Overview
- Average Client Assets
- $5.5 million
- SEC CRD Number
- 150402
Fee Structure
Primary Fee Schedule (BWM FORM ADV PART 2A & 2B)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | and above | 1.75% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $17,500 | 1.75% |
| $5 million | $87,500 | 1.75% |
| $10 million | $175,000 | 1.75% |
| $50 million | $875,000 | 1.75% |
| $100 million | $1,750,000 | 1.75% |
Clients
- HNW Share of Firm Assets
- 77.88%
- Total Client Accounts
- 344
- Discretionary Accounts
- 342
- Non-Discretionary Accounts
- 2
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients
Regulatory Filings
Additional Brochure: BWM FORM ADV PART 2A & 2B (2026-03-26)
View Document Text
Item 1 – Cover Page
Part 2A of Form ADV Firm Brochure
Blossom Wealth Management, LLC
PO Box 125
Alamo, CA 94507
Tel: (925) 833-9999
Fax: (877) 665-8765
www.blossomwm.com
March 26, 2026
This Brochure provides information about the qualifications and business practices of
Blossom Wealth Management, LLC (hereinafter “BWM,” “Adviser” or the “Firm”). If you have
any questions about the contents of this Brochure, please contact us at (925) 833-9999
and/or email james@blossomwm.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.
information about BWM
BWM is a registered investment adviser. Registration as an Investment Adviser does not
imply any level of skill or training. The oral and written communications of an Adviser
provide you with information about which you determine to hire or retain an Adviser.
Additional
is also available on the SEC’s website at
www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as
a CRD number. Our firm’s CRD number is 150402.
Item 2 – Material Changes
The purpose of this page is to inform you of any material changes to our brochure. If you are
receiving this brochure for the first time this section may not be relevant to you.
Blossom Wealth Management, LLC (“BWM”) reviews and updates our brochure at least
annually to confirm that it remains current. We made the following material change with the
annual update to our brochure, dated March 26, 2026:
Item 4 – Advisory Business
• We removed language regarding the (“THRIVE”) automated investment program,
which we no longer offer.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
• We made updates to the strategies and risks associated with the investment types we
utilize in client accounts.
Please see the corresponding section below for complete information regarding the above
change.
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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 ...................................................................................................................5
Description of Advisory Firm ....................................................................................................................... 5
Tailored Services and Client Imposed Restrictions ..................................................................................... 9
Wrap Fee Programs ................................................................................................................................... 10
Assets Under Management ....................................................................................................................... 10
Publication of Periodicals .......................................................................................................................... 10
Research Reports ...................................................................................................................................... 10
Item 5 – Fees and Compensation ........................................................................................................ 11
Fee Schedule ............................................................................................................................................. 11
Billing Method ........................................................................................................................................... 12
Other Fees and Expenses .......................................................................................................................... 13
Other Compensation ................................................................................................................................. 13
Termination ............................................................................................................................................... 14
Item 6 – Performance-Based Fees and Side-By-Side Management ....................................................... 14
Item 7 – Types of Clients ..................................................................................................................... 14
Account Minimum ..................................................................................................................................... 14
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................................. 15
Methods of Analysis .................................................................................................................................. 15
Investment Strategies ............................................................................................................................... 15
Risk of Loss ................................................................................................................................................ 18
Item 9 – Disciplinary Information ........................................................................................................ 26
Item 10 – Other Financial Industry Activities and Affiliations ............................................................... 26
Agents of Unaffiliated Insurance Agency .................................................................................................. 26
Item 11 – Code of Ethics ..................................................................................................................... 26
Code of Ethics ............................................................................................................................................ 26
Item 12 – Brokerage Practices............................................................................................................. 28
The Custodian and Brokers We Use .......................................................................................................... 28
Aggregation with Client Orders ................................................................................................................. 31
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Item 13 – Review of Accounts ............................................................................................................. 33
Review of Accounts ................................................................................................................................... 33
Reports to Clients ...................................................................................................................................... 34
Item 14 – Client Referrals and Other Compensation ............................................................................ 34
Outside Referrals ...................................................................................................................................... 34
Item 15 – Custody .............................................................................................................................. 35
Item 16 – Investment Discretion ......................................................................................................... 35
Item 17 – Voting Client Securities ....................................................................................................... 36
Item 18 – Financial Information .......................................................................................................... 36
Part 2B of Form ADV: Brochure Supplements ........................................................................................ i
Item 1 – Cover Page ..................................................................................................................................... i
George A. Salter II ............................................................................................................................... iv
Item 2 – Educational Background and Business Experience ...................................................................... iv
Item 3 – Disciplinary Information ............................................................................................................... v
Item 4 – Other Business Activities .............................................................................................................. v
Item 5 – Additional Compensation ............................................................................................................ vi
Item 6 – Supervision .................................................................................................................................. vi
James E. Salter ................................................................................................................................... vii
Item 2 – Educational Background and Business Experience ...................................................................... vii
Item 3 – Disciplinary Information ............................................................................................................. viii
Item 4 – Other Business Activities ............................................................................................................ viii
Item 5 – Additional Compensation .............................................................................................................ix
Item 6 – Supervision ...................................................................................................................................ix
Craig Braemer ...................................................................................................................................... x
Item 2 – Educational Background and Business Experience ....................................................................... x
Item 3 – Disciplinary Information ...............................................................................................................xi
Item 4 – Other Business Activities ..............................................................................................................xi
Item 5 – Additional Compensation .............................................................................................................xi
Item 6 – Supervision ...................................................................................................................................xi
PRIVACY INFORMATION ...................................................................................................................... A
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Item 4 – Advisory Business
Description of Advisory Firm
Blossom Wealth Management, LLC (“Blossom,” “BWM,” “Firm,” or “Adviser”) is a privately
owned limited liability company registered with the U.S. Securities and Exchange
Commission. Blossom’s principal place of business is in San Ramon, California. The firm's
principal shareholders - George A. Salter II, CEO, and James E. Salter, COO, co-founded the
firm in 2009.
Fiduciary Duty
Registered investment advisers are considered fiduciaries under federal law. Our fiduciary
duty carries with it an obligation to act in the best interest of our clients pursuant to a
relationship of trust and confidence. It encompasses a duty of care and a duty of loyalty.
Duty of Care
The duty of care includes, among other things:
•
the duty to provide advice that is in the best interest of the client;
•
the duty to seek best execution of a client’s transactions where the adviser has the
• responsibility to select broker-dealers to execute client trades; and
•
the duty to provide advice and monitoring over the course of the relationship.
The duty to provide advice suitable to each client based on a reasonable understanding of
the client’s objectives is a critical component of the duty of care. Providing suitable advice
includes making a reasonable inquiry into the client’s financial situation, investment
experience, and financial goals and then updating this information as necessary throughout
the course of the relationship to reflect the client’s changing objectives over time and
adjusting the advice we provide to reflect any changed circumstances.
When BWM has the responsibility to select broker-dealers to execute client trades in
discretionary accounts, we seek to trade such that the client’s total cost or proceeds in each
transaction are the most favorable under the circumstances. In doing so, we consider the full
range and quality of a broker’s services and so the determinative factor is not necessarily the
lowest possible commission cost but whether the transaction represents the best qualitative
execution. Moreover, we periodically and systematically evaluate the execution we receive
on behalf of our clients.
Our duty of care includes an obligation to provide advice and monitoring at a frequency that
is in the best interest of the client, taking into account the scope of the agreed relationship.
This scope is indicated by the duration and nature of the services as outlined in each client’s
advisory arrangement and extends to all personalized advice provided to clients.
