide authorization permitting the Third-Party Money Manager to be directly
paid by these terms;
The Third-Party Money Manager calculates the advisory fee and deducts them from the
client’s account; and
If our firm sends a copy of our invoice to the client, a legend urging the comparison of
information provided in our statement with those from the qualified custodian will be
included.
Financial Planning & Consulting:
Our firm charges on a flat fee or hourly fee basis for stand-alone Financial Planning & Consulting
services. Financial plans are priced according to the degree of complexity associated with the client’s
situation. The ultimate fee we charge you will be detailed in the Financial Planning Agreement. Our
flat fees range from $1,000 to $50,000, and the maximum hourly fee to be charged will not exceed
$300. Basic Financial Plans for families will be priced at $1,000 - $5,000, Financial Plans for
Businesses will be priced at $5,000 - $15,000, and Complex and multifaceted Financial Plans will be
priced at $15,000 to $50,000.
Fees are NEGOTIABLE. The fee for a financial plan is predicated upon the facts known at the start of
the engagement. Fees are commonly negotiated where multiple family accounts are involved. Since
financial planning is a discovery process, situations occur wherein the client is unaware of certain
financial exposures or predicaments. Our firm will not require a retainer exceeding $1,200 when
services cannot be rendered within 6 months.
Retirement Plan Consulting:
Our Retirement Plan Consulting services are billed on an hourly or flat fee basis or a fee based on the
percentage of Plan assets under management. The total estimated fee, as well as the ultimate fee
charged, is based on the scope and complexity of our engagement with the client. Our flat fees range
from $1,000 to $20,000. The maximum hourly fee to be charged will not exceed $300. Fees based on
a percentage of managed Plan assets will not exceed 1.00% and are billed on a pro-rata basis either
monthly or quarterly in arrears based on the value of the account(s) on the last day of the month or
quarter. The fee-paying arrangements will be determined on a case-by-case basis and will be detailed
in the signed consulting agreement. Investment management fees for 401k plans are billed monthly
or quarterly, in ARREARS, meaning accounts are invoiced at the end of the month or three-month
billing period.
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Other Types of Fees & Expenses
Custodians may charge transaction fees on purchases or sales of certain mutual funds and exchange-
traded funds via individual transaction charges. These transaction charges are usually small and
incidental to the purchase or sale of a security. However, certain custodial platforms offered by
custodians that custody our Clients’ assets such as Charles Schwab & Co., Inc. (“Schwab”), and Fidelity
Brokerage Services (“Fidelity”) have eliminated transaction fees for U.S. listed equities and exchange
traded funds. Fidelity requires that Clients opt into electronic delivery of statements or maintain at
least $1 million in assets at Fidelity in order to avoid transaction costs.
Termination & Refunds
Either party may terminate the advisory agreement signed with our firm for Comprehensive Wealth
Management service in writing at any time. Upon notice of termination from clients who are billed
quarterly in advance, the Third-Party Money Manager will process a pro-rata refund of the unearned
portion of the advisory fees charged in advance. Upon notice of termination from clients billed
quarterly in arrears, pro-rata advisory fees for services rendered to the point of termination will be
charged. If advisory fees cannot be deducted, our firm will send an invoice for due advisory fees to
the client.
Financial Planning & Consulting clients may terminate their agreement at any time before the
delivery of a financial plan by providing written notice. For purposes of calculating refunds, all work
performed by us up to the point of termination shall be calculated at the hourly fee currently in effect.
Clients will receive a pro-rata refund of unearned fees based on the time and effort expended by our
firm.
Our firm reserves the right to stop work on any account that is more than 30 days overdue. In
addition, our firm reserves the right to terminate any financial planning engagement where a client
has willfully concealed or has refused to provide pertinent information about financial situations
when necessary and appropriate, in our firm’s judgment, to providing proper financial advice.
Either party to a Retirement Plan Consulting Agreement may terminate at any time by providing
written notice to the Record Keeper. Upon receipt of the notice to terminate, the Record Keeper will
charge the client on a pro-rata basis, which takes into account work completed by our firm on behalf
of the client up to the point of termination and such fees will be due and payable.