Duty of Loyalty
BWM adheres to a duty of loyalty where we seek to serve the best interests of our clients and
never subordinate the interests of our clients to our own. Simply put, BWM cannot place its
own interests ahead of the interests of our clients. In observance of this duty, we must make
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full and fair disclosure to clients of all material facts relating to the advisory relationship.
Further, we also seek to eliminate or at least expose through full and fair disclosure all
conflicts of interest which might incline BWM, consciously or unconsciously, to render advice
that is not disinterested. We believe that in order for disclosure to be full and fair, it should
be sufficiently specific so that each client is able to understand the material fact or conflict of
interest and make an informed decision whether to provide consent. Consequently, we
provide this ADV 2A brochure to all prospective clients at or before entering into a contract
so that they can use the information within to decide whether or not to enter into an advisory
relationship.
Blossom offers the following advisory services to its clients:
Investment Management Services
Blossom provides discretionary investment supervisory services. Each portfolio is designed
in an effort to meet the client’s particular investment goals, objectives, circumstances, and
risk tolerance while also providing clients with access to personal advisory services. Because
investments involve varying degrees of risk, they will only be implemented or recommended
when we deem them to be consistent with the client's stated investment objectives, tolerance
for risk, liquidity, and suitability.
in client accounts. Additionally, Blossom’s
Blossom primarily utilizes Exchange traded funds (ETFs) when making investment
selections/recommendations
investment
selections/recommendations, depending on the individual investment objectives and needs
of the client may include:
• Exchange-listed equity securities
• Mutual fund shares
• Securities traded over-the-counter (unlisted)
• Corporate debt securities
• Money market funds, cash sweeps, and other cash equivalents
• Certificates of deposit
• Municipal securities
• United States governmental securities
On rare occasions, we also transact in options contracts in client accounts.
Blossom occasionally offers advice regarding additional types of investments if they are
appropriate to address the individual needs, goals, and objectives of the client or in response
to client inquiry. Blossom may offer investment advice on any investment held by the client
at the start of the advisory relationship. We describe the material investment risks for many
of the securities that we select/recommend in Item 8 below.
We discuss our discretionary authority below under Item 16 - Investment Discretion. For
more information about the restrictions clients can put on their accounts, see Tailored
Services and Client Imposed Restrictions in this item below. We describe the fees charged
for Investment Management Services below under Item 5 - Fees and Compensation.
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Financial Planning and Financial Consulting Services
BWM provides a variety of financial planning services, pursuant to a written agreement, to
individuals, families, and other clients regarding the management of their financial resources
based upon an analysis of the client’s current situation, goals, and objectives. Generally, such
financial planning services will involve preparing a financial plan or rendering a financial
consultation for clients based on the client’s financial goals and objectives. This planning or
consulting typically encompasses one or more of the following areas: investment planning,
retirement planning, estate planning, charitable giving, education planning, and business
planning.
The plan developed or financial consultation rendered to the client will usually include
general recommendations for a course of activity or specific actions to be taken by the clients.
For example, recommendations may be made that the clients begin or revise investment
programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or
alter retirement savings, or establish education or charitable giving programs. BWM may
also refer clients to an accountant, attorney, or other specialist. For planning engagements,
Adviser will generally provide a written summary of Client’s financial situation,
observations, and recommendations. However, on some occasions, plans are delivered
verbally. For consulting engagements, Adviser generally does not provide a written
summary. Plans or consultations are typically completed within six months of contract date,
assuming all information and documents requested are provided promptly.
investment advisor.
Implementation of
Should a client choose to implement the recommendations contained in the plan, Blossom
suggests the client work closely with his/her attorney, accountant, insurance agent,
mortgage broker, and/or
financial plan
recommendations is entirely at the client’s discretion. Clients may choose but are not
required to have Blossom assist with financial plan implementation, including investment
management services, for which Blossom receives additional compensation, as described
below in Item 5 – Fees and Compensation.
Family Office Services
Blossom approaches investment management with multiple generations in mind. We strive
to apply the same concepts as larger family offices to families who can potentially benefit
from similar advice but at a smaller scale. Our Family Office Services are based on the scope
and complexity of the client’s financial picture. Services typically include but are not limited
to investment management, philanthropic management, life management and budgeting,
business advisory, liquidity & succession planning, estate planning and wealth transfer,
training and education, reporting and record keeping, administrative/back-office services,
tax and legal advisory, and risk management and insurance services.
Services provided may be directly executed by Blossom, which creates a conflict where
affiliated persons of Blossom recommend themselves for services where they will earn
additional compensation (see Item 10 – Other Financial Industry Activities and
Affiliations for additional information). These services may also be executed by an
unaffiliated third party, generally when the service requires special licensing licensed
personnel or unique experience (e.g., accounting & legal services). In those circumstances,
Blossom will assist in identifying the need for such services and will connect the client with
recommended third party services. Blossom will sometimes act as a liaison between the
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Client and the third party.
Types of Family Offices
We classify family offices into three distinct categories:
• SFO or Single Family Office
As the name suggests, this is a private company that deals with the management of
finances for a single family. The functions of a single family office include managing part
or all of the family’s investments, trusts, estates, and acting as fiduciary. Often, the SFO
also offers concierge services to the family.
• MFO or Multi-Family Office
This is a company that offers investment, trust, estate, and fiduciary management
services to multiple families. MFOs can be private (i.e., only offering services to a few
families and not available to others), but most are commercial and available for many
families to hire. The families may or may not be connected, and a successful SFO can
potentially transition into a multi-family office over time.
• VFO or Virtual Family Office
Designed for families seeking the benefits of a family office without setting up a
company to facilitate it. A virtual family office allows families to outsource financial
services and other functions to professionals. Through the use of external consultants
and service providers, a VFO offers families many of the same benefits of a traditional
family office.
Fees for BWM’s Family Office Services are described below under Item 5 – Fees and
Compensation.
Retirement Plan Consulting Services
Our firm provides non-discretionary 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 may include:
• Establishing an Investment Policy Statement – Our firm will assist in the development
of a statement on behalf of the Plan 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.
•
Investment Monitoring – Our firm will monitor the performance of the investments and
notify the client in the event of a change in investment lineup is warranted.
• Participant Education – Our firm will provide opportunities to educate plan participants
about their retirement plan offerings, different investment options, and general
guidance on allocation strategies at least annually.
In providing services for retirement plan consulting, our firm does not provide any advisory
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services with respect to the following types of assets: employer securities, real estate
(excluding real estate 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) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to
the provision of services described therein.
Fees for BWM’s Retirement Plan Consulting Services are described below under Item 5 –
Fees and Compensation.
Limitations on Investments
In some circumstances, Blossom’s advice may be limited to certain types of securities.
Limitation by Plan Sponsor/Employer
In the event Blossom is managing assets within a retirement plan such as 401(k), 403(b), or
other employer plan, Blossom is limited to those investment providers and investment
options chosen by the plan administrator. Similarly, when we provide services to
participants in an employer-sponsored plan, the participant may be limited to investing in
securities included in the plan’s investment options. Therefore, Blossom can only make
recommendations to the client from among the available options and will not recommend or
invest the client’s account in other securities, even if there may be more suitable options
elsewhere.
Limitation by Client
Blossom may also limit advice based on certain client-imposed restrictions. For more
information about the restrictions clients can put on their accounts, see Tailored Services
and Client Imposed Restrictions in this Item below.
Non-Managed Assets
At its discretion, Blossom may offer securities trading activities for cash and securities in a
client’s non-managed account, acting as an intermediary between the client and the
custodian of the non-managed account. We do not provide investment advice regarding a
client’s non-managed assets or provide opinions as to the merits of any securities in non-
managed accounts. We also do not make any judgments as to the appropriateness of
assumed risk or suitability of any non-managed investment given the client’s situation. At
our discretion, Blossom offers this service in consideration of the client’s other accounts that
we manage.
Tailored Services and Client Imposed Restrictions
Blossom manages client accounts based on the investment strategy the client chooses, as
discussed below under Item 8 - Methods of Analysis, Investment Strategies, and Risk of
Loss. Blossom applies the strategy for each client, based on the client’s individual
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circumstances and financial situation. We make investment decisions for clients based on
information the client supplies about their financial situation, goals, and risk tolerance. Our
recommendations/investment selections may not be suitable if the client does not provide
us with accurate and complete information. It is the client’s responsibility to keep Blossom
informed of any changes to their investment objectives or restrictions.
Clients may also request other restrictions on the account, such as when a client needs to
keep a minimum level of cash in the account or does not want Blossom to buy or sell certain
specific securities or security types in the account. Blossom reserves the right to not accept
and/or terminate management of a client’s account if we feel that the client-imposed
restrictions would limit or prevent us from meeting or maintaining the client’s investment
strategy.
Wrap Fee Programs
Blossom does not manage accounts as part of a wrap or bundled fee program.
Assets Under Management
Blossom manages client assets in discretionary accounts on a continuous and regular basis.
We also provide retirement plan consulting services on a non-discretionary basis. As of
January 20, 2026, the total amount of assets under our management was:
Discretionary Assets
Non-Discretionary Assets
$ 363,980,740
$ 4,212,918
Total Assets
$368,193,658
Publication of Periodicals
Blossom utilizes a third-party service provider to issue a monthly newsletter providing
general information on various financial topics including, but not limited to, estate and
retirement planning, market trends, etc. No specific investment recommendations are
provided in this newsletter and the information provided does not purport to meet the
objective or needs of any individual. This newsletter is distributed free of charge.
Research Reports
Blossom Wealth Management provides a research product consisting of portfolio offerings
similar to those we manage for our clients. The service includes the following:
• Monthly/quarterly list and weightings of names in the Strategy portfolio;
• Research reports of original stock recommendations are shared upon request of
existing portfolio names. Subscribers are notified of new purchase ideas and the
company report around the date of addition; and
• Notification by email of portfolio changes on the day of the portfolio changes.
Portfolios are designed to follow a specific strategy among several offered, including multiple
individual stock strategies and an ETF based asset allocation model. The service is provided
through a subscription-based model and limited to representatives of unaffiliated
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investment advisers and broker-dealers that would like to bring in an outside research
service to help manage their clients’ money.
Item 5 – Fees and Compensation
Fee Schedule
Investment Management Services
Blossom Wealth Management charges an annual fee of up to 1.75%, payable quarterly in
advance, for Investment Management Services on actively managed accounts. Some
accounts, including employee accounts, are under different fee schedules honoring prior
agreements. We also manage some family and related accounts with fees waived or at a
reduced charge. Cash balances and balances subject to currently outstanding margin loans
are included for fee calculation purposes. For additions or withdrawals to existing accounts,
Blossom adjusts the client’s next quarterly billing calculation, when the total of all
contributions and withdrawals results in a difference of $10 or more in advisory fees.
Fees are generally negotiable. The Client’s fee rate will take into account the aggregate
number of portfolios they have under our management, including family accounts. Fees are
generally automatically deducted from the account in accordance with each client’s custodial
agreement. Clients will be provided with a quarterly statement from account custodian
reflecting deduction of the advisory fee.
Financial Planning/Financial Consulting
Adviser offers financial planning/consulting services on an hourly basis at a rate of $250 per
hour. BWM waives financial planning fees for clients that have engaged us for Investment
Management Services with portfolios holding $1 million or more in assets under our
management. An estimate for total hours will be determined at the start of the advisory
relationship after considering many factors, such as the level and scope of the services.
Adviser also offers financial planning services at a negotiable fixed fee ranging from $1,000
to $15,000, the total of which is calculated based on our hourly rate of $250 per hour and
dependent upon the level and scope of these services. The Adviser’s fee is exclusive of, and
in addition to brokerage commissions, transaction fees, and other related costs and expenses
associated with the plan’s implementations, which shall be incurred by the client.
Family Office Services
Adviser offers Family Office Services to clients using multiple fee options, as listed below. All
rates are negotiable at our discretion based on the scope and complexity of the services
provided.
1. Assets Under Management (AUM):
Assets Under Management
Up to $2,000,000
Next $1,000,000
Next $1,000,000
Next $1,000,000
$5,000,000+
Annual Fee*
1.00%
0.90%
0.80%
0.70%
0.60%
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2. Flat rate percentage fee based on client’s net worth and scope & complexity of
services provided at a negotiable rate not to exceed 1.0% per annum.
3. Fee based on hourly rate of $250 per hour.
Retirement Plan Consulting Services
Our Retirement Plan Consulting services are billed on an hourly or flat fee basis, and/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. Fees based on a percentage of managed
Plan assets will not exceed 1.00%. The fee-paying arrangements will be determined on a
case-by-case basis and will be detailed in the signed consulting agreement.
Billing Method
Investment Management Services
Blossom’s advisory fees are payable quarterly in advance at the beginning of each calendar
quarter. We charge one fourth of the annual fee each quarter based on the market value of
the client’s portfolio as of the last business day of the prior calendar quarter. The formula
used for the calculation is as follows: (Annual Rate) x (Total Assets Under Management at
Quarter-End) / 4.
For new client accounts, the first payment is a pro-rata calculation due upon execution of the
advisory agreement and/or when the client places assets in the custodial account(s) we
manage for them. The calculation will take into consideration the number of days remaining
in the quarter and the initial value of the portfolio. The formula used to calculate the initial
advisory fee would be as follows: (Result of Quarterly Calculation) x (Days Remaining in
Quarter) / (Total Number of Days in Quarter).
Financial Planning/Financial Consulting Services
One half of the total estimated hourly/fixed fees are due and payable at the time the client’s
agreement is executed, the remainder of the fees are due upon presentation of a plan or the
rendering of consulting services. Financial plans will be presented to the clients within 6
months of the contract date, provided that all information needed to prepare the financial
plan has been promptly provided by the clients.
Family Office Services
Clients may choose to have fees for family office services debited from their custodial
accounts or invoiced and payable by check.
AUM fees are billed quarterly in advance based on the above schedule. Fees based on a
client’s net worth are billed based on client’s initial net worth at the start of the relationship
and based on each subsequent previous year-end’s total net worth going forward. For hourly
and annual fee arrangements, a retainer equal to 25% of total quarterly estimated fees is
payable at the commencement of the agreement and ongoing fees are payable upon invoice
and/or at the conclusion of the contracted services rendered.
Set-up fees
Depending on the type of Family Office Services selected by the client, certain setup-related
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fees will also be charged when applicable. Such fees can include but are not limited to client
onboarding fees charged by third-party service providers that Blossom utilizes, and hourly
fees charged to help assess the client’s needs for outside attorneys, CPAs, and other
professionals.
In all cases, any additional fees will be discussed in advance with the client in advance, if
applicable.
Retirement Plan Consulting Services
Flat fees for Retirement Plan Consulting services are generally invoiced in advance on a
quarterly or annual basis. Fees based on the percentage of Plan assets under management
are calculated and debited quarterly in arrears by the Plan administrator and remitted to
Blossom.
Other Fees and Expenses
Blossom’s fees do not include custodian fees. Clients pay all brokerage commissions, bond
broker fees, stock transfer fees, margin charges, foreign exchange and settlement fees,
and/or other charges incurred in connection with transactions in accounts, from the assets
in the account. These charges are in addition to the fees clients pay to Blossom. See Item 12
– Brokerage Practices below for more information.