Commissionable Securities Sales
Representatives of our firm are registered representatives, as well as Investment Advisor
Representatives of Osaic Wealth, Inc. (“OW”), member FINRA/SIPC, and a Registered Investment
Advisor. As such they are able to accept compensation for the sale of securities or other investment
products, including distribution or service (“trail”) fees. Clients should be aware that the practice of
accepting commissions for the sale of securities presents a conflict of interest and gives our firm
and/or our representatives an incentive to recommend investment products based on the
compensation received. Our firm generally addresses commissionable sales conflicts that arise when
explaining to clients these sales create an incentive to recommend based on the compensation to be
earned and/or when recommending commissionable mutual funds, explaining that “no-load” funds
are also available. Our firm does not prohibit clients from purchasing recommended investment
products through other unaffiliated brokers or agents.
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Ashworth Wealth, LLC
Our firm does not charge advisory fees in addition to commissions or markups.
Item 6: Performance-Based Fees & Side-By-Side Management
.
Our firm does not charge performance-based fees
Item 7: Types of Clients & Account Requirements
Our firm has the following types of clients:
•
•
Individuals and High Net Worth Individuals;
Pension and Profit-Sharing Plans;
•
Our requirements for opening and maintaining accounts or otherwise engaging us:
•
Our firm requires a minimum account balance of $500,000 for our Comprehensive Wealth
Management service. However, our firm, in its sole discretion may waive this requirement.
The minimum annual investment advisory fee for our Comprehensive Wealth Management
service is $5,000.00. However, legacy client relationships may exist where the fees are lower.
Further, our firm’s management, in its sole discretion, may waive this 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.).
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
Methods of Analysis
Securities analysis methods rely on the assumption that the companies whose securities are
purchased and/or sold, the rating agencies that review these securities, and other publicly available
sources of information about these securities, are providing accurate and unbiased data. While our
firm is alert to indications that data may be incorrect, there is always a risk that our firm’s analysis
may be compromised by inaccurate or misleading information.
Charting:
In this type of technical analysis, our firm reviews charts of market and security activity in
an attempt to identify when the market is moving up or down and to predict how long the trend may
last and when that trend might reverse.
Cyclical Analysis:
Statistical analysis of specific events occurring at a sufficient number of relatively
predictable intervals that they can be forecasted into the future. Cyclical analysis asserts that cyclical
forces drive price movements in the financial markets. Risks include that cycles may invert or
disappear and there is no expectation that this type of analysis will pinpoint turning points, instead
be used in conjunction with other methods of analysis.
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Ashworth Wealth, LLC
Fundamental Analysis:
The analysis of a business's financial statements (usually to analyze the
business's assets, liabilities, and earnings), health, and its competitors and markets. When analyzing
a stock, futures contract, or currency using fundamental analysis there are two basic approaches one
can use: bottom up analysis and top down analysis. The terms are used to distinguish such analysis
from other types of investment analysis, such as quantitative and technical. Fundamental analysis is
performed on historical and present data, but with the goal of making financial forecasts. There are
several possible objectives: (a) to conduct a company stock valuation and predict its probable price
evolution; (b) to make a projection on its business performance; (c) to evaluate its management and
make internal business decisions; (d) and/or to calculate its credit risk.; and (e) to find out the
intrinsic value of the share.
When the objective of the analysis is to determine what stock to buy and at what price, there are two
basic methodologies investors rely upon: (a) Fundamental analysis maintains that markets may
misprice a security in the short run but that the "correct" price will eventually be reached. Profits can
be made by purchasing the mispriced security and then waiting for the market to recognize its
"mistake" and reprice the security.; and (b) Technical analysis maintains that all information is
reflected already in the price of a security. Technical analysts analyze trends and believe that
sentiment changes predate and predict trend changes. Investors' emotional responses to price
movements lead to recognizable price chart patterns. Technical analysts also analyze historical
trends to predict future price movement. Investors can use one or both of these different but
complementary methods for stock picking. This presents a potential risk, as the price of a security
can move up or down along with the overall market regardless of the economic and financial factors
considered in evaluating the stock.