All fees paid to Adviser for investment advisory services are separate from the fees and
expenses charged by mutual funds and exchange traded funds to their shareholders. If
mutual fund shares are held in a client’s account, the client will be subject to deferred sales
charges, 12b-1 fees, early redemption fees, and other fund-related expenses, as applicable.
Each fund’s prospectus fully describes the fees and expenses. All fees paid to Blossom for
investment management are separate and distinct from the fees and expenses charged by
mutual funds. Mutual funds pay advisory fees to their managers, which are indirectly
charged to all holders of the mutual fund shares.
A client could invest in a mutual fund directly, without the services of Adviser. In that case,
the client would not receive the services provided by Adviser which are designed, among
other things, to assist the client in determining which mutual fund or funds are most
appropriate to the client’s financial condition, goals, and objectives. Accordingly, the clients
should review both the fees charged by the funds and the fees charged by Adviser to fully
understand the total amount of fees to be paid by the clients and to thereby evaluate the
advisory services being provided.
Advisory recommendations are based on the client’s financial situation at the time the
services are provided and are based on financial information disclosed by the client to
Adviser. Clients are advised that certain assumptions are generally made with respect to
interest and inflation rates and the use of past trends and performance of the market and
economy. Past performance is in no way an indication of future performance. As the client’s
financial situation, goals, objectives, or needs change, the client must notify BWM promptly.
Other Compensation
BWM receives payment for the research reports it provides to unaffiliated advisers, as
described in Research Reports in Item 4, above. For a description of the additional
compensation earned by BWM’s affiliated persons, also see Agents of Unaffiliated
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Insurance Agency in Item 10, below.
Termination
Investment Management Services
Either party may terminate the agreement at any time by providing written notice to the
other party. clients will receive pro-rata refunds for unearned advisory fees collected in
advance.
Financial Planning & Consulting Services
In the event that a client should cancel the financial planning agreement under which any
plan is being created, the client shall be billed for actual hours logged on the planning project
times the agreed upon hourly rate. Any surplus in the Adviser's possession as the result of
collecting a deposit at the time of signing the financial planning agreement will promptly be
returned to the client.
Family Office Services
Either party may terminate family office services for any reason upon a 30 days’ written
notice. Any unearned fees collected in advance will be prorated for services rendered and
the remaining portion refunded to the client.
Retirement Plan Consulting Services
Either party to a Retirement Plan Consulting Agreement may terminate at any time by
providing written notice to the other party. Full refunds will only be made in cases where
cancellation occurs within 5 business days of signing an agreement. After 5 business days
from initial signing, either party must provide the other party with 30 days’ written notice to
terminate billing. Billing will terminate 30 days after receipt of termination notice. Clients will
be charged on a pro-rata basis, which takes into account work completed by our firm on behalf
of the client. Clients will incur charges for bona fide advisory services rendered up to the point
of termination (determined as 30 days from receipt of said written notice) and such fees will
be due and payable.
Item 6 – Performance-Based Fees and Side-By-Side Management
BWM does not charge any performance-based fees (fees based on a share of capital gains on
or capital appreciation of the assets of a client).
Item 7 – Types of Clients
Investment Management Services
BWM provides portfolio management to individuals, high net worth individuals,
corporations, corporate pension and profit-sharing plans, and charitable institutions.
Account Minimum
Investment Management Services client portfolios are not subject to minimum account sizes.
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Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
We generally use a combination of fundamental and technical analysis across client accounts
and our various strategies when we purchase individual equity securities and based on this
analysis, sometimes sell off existing account positions brought into Blossom with new client
relationships. This fundamental analysis is generally a combination of seeking to understand
a company's long term business model (sometimes referred to as an economic moat) and its
potential upside. Other fundamental factors we would consider are the profitability of the
company, their cash flow, the strength of their balance sheet, and whether they pay
dividends. On the technical side, we evaluate whether the company is trading near all-time
highs or lows as those could be inflection points from a trading perspective.
Investment Strategies
BWM uses the following strategies in managing client accounts:
Long-term Purchases
We purchase securities with the idea of holding them in the clients account for a year or
longer. We sometimes do this because we believe the securities to be currently undervalued.
We generally do this because we want exposure to a particular asset class over time,
regardless of the current projection for this class.
A risk in a long-term purchase strategy is that, by holding the security for this length of time,
we sometimes do not take advantage of short-term gains that could be profitable to a client.
Moreover, if our predictions are incorrect, a security sometimes declines sharply in value
before we make the decision to sell.
Short-term Purchases
In some circumstances, we purchase securities with the idea of selling them within a
relatively short time (typically a year or less). We do this in an attempt to take advantage of
conditions that we believe will soon result in a price swing in the securities we purchase.
A risk in a short-term purchase strategy is that, should the anticipated price swing not
materialize, we are left with the option of having a long-term investment in a security that
was designed to be a short-term purchase, or potentially taking a loss. In addition, this
strategy involves more frequent trading than does a longer-term strategy and will result in
increased brokerage and other transaction-related costs, as well as less favorable tax
treatment of short-term capital gains.
Option Writing
In rare circumstances, we use options as an investment strategy. An option is a contract that
gives the buyer the right, but not the obligation, to buy or sell an asset (such as a share of
stock) at a specific price on or before a certain date. An option, just like a stock or bond, is a
security. An option is also a derivative because it derives its value from an underlying asset.
The two types of options are calls and puts:
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• A call gives us the right to buy an asset at a certain price within a specific period of time.
We will buy a call if we have determined that the stock will increase substantially before
the option expires.
• A put gives the holder the right to sell an asset at a certain price within a specific period
of time. We will buy a put if we have determined that the price of the stock will fall before
the option expires.
We sometimes use options to speculate on the possibility of a sharp price swing. We will also
use options to “hedge” a purchase of the underlying security; in other words, we will use an
option purchase to limit the potential upside and downside of a security we have purchased
for a client’s portfolio. We use “covered calls,” in which we sell an option on a security the
client owns. In this strategy, the client receives a fee for making the option available, and the
person purchasing the option has the right to buy the security from the client at an agreed
upon price. A risk of covered calls is that the option buyer does not have to exercise the
option, so that if we want to sell the stock prior to the end of the option agreement, we have
to buy the option back from the option buyer, for a possible loss. We use a “spreading
strategy,” in which we purchase two or more option contracts (for example, a call option that
the client buys and a put option that they sell) for the same underlying security. This
effectively puts clients on both sides of the market, but with the ability to vary price, time,
and other factors.
A risk of spreading strategies is that the ability to fully profit from a price swing is limited.
Short Sales
Short Sales are not made but purchases of negative beta mutual funds and Exchange Traded
Funds (“ETFs”) are made from time to time. A negative beta means that the stock is inversely
correlated with the market. Many precious metals and precious-metal-related stocks are
beta-negative as their value tends to increase when the general market is down and vice
versa.
BWM-Specific Strategies
BWM generally offers discretionary management services in the form of one of the following
strategies:
• ROME
• TAHOE
• DIVIDEND GROWTH EQUITY
• QUALITY GROWTH EQUITY
• REAL
• STABLE INCOME
• CUSTOM
The ROME Strategy
The Rome Strategy generally invests in ETFs holding broadly diversified, global asset classes
including stocks, bonds, and cash in varying allocations to target a specific risk category:
Aggressive, Normal, Moderate or Conservative. Depending on the circumstances, alternative
asset mutual funds and/or ETFs with underlying holdings including but not limited to real
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estate and commodities may also be deployed. Clients have the flexibility to invest in any of
the core strategies based on his or her risk profile and can easily shift to one of the other risk-
managed strategies if his or her risk preference changes.
The TAHOE Strategy
The Tahoe Strategy seeks to provide total return from growth and income investments with
a limited number of funds. The strategy is comprised of one or more each of global equity
and fixed income funds. In seeking to achieve its objective under normal circumstances, the
global equity portion of the strategy allocates its assets to underlying funds which invest in
domestic and international securities. In general, these funds purchase a broad and diverse
group of securities of companies with a greater emphasis on small capitalization and
value companies compared to their representation in the universe. The equity and fixed
income allocations are generally comprised of mutual funds that follow specific strategies
within their respective portfolios.
Dividend Growth Equity Strategy
The Dividend Growth Equity Strategy seeks to provide total return from a diversified cluster
of growing dividend companies. It is a concentrated allocation of dividend paying stocks that
focuses on companies that have generally grown their dividends over at least 10 years. This
is not a high yield strategy, but a strategy that focuses on companies that we deem to be
adequate capital allocators. these low-turnover holdings prefer companies with ten years of
consistent dividend growth led by what we perceive to be quality business models, strong
financial statements, and historically more conservative growth than stocks in general.
Quality Growth Equity Strategy
The Quality Growth Equity Strategy seeks to provide a total return driven by the
appreciation of the companies owned in the strategy. This concentrated, low-turnover,
equity strategy will hold growth companies in a diversified portfolio, typically dividend
paying, that we believe to be industry leaders potentially showing consistent and sustainable
growth. Valuation is important with these younger companies, but a strong business model
is the key metric in this investment decision making process.
The REAL Strategy
The Real Strategy is designed with the goal of generating competitive real estate income
versus both the overall market and privately held real estate using primarily publicly traded
Real Estate Investment Trusts (REITs). This concentrated strategy is well-diversified within
the REIT sector and will focus on what we perceive to be high quality assets in the various
REIT sectors. It will concentrate on companies within specific REIT sectors that we deem to
be growing dividend payers with adequate balance sheets in areas with potentially good
opportunities. This is not a high yield-oriented strategy. The Real Strategy will use both
individual and managed products in seeking to meet its stability and income goals.
Stable Income Strategy
The Stable Income Strategy is designed to generate income competitive with fixed income
when interest rates are relatively low and also seeks to generate some growth over time. The
goal is to build stable value over time with a similar or higher yield than the Bloomberg
Barclays U.S. Aggregate Bond Index. This well-diversified strategy will focus on what we
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perceive to be quality assets in several specific categories including: fixed income – short and
intermediate maturities, utilities, REITs (Real Estate Investment Trusts), and several
companies that generate market or better yields that have also shown consistent dividend
growth over time. This is not a high yield-oriented strategy, and it will use both individual
and managed products in an effort to meet its stability and income goal.
Custom Strategy
Where appropriate, BWM also offers a Custom Portfolio Allocation Strategy, which is a
comprehensive, customized strategy tailored specifically to a client’s needs across multiple
account types and risk categories.
Risk of Loss
Note: All investments involve the risk of loss, including (among other things) loss of principal, a
reduction in earnings (including interest, dividends, and other distributions), and the loss of
future earnings. These risks include market risk, liquidity risk, concentration risk, interest rate
risk, issuer risk, credit risk, currency risk, foreign investment risk, reinvestment risk, inflation
risk, horizon risk, longevity risk and general economic risk. Although BWM advises assets in a
manner consistent with risk tolerances, there can be no guarantee that our efforts will be
successful. Clients should be prepared to bear the risk of loss.
Market Risks
Competition
The securities industry and the varied strategies and techniques to be engaged in by the
Adviser are extremely competitive and each involves a degree of risk. The Adviser will
compete with firms, including many of the larger securities and investment banking firms,
which have substantially greater financial resources and research staff.
Market Volatility
The profitability of the Adviser substantially depends upon it correctly assessing the future
price movements of stocks, bonds, options on stocks, and other securities and the
movements of interest rates. The Adviser cannot guarantee that it will be successful in
accurately predicting price and interest rate movements.
Accuracy of Public Information
The Adviser selects investments, in part, on the basis of information and data filed by issuers
with various government regulators or made directly available to the Adviser by the issuers
or through sources other than the issuers. Although the Adviser evaluates such information
and data and sometimes seeks independent corroboration when it’s considered appropriate
and reasonably available, the Adviser is not in a position to confirm the completeness,
genuineness or accuracy of such information and data, and in some cases, complete and
accurate information is not available.
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Internal Risks
Adviser’s Investment Activities
The Adviser’s investment activities involve a significant degree of risk. The performance of
any investment is subject to numerous factors which are neither within the control of nor
predictable by the Adviser. Such factors include a wide range of economic, political,
competitive, technological, and other conditions (including acts of terrorism and war) that
sometimes affect investments in general or specific industries or companies. The securities
markets are sometimes volatile, which can adversely affect the ability of the Adviser to
generate profits in client accounts.
Conflicts of Interest
In the administration of client portfolios and financial reporting, the Adviser faces inherent
conflicts of interest which are described in this brochure. Generally, the Adviser seeks to
mitigate these conflicts through its Code of Ethics which provides that the client’s interest is
always held above that of the Firm and its associated persons.
Supervision of Trading Operations
The Adviser, with assistance from its brokerage and clearing firms, intends to supervise and
monitor trading activity in clients’ accounts in an effort to comply with firm and client
objectives. Despite the Adviser’s efforts, however, there is a risk that unauthorized or
otherwise inappropriate trading activity may occur in accounts.
Depending on the nature of the investment management service selected by a client and the
securities used to implement the investment strategy, clients will be exposed to risks that
are specific to the securities in their particular investment portfolio.
Reliance on Management and Key Personnel
Clients have no right or power to take part in the management of BWM. Accordingly, no client
should invest with BWM unless they are willing to entrust all aspects of management to
BWM. The investment performance of BWMs strategies depends largely on the skill of key
personnel of BWM. If key personnel were to leave BWM, we might not be able to find equally
desirable replacements and our performance could, as a result, be adversely affected.
Investment Risks - General
Strategies sometimes invest substantially all of the client’s available capital principally in
securities and can also engage in short sales of securities and trades in options (including
covered and over-the-counter options) and other derivative instruments, private securities,
and money market instruments. Markets for such instruments fluctuate and the market
value of any particular investment can vary substantially. In addition, such securities may be
issued by unseasoned companies and may be highly speculative. There is no guarantee that
BWM’s strategies will generate any income or appreciate in value.
Investments in Undervalued Securities
The Adviser intends to invest in undervalued securities. The identification of investment
opportunities in undervalued securities is a difficult task, and there are no assurances that
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such opportunities will be successfully recognized or acquired. While investments in
undervalued securities offer the opportunities for above-average capital appreciation, these
investments involve a high degree of financial risk and can result in substantial losses.
Returns generated from the Adviser’s investments sometimes do not adequately
compensate for the business and financial risks assumed.
Lack of Diversification
Client portfolios invested in BWM’s strategies may not be widely diversified among sectors,
industries, geographic areas, or types of securities. Further, client portfolios may not
necessarily be diversified among a wide range of issuers. Accordingly, client portfolios may
be subject to more rapid change in value than would be the case if the positions maintained a
wide diversification among companies or industry groups.
Short Sales
BWM may sell securities short. Short sales can, in certain circumstances, substantially
increase the impact of adverse price movements on a client’s portfolio. A short sale involves
the risk of a theoretically unlimited increase in the market price of the particular investment
sold short, which could result in an inability to cover the short position and a theoretically
unlimited loss; however, Blossom does not engage in such “naked” strategies. There can be
no assurance that securities necessary to cover a short position will be available for purchase.