Technical Analysis:
A security analysis methodology for forecasting the direction of prices through
the study of past market data, primarily price and volume. A fundamental principle of technical
analysis is that a market's price reflects all relevant information, so their analysis looks at the history
of a security's trading pattern rather than external drivers such as economic, fundamental and news
events. Therefore, price action tends to repeat itself due to investors collectively tending toward
patterned behavior – hence technical analysis focuses on identifiable trends and conditions.
Technical analysts also widely use market indicators of many sorts, some of which are mathematical
transformations of price, often including up and down volume, advance/decline data and other
inputs. These indicators are used to help assess whether an asset is trending, and if it is, the
probability of its direction and of continuation. Technicians also look for relationships between
price/volume indices and market indicators. Technical analysis employs models and trading rules
based on price and volume transformations, such as the relative strength index, moving averages,
regressions, inter-market and intra-market price correlations, business cycles, stock market cycles
or, classically, through recognition of chart patterns. Technical analysis is widely used among traders
and financial professionals and is very often used by active day traders, market makers and pit
traders. The risk associated with this type of analysis is that analysts use subjective judgment to
decide which pattern(s) a particular instrument reflects at a given time and what the interpretation
of that pattern should be.
Investment Strategies We Use
The primary investment strategy used on client accounts is structured asset allocation. This means
that we use passively managed index, asset class funds, and exchange-traded funds as the core
investments, and may add actively managed funds where there may be other opportunities within
the client’s overall risk tolerances. Portfolios are generally globally diversified to control the risk
associated with traditional markets.
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Ashworth Wealth, LLC
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. Other strategies may include long-
term purchases, short-term purchases, and margin transactions.
Cash & Cash Equivalents:
Cash and cash equivalents generally refer to either United States dollars
or highly liquid short-term debt instruments such as, but not limited to, treasury bills, bank CD’s and
commercial papers. Generally, these assets are considered nonproductive and will be exposed to
inflation risk and considerable opportunity cost risk. Investments in cash and cash equivalents will
generally return less than the advisory fee charged by our firm. Our firm may recommend cash and
cash equivalents as part of our clients’ asset allocation when deemed appropriate and in their best
interest. Our firm considers cash and cash equivalents to be an asset class. Therefore, our firm assess
an advisory fee on cash and cash equivalents unless indicated otherwise in writing.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear. While the stock
market may increase and the account(s) could enjoy a gain, it is also possible that the stock market
may decrease, and the account(s) could suffer a loss. It is important that clients understand the risks
associated with investing in the stock market, and that their assets are appropriately diversified in
investments. Clients are encouraged to ask our firm any questions regarding their risk tolerance.
Description of Material, Significant or Unusual Risks
All investment programs have certain risks that are borne by the investor. Our investment approach
constantly keeps the risk of loss in mind. Investors face the following investment risks:
•
•
•
•
•
•
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.
Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible
and intangible events and conditions. This type of risk is caused by external factors
independent of a security’s particular underlying circumstances. For example, political,
economic and social conditions may trigger market events.
Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as 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.
Business Risk: These risks are associated with a particular industry or a particular company
within an industry. For example, oil-drilling companies depend on finding oil and then
refining it, a lengthy process, before they can generate a profit. They carry a higher risk of
profitability than an electric company, which generates its income from a steady stream of
customers who buy electricity no matter what the economic environment is like.
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Ashworth Wealth, LLC
•
•
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.
Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of
profitability, because the company must meet the terms of its obligations in good times and
bad. During periods of financial stress, the inability to meet loan obligations may result in
bankruptcy and/or a declining market value.
Item 9: Disciplinary Information
There are no legal or disciplinary events that are material to the evaluation of our advisory business
or the integrity of our management.
Item 10: Other Financial Industry Activities & Affiliations
Investment Advisors are also licensed insurance agents and have affiliations with various insurance
companies whose products they sell. This may create a conflict of interest and may offer IA Reps an
incentive to recommend insurance products that produce insurance commissions for the IA Rep.
When any such recommendations are made, IA Reps will disclose this potential conflict of interest
prior to completing any transaction and will obtain specific consent from the Client before
purchasing any insurance product. Additionally, Clients always have the option to purchase
insurance products through other agents not affiliated with Ashworth Wealth, LLC.