Non-U.S. Investments
From time to time, the Adviser may invest and trade a portion of its assets in non-U.S.
securities and other assets (through ADRs and otherwise), which will give rise to risks
relating to political, social, and economic developments abroad, as well as risks resulting
from the differences between the regulations to which U.S. and foreign issuers and markets
are subject. Such risks may include:
• Political or social instability, the seizure by foreign governments of company assets, acts
of war or terrorism, withholding taxes on dividends and interest, high or confiscatory
tax levels, and limitations on the use or transfer of a client’s assets.
• Enforcing legal rights in some foreign countries is difficult, costly, and slow, and there
are sometimes special problems enforcing claims against foreign governments.
• Foreign securities and other assets often trade in currencies other than the U.S. dollar,
and the Adviser may directly hold foreign currencies and purchase and sell foreign
currencies through forward exchange contracts. Changes in currency exchange rates
will affect the Adviser’s net asset value, the value of dividends and interest earned, and
gains and losses realized on the sale of investments. An increase in the strength of the
U.S. dollar relative to these other currencies may cause the value of the Adviser’s
investments to decline. Some foreign currencies are particularly volatile. Foreign
governments may intervene in the currency markets, causing a decline in value or
liquidity of the Adviser’s foreign currency holdings. If the Adviser enters into forward
foreign currency exchange contracts for hedging purposes, it may lose the benefits of
advantageous changes in exchange rates. On the other hand, if the Adviser enters
forward contracts for the purpose of increasing return, it may sustain losses.
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• Non-U.S. securities, commodities and other markets may be less liquid, more volatile,
and less closely supervised by the government than in the United States. Foreign
countries often lack uniform accounting, auditing and financial reporting standards, and
there may be less public information about the operations of issuers in such markets.
Lack of Liquidity
BWM’s strategies may invest in thinly traded and relatively illiquid securities or those
securities may not be traded at the time a client’s account invested or may cease to be traded
after an account invests. Client accounts also may acquire significant positions in some
securities. In such cases, and in the event of extreme market activity, we may not be able to
liquidate account investments promptly, if necessary. In addition, an account’s sales of thinly
traded securities could potentially depress the market value of those securities and
thereby reduce the account’s profitability or increase its losses. Such circumstances or
events could affect client account gains or losses materially and adversely.
Risk of Default or Bankruptcy of Third Parties
The Adviser may engage in transactions in securities, commodities, other financial
instruments, and other assets that involve counterparties. Under certain conditions, the
Adviser could suffer losses if a counterparty to a transaction were to default or if the market
for certain securities, commodities, other financial instruments and/or other assets were to
become illiquid.
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.
Regulatory Risks
Strategy Restrictions
Certain institutions may be restricted from directly utilizing investment strategies of the
type in which the Adviser may engage. Such institutions, including entities subject to ERISA,
should consult their own advisors, counsel, and accountants to determine what restrictions
may apply and whether an investment in the Adviser is appropriate.
Trading Limitations
For securities, instruments and/or assets listed on an exchange, including options listed on
a public exchange, the exchange generally has the right to suspend or limit trading under
certain circumstances. Such suspensions or limits could render certain strategies difficult to
complete or continue and subject the Adviser to loss. Also, such a suspension could render it
impossible for the Adviser to liquidate positions and thereby expose the Adviser to potential
losses.
Lack of Registration
LP interests have neither been registered under the Securities Act nor under the securities
or “blue sky” laws of any state and, therefore, are subject to transfer restrictions.
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Security-Specific Risks
Exchange-Traded Funds
An exchange-traded fund (“ETF”) is a type of Investment Company (usually, an open-end fund
or unit investment trust) containing a basket of equities, fixed income instruments, and/or
commodities. ETFs may be structured to track the performance of a particular market index,
including broad-based or sector-specific indexes. These “passive” ETFs seek to achieve
investment results that correspond, before fees and expenses, to the performance of the
underlying index by generally holding the same securities, or a representative sample of the
securities, included in the index. However, such ETFs may not perfectly track their target index
due to fees, expenses, tracking error, market conditions, or portfolio rebalancing. Other ETFs
do not seek to replicate the performance of a specific index and instead rely on active portfolio
management. Actively managed ETFs may invest in a more limited number of securities, may
deviate significantly from market indexes, and may underperform or outperform the broader
market depending on market conditions and the effectiveness of the investment manager’s
strategies.
Unlike traditional mutual funds, which can only be redeemed at the end of a trading day, ETFs
trade throughout the day on an exchange. Like mutual funds, the prices of the underlying
securities and the overall market affect ETF prices. Similarly, factors affecting a particular
industry segment typically affect ETF prices that track that particular sector.
Equity Securities
Equity securities represent an ownership position in a company. Equity securities typically
consist of common stocks. The prices of stocks and the income they generate (such as
dividends) may fluctuate based on events specific to the company that issued the shares,
conditions affecting the general economy and overall market changes, changes or weakness
in the business sector the company does business in, and other factors. Further, prices of these
securities can be affected by financial contracts held by the issuer or third parties (such as
derivatives) relating to the security or other assets or indices.
There may be little trading in the secondary market for particular equity securities, which may
adversely affect the ability to dispose of those equity securities. Adverse publicity and investor
perceptions, whether or not based on fundamental analysis, may decrease the value and/or
liquidity of equity securities.
Small Cap Companies
Some of BWM’s strategies may invest a portion of assets in the stocks of companies with
small market capitalizations. While BWM believes these investments often provide
significant potential for appreciation, those stocks typically involve higher risks in some
respects than do investments in stocks of larger companies. For example, prices of such
stocks are often more volatile than prices of large-capitalization stocks. In addition, due to
thin trading in some such stocks, an investment in these stocks may be more illiquid than
that of larger capitalization stocks.
American Depository Receipts (ADR)
An ADR is a security that trades on U.S. exchanges but represents a specified number of
shares in a foreign corporation. Investors buy and sell ADRs on American markets just like
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regular stocks. Some banks and brokerage firms issue/sponsor ADRs. ADRs are subject to
risks of investing in foreign securities, including, but not limited to, less complete financial
information available about foreign issuers, less market liquidity, more market volatility, and
political instability. In addition, currency exchange-rate fluctuations affect the U.S. dollar-
value of foreign holdings.
Some ADRs and ordinary shares of foreign securities pay dividends, and many foreign
countries impose dividend withholding taxes up to 30%. Depending on a custodian’s ability
to reclaim any withheld foreign taxes on dividends, taxable accounts may be able to recoup
a portion of these taxes by use of the foreign tax credit. However, tax-exempt accounts, to the
extent they pay any foreign withholding taxes, may not be able to utilize the foreign tax
credit. Therefore, investors may be unable to recover any foreign taxes withheld on
dividends of foreign securities or ADRs.
Debt Securities (Bonds)
Issuers use debt securities to borrow money. Generally, issuers pay investors periodic
interest and repay the amount borrowed either periodically during the life of the security
and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-
coupon bonds, which do not pay current interest, but rather are priced at a discount from
their face values and their values accrete over time to face value at maturity. The market
prices of debt securities fluctuate depending on such factors as interest rates, credit quality,
and maturity. In general, market prices of debt securities decline when interest rates rise
and increase when interest rates fall. The longer the time to a bond’s maturity, the greater
its interest rate risk.
Market or Interest Rate Risk
The price of most fixed income securities moves in the opposite direction of the change in
interest rates. For example, as interest rates rise, the price of fixed income securities falls. If
the Adviser holds a fixed income security to maturity, the change in its price before maturity
may have little impact on the Adviser’s performance; however, if the Adviser has to sell the
fixed income security before the maturity date, an increase in interest rates could result in a
loss to the Adviser.
Fixed Income Call Option Risk
Many bonds, including agency, corporate and municipal bonds, and all mortgage-backed
securities, contain a provision that allows the issuer to “call” all or part of the issue before the
bond’s maturity date. The issuer usually retains this right to refinance the bond in the future
if market interest rates decline below the coupon rate. There are three disadvantages to the
call provision. First, the cash flow pattern of a callable bond is not known with certainty.
Second, because the issuer will call the bonds when interest rates have dropped, the Adviser
is exposed to reinvestment rate risk – the Adviser will have to reinvest the proceeds received
when the bond is called at lower interest rates Finally, the capital appreciation potential of
a bond will be reduced because the price of a callable bond may not rise much above the price
at which the issuer may call the bond.
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Inflation Risk
Inflation risk results from the variation in the value of cash flows from a security due to
inflation, as measured in terms of purchasing power. For example, if the Adviser purchases
a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then
the purchasing power of the cash flow has declined. For all but inflation- linked bonds,
adjustable bonds or floating rate bonds, the Adviser is exposed to inflation risk because the
interest rate the issuer promises to make is fixed for the life of the security.
Options and Other Derivative Instruments
BWM may invest, from time to time, in options and other derivative instruments, including,
but not limited to, the buying and selling of puts and calls on some of the securities held by
BWM. The prices of many derivative instruments, including many options and swaps, are
highly volatile. The values of options and swap agreements depend primarily upon the price
of the securities, indexes, commodities, currencies, or other instruments underlying them.
Price movements of options contracts and payments pursuant to swap agreements are also
influenced by, among other things, interest rates, changing supply and demand relationships,
trade, fiscal, monetary and exchange control programs and policies of governments, and
national and international political and economic events and policies. Options on highly
volatile securities, currencies or other assets may be more expensive than options on other
investments.
Hedging Transactions
Investments in financial instruments such as forward contracts, options, commodities and
interest rate swaps, caps and floors, other derivatives, and other investment techniques are
utilized to hedge against fluctuations in the relative values of account positions as a result of
changes in currency exchange rates, interest rates and/or the equity markets or sectors
thereof. Any hedging against a decline in the value of an account’s positions does not
eliminate fluctuations in the values of those positions or prevent losses if the values of such
positions decline, but establishes other positions designed to gain from those same
developments, thus moderating the decline in the position’s value. Such hedging transactions
also limit the opportunity for gain if the value of the account’s positions should increase.
BWM is not obligated to establish hedges for positions held in clients’ accounts.
Leverage
Some of BWM’s strategies will use leverage by engaging in short sales, entering into swaps
and other derivatives contracts, and other leveraging strategies. Such leverage increases the
risk of loss and volatility. In addition, the use of leverage requires the pledging of assets as
collateral. Margin calls or changes in margin requirements can cause a client’s account to be
required to pledge additional collateral or liquidate holdings, which could require the
account to close positions at substantial losses that would not otherwise be realized.
Alternative Investments (Limited Partnerships)
Some Blossom clients own individual alternative investment securities purchased under
prior investment strategies; however, Blossom no longer invests in such securities on an
individual basis. Instead, alternative investments in our current strategies are limited to
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publicly-traded Exchange Traded Fund (ETF) and open-end mutual fund purchases.
A limited partnership is a financial affiliation that includes at least one general partner and
a number of limited partners. The partnership invests in a venture, such as real estate
development or oil exploration, for financial gain. The general partner does not usually
invest any capital but has management authority and unlimited liability. That is, the general
partner runs the business and, in the event of bankruptcy, is responsible for all debts not
paid or discharged. The limited partners have no management authority and confine their
participation to their capital investment. That is, limited partners invest a certain amount of
money and have nothing else to do with the business. However, their liability is limited to
the amount of the investment. In the worst-case scenario for a limited partner, he/she loses
what he/she invested. Profits are divided between general and limited partners according to
an arrangement formed at the creation of the partnership. Full disclosure is available in the
offering documents of the particular limited partnership.
Withdrawal of Capital
The ability to withdraw funds from LP interests is usually restricted in accordance with the
withdrawal provisions contained in an Offering Memorandum. In addition, substantial
withdrawals by investors within a short period of time could require a fund to liquidate
securities positions and other investments more rapidly than would otherwise be desirable,
possibly reducing the value of the fund’s assets and/or disrupting the fund’s investment
strategy.
Financial Planning Risk
The financial planning tools BWM uses to create financial plans for clients rely on various
assumptions, such as estimates of inflation, risk, economic conditions, and rates of return on
security asset classes. Return assumptions generally reflect asset class returns instead of
actual investment returns, and do not always include fees or expenses that clients would pay
if they invested in specific products.
Financial planning software is only a tool used to help guide BWM and the client in
developing an appropriate plan, and we cannot guarantee that clients will achieve the results
shown in the plan. Results will vary based on the information provided by the client
regarding the client’s assets, risk tolerance, and personal information. Changes to the
program’s underlying assumptions or differences in actual personal, economic, or market
outcomes generally result in different outcomes for the client.
Clients should carefully consider the assumptions and limitations of the financial planning
software and should discuss the results of the plan with us before making any changes to
their investments or financial plan. If the financial plan includes recommendations for
investing in securities, you should understand that investing in securities involves risk of
loss, and you should be prepared to bear that risk.
Other Risks
Cybersecurity
Information and technology systems can be vulnerable to damage or interruption from
computer viruses, network failures, computer and telecommunication failures, infiltrations
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by unauthorized persons and security breaches, usage errors by its professionals, power
outages and catastrophic events such as fires, tornadoes, floods, hurricanes, and
earthquakes. Although we have implemented various measures to manage risks relating to
these types of events, if these systems are compromised, or become inoperable for extended
periods of time, or cease to function properly, we may have to make a significant investment
to fix or replace them. The failure of these systems can cause significant interruptions in our
operations and result in a failure to maintain the security, confidentiality or privacy or
sensitive data, including personal information relating to clients. Such a failure could
potentially harm our reputation, subject us to legal claims, and otherwise have an adverse
impact on our ability to perform advisory functions.
Pandemics and Other Public Health Crises
Pandemics and other health crises, such as the outbreak of an infectious disease such as
severe acute respiratory syndrome, avian flu, H1N1/09 flu and COVID-19 or any other
serious public health concern, together with any resulting restrictions on travel or
quarantines imposed, could have a negative impact on the economy, and business activity in
any of the areas in which client investments may be located. Such disruption, or the fear of
such disruption, could have a significant and adverse impact on the securities markets, lead
to increased short-term market volatility or a significant market downturn, and can have
adverse long-term effects on world economies and markets generally.
Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal
or disciplinary events that would be material to your evaluation of BWM or the integrity of
BWM’s management. BWM has no information applicable to this item.
Item 10 – Other Financial Industry Activities and Affiliations
Agents of Unaffiliated Insurance Agency
As licensed insurance agents, Messrs. George A. Salter II, and James E. Salter, in their
individual capacities, sometimes recommend to advisory clients a variety of insurance
products, including commissionable (variable and non-variable) insurance products for
which they receive compensation, in addition to fees received for Investment Management
Services. We recognize that this practice presents a conflict of interest and provides these
employees with an incentive to recommend investment products based on compensation
received rather than on client need. We address this conflict by retaining and reviewing all
orders for such products to verify that there is a suitable benefit for the client through such a
transaction. Clients are under no obligation to implement any recommended insurance
transactions through any particular insurance company and are not obligated to purchase
any insurance products from BWM’s associated persons.