Certain persons affiliated with our firm are also registered representatives and investment adviser
representatives of Osaic Wealth, Inc. (OW), member FINRA/SIPC (a Broker-Dealer and Registered
Investment Adviser) and may receive compensation in the form of commissions and other Advisory
Fees. While this can create a conflict of interest, we are bound by our code of ethics and will only act
in the best interest of our clients.
Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal
Trading
As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material
facts and to act solely in the best interest of each of our clients at all times. Our fiduciary duty is the
underlying principle for our firm’s Code of Ethics, which includes procedures for personal securities
transaction and insider trading. Our firm requires all representatives to conduct business with the
highest level of ethical standards and to comply with all federal and state securities laws at all times.
Upon employment with our firm, and at least annually thereafter, all representatives of our firm will
acknowledge receipt, understanding and compliance with our firm’s Code of Ethics. Our firm and
representatives must conduct business in an honest, ethical, and fair manner and avoid all circumstances
that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure
is provided to give all clients a summary of our Code of Ethics. If a client or a potential client wishes to
review our Code of Ethics in its entirety, a copy will be provided promptly upon request.
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Ashworth Wealth, LLC
Our firm recognizes that the personal investment transactions of our representatives demand the
application of a Code of Ethics with high standards and requires that all such transactions be carried out
in a way that does not endanger the interest of any client. At the same time, our firm also believes that if
investment goals are similar for clients and for our representatives, it is logical, and even desirable, that
there be common ownership of some securities.
1
In order to prevent conflicts of interest, our firm has established procedures for transactions effected by
. In order to monitor compliance with our personal
our representatives for their personal accounts
trading policy, our firm has pre-clearance requirements and a quarterly securities transaction reporting
system for all of our representatives.
Neither our firm nor a related person recommends, buys or sells for client accounts, securities in
which our firm or a related person has a material financial interest without prior disclosure to the
client.
Likewise, related persons of our firm buy or sell securities for themselves at or about the same time they
buy or sell the same securities for client accounts. In order to minimize this conflict of interest, our
related persons will place client interests ahead of their own interests and adhere to our firm’s Code of
Ethics, a copy of which is available upon request. Further, our related persons will refrain from buying
or selling the same securities prior to buying or selling for our clients in the same day unless included in
a block trade.
Item 12: Brokerage Practices
Selecting a Brokerage Firm
Our firm does not maintain custody of client assets. Client assets must be maintained by a qualified
custodian. Our firm does not have discretionary authority to determine the Broker-Dealer to be used
for a purchase or sale of securities for a client’s account. Clients should refer to the specific
Investment Manager’s ADV Part 2A regarding their specific Brokerage Practices used and any
conflicts of interest that might exist.
Ashworth Wealth, LLC does not receive fees or commissions from any of these arrangements. Certain
immediate family members have the option of portfolio aggregation in order to lower custodian
trading costs.
Item 13: Review of Accounts or Financial Plans
Our management personnel or financial advisors review accounts on at least an annual basis for our
Comprehensive Wealth Management Clients. Account reviews may be performed more frequently
1
For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse,
his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our
associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect
beneficial interest in.
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Ashworth Wealth, LLC
when market conditions dictate. Other conditions that may trigger a review are changes in the tax
laws, new investment information, and changes in a client's situation.
Clients receive periodic communications on at least an annual basis. Investment Advisory clients
receive written quarterly updates from Third Party Money Managers. The written updates may
include a net worth statement, a portfolio statement, and performance reports.
Item 14: Client Referrals & Other Compensation
Referral Fees
In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm provides cash or
non-cash compensation directly or indirectly to unaffiliated persons for testimonials or
endorsements (which include client referrals). Such compensation arrangements will not result in
higher costs to the referred client. In this regard, our firm maintains a written agreement with each
unaffiliated person that is compensated for testimonials or endorsements in an aggregate amount of
$1,000 or more (or the equivalent value in non-cash compensation) over a trailing 12-month period
in compliance with Rule 206 (4)-1 of the Investment Advisers Act of 1940 and applicable state and
federal laws. The following information will be disclosed clearly and prominently to referred
prospective clients at the time of each testimonial or endorsement:
•
•
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Whether or not the unaffiliated person is a current client of our firm,
A description of the cash or non-cash compensation provided directly or indirectly by our
firm to the unaffiliated person in exchange for the referral, if applicable, and
A brief statement of any material conflicts of interest on the part of the unaffiliated person
giving the referral resulting from our firm’s relationship with such unaffiliated person.
In cases where state law requires licensure of solicitors, our firm ensures that no solicitation fees are
paid unless the solicitor is registered as an investment adviser representative of our firm. If our firm
is paying solicitation fees to another registered investment adviser, the licensure of individuals is the
other firm’s responsibility.
More specifically, our firm pays SmartAsset a flat rate fee per referral from their online platform.
SmartAsset’s website enables users to find a financial adviser based on criteria provided by the user.
SmartAsset is not engaged in any activities either intended to (or appear to intend to) promote or
market the services of any particular investment adviser. Any information regarding financial
advisers is presented in a random or objective manner and does not involve highlighting the services
of any financial adviser to the disadvantage of others on the platform. Clients who are referred to our
firm through the SmartAsset platform will receive a solicitor acknowledgement disclosure form
explaining the fee arrangement between our firm and SmartAsset. Referred Clients will be required
to sign the disclosure form acknowledging that they understand the fee paying arrangements before
receiving advisory services from our firm.
Ashworth Wealth, LLC does not accept referral fees or any form of remuneration from other
professionals for client referrals.
The compensation paid to us by the Third-Party Money Manager may vary, and thus, there may be a
conflict of interest in recommending a Third-Party Money Manager who shares a larger portion of its
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Ashworth Wealth, LLC
advisory fees over another Third-Party Money Manager. Our firm’s fees are not higher than they
would have been had our client obtained services directly from the Third-Party Money Manager.
Prior to referring clients to any third-party advisors, we will ensure that third-party advisors are
licensed, or notice filed with the respective authorities. A potential conflict of interest in utilizing a
Third-Party Money Manager may be an incentive to us in selecting a particular Third-Party Money
Manager over another in the form of fees or services. In order to minimize this conflict our firm will
make our selections in the best interest of our clients. Our selection process factors in account sizes,
project complexity, taxation concerns, philanthropic desires, investment experience, etc. Our firm
will discuss all relevant factors with each client to help them determine the best Third-Party Money
Manager.
Item 15: Custody
All of our clients receive account statements directly from their qualified custodians at least quarterly
upon opening of an account. If our firm decides to also send account statements to clients, such notice
and account statements include a legend that recommends that the client compare the account
statements received from the qualified custodian with those received from our firm. Clients are
encouraged to raise any questions with us about the custody, safety or security of their assets and
our custodial recommendations.
Item 16: Investment Discretion
Ashworth Wealth, LLC does not have any investment discretion on managed accounts. Client should
refer to the specific Investment Manager agreement as it relates to discretion.
Item 17: Voting Client Securities
Our firm does not accept the proxy authority to vote client securities. Clients will receive proxies or
other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent
to our firm, our firm will forward them to the appropriate client and ask the party who sent them to
mail them directly to the client in the future. Clients may call, write or email us to discuss questions
they may have about particular proxy votes or other solicitations.
Third-Party Money Managers selected or recommended by our firm may vote proxies for clients.
Therefore, except in the event a Third-Party Money Manager votes proxies, clients maintain exclusive
responsibility for: (1) directing the manner in which proxies solicited by issuers of securities
beneficially owned by the client shall be voted, and (2) making all elections relative to any mergers,
acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s
investment assets. Therefore (except for proxies that may be voted by a Third-Party Money
Manager), our firm and/or the client shall instruct the qualified custodian to forward to copies of all
proxies and shareholder communications relating to the client’s investment assets.
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Ashworth Wealth, LLC
Item 18: Financial Information
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Our firm is not required to provide financial information in this Brochure because:
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Our firm does not require the prepayment of more than $1,200 in fees when services cannot
be rendered within 6 months.
Our firm does not have a financial condition or commitment that impairs our ability to meet
contractual and fiduciary obligations to clients.
Our firm has never been the subject of a bankruptcy proceeding.
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Ashworth Wealth, LLC