Item 11 – Code of Ethics
Code of Ethics
BWM has adopted a Code of Ethics for all supervised persons of the firm describing its high
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standard of business conduct, and fiduciary duty to its clients. The Code of Ethics includes
provisions relating to the confidentiality of client information, a prohibition on insider
trading, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts
and the reporting of certain gifts and business entertainment items, and personal securities
trading procedures, among other things. All supervised persons at BWM must acknowledge
the terms of the Code of Ethics upon hire and each time it is amended thereafter.
The Code of Ethics is designed so that the personal securities transactions, activities, and
interests of the employees of BWM will not interfere with (i) making decisions in the best
interest of advisory clients and (ii) implementing such decisions while, at the same time,
allowing employees to invest for their own accounts. Under the Code certain classes of
securities have been designated as exempt transactions, based upon a determination that
these would materially not interfere with the best interest of BWM’s clients. In addition, the
Code requires pre-clearance of certain transactions and restricts trading in close proximity
to client trading activity. Nonetheless, because the Code of Ethics in some circumstances
would permit employees to invest in the same securities as clients, there is a possibility that
employees might benefit from market activity by a client in a security held by an employee.
Employee trading is continually monitored under the Code of Ethics, and to reasonably
prevent conflicts of interest between BWM and its clients.
BWM’s clients or prospective clients may request a copy of the firm's Code of Ethics by
contacting James E. Salter at (925) 833-9999 or via email at james@blossomwm.com.
Personal Trading Practices
Adviser and its representatives buy and sell for their personal accounts investment products
identical to those recommended to clients. It is the express policy of Adviser that neither
Adviser, nor its representatives may purchase or sell any security prior to a transaction being
implemented for an advisory account except when entered as part of an aggregated purchase
(See Aggregation with Client Orders below for more information).
This policy is meant to prevent Adviser and/or its representatives from benefiting as a result
of transactions placed on behalf of advisory accounts. Adviser has established the following
restrictions in order to ensure its fiduciary responsibilities to clients are met:
1. No principal or employee of our firm may put his or her own interest above the
interest of an advisory client.
2. No principal or employee of the firm may buy or sell securities for their personal
portfolio(s) where their decision is a result of information received as a result of his
or her employment unless the information is also available to the investing public.
3. BWM requires prior approval for any IPO or private placement investments by related
persons of the firm.
4. BWM maintains a list of all reportable securities holdings for our firm and anyone
associated with this advisory practice that has access to advisory recommendations
("access person"). These holdings are reviewed on a regular basis by our firm's Chief
Compliance Officer or his/her designee.
5. BWM has established procedures for the maintenance of all required books and
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records.
6. Clients can decline to implement any advice rendered, except in situations where
BWM is granted discretionary authority.
7. All of the principals and employees must act in accordance with all applicable Federal
regulations governing registered investment advisory practices.
Insider Trading
In accordance with Section 204A of the Investment Advisers Act of 1940, Adviser also
maintains and enforces written policies reasonably designed to prevent the misuse of
material non-public information by Adviser.
Privacy Statement
BWM is committed to safeguarding the confidential information of its clients and holds all
personal information provided to it in the strictest confidence. These records include all
personal information that BWM collects from its clients or receives from other firms in
connection with any of the financial services they provide. BWM also requires other firms
with whom they deal to restrict the use of client’s information.
Item 12 – Brokerage Practices
The Custodian and Brokers We Use
Investment Management Services
Clients must maintain assets in an account at a “qualified custodian,” generally a broker-
dealer or bank. We recommend that our clients use Charles Schwab & Co., Inc. (Schwab), a
registered broker-dealer, member SIPC, as the qualified custodian. We are independently
owned and operated and unaffiliated with Schwab. Schwab will hold client assets in a
brokerage account and buy and sell securities when we instruct them to.
While we recommend that clients use Schwab as custodian/broker, client must decide
whether to do so and open accounts with Schwab by entering into account agreements
directly with them. We will open accounts with Schwab on the client’s behalf and will notify
the client in writing of the custodian’s name, address, and the title of the account, promptly
when the account is opened and following any changes to this information. The accounts will
always be held in the name of the client and never in Blossom’s name. Even though clients
maintain accounts at Schwab, we can still use other brokers to execute trades for client
accounts (see Client Brokerage and Custody Costs, below).
How We Select Brokers/Custodians
We seek to recommend a custodian/broker who will hold client assets and execute
transactions on terms that are, overall, most advantageous when compared to other
available providers and their services. We consider a wide range of factors, including, among
others:
1. Combination of transaction execution services and asset custody services (generally
without a separate fee for custody)
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2. Capability to execute, clear, and settle trades (buy and sell securities for client
accounts)
3. Capability to facilitate transfers and payments to and from accounts (wire transfers,
check requests, bill payment, etc.)
4. Breadth of available investment products (stocks, bonds, exchange-traded funds
[ETFs], etc.)
5. Availability of investment research and tools that assist us in making investment
decisions
6. Quality of services
7. Competitiveness of the price of those services (commission rates, other fees, etc.) and
willingness to negotiate the prices
8. Reputation, financial strength, and stability
9. Prior service to Blossom and our other clients
10. Availability of other products and services that benefit us, as discussed below (see
Products and Services Available to Us From Schwab).
Client Brokerage and Custody Costs
For our clients’ accounts that Schwab maintains, Schwab generally does not charge
separately for custody services. However, Schwab receives compensation by charging
commissions or other fees on trades that it executes or that settle into clients’ Schwab
accounts. In addition to commissions, Schwab charges a flat dollar amount as a “prime
broker” or “trade away” fee for each trade that we have executed by a different broker-dealer,
but where the securities bought or the funds from the securities sold are deposited (settled)
into a client’s Schwab account. These fees are in addition to the commissions or other
compensation the client pays the executing broker-dealer. Because of this, in order to
minimize trading costs, we have Schwab execute most trades for client accounts. We have
determined that having Schwab execute most trades is consistent with our duty to seek “best
execution” of client trades. Best execution means the most favorable terms for a transaction
based on all relevant factors, including those listed above (see How We Select
Brokers/Custodians).
Products and Services Available to Us from Schwab
Schwab Advisor Services™ is Schwab’s business serving independent investment advisory
firms like us. They provide Blossom and our clients with access to its institutional brokerage,
trading, custody, reporting, and related services, many of which are not typically available to
Schwab retail customers. Schwab also makes available various support services. Some of
those services help us manage or administer our clients’ accounts; others help us manage
and grow our business. Schwab’s support services are generally available on an unsolicited
basis (we do not have to request them) and at no charge to us.
Following is a more detailed description of Schwab’s support services:
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Services That Benefit Our Clients
Schwab’s institutional brokerage services include access to a broad range of investment
products, execution of securities transactions, and custody of client assets. The investment
products available through Schwab include some to which we might not otherwise have
access or that would require a significantly higher minimum initial investment by our clients.
Schwab’s services described in this paragraph generally benefit our clients and their
accounts.
Services That May Not Directly Benefit Our Clients
Schwab also makes available to us other products and services that benefit us but may not
directly benefit our clients or their accounts. These products and services assist us in
managing and administering our clients’ accounts. They include investment research, both
Schwab’s own and that of third parties. We may use this research to service all or a
substantial number of our clients’ accounts, including accounts not maintained at Schwab. In
addition to investment research, Schwab also makes available software and other technology
that:
1. Provide access to client account data (such as duplicate trade confirmations and
account statements)
2. Facilitate trade execution and allocate aggregated trade orders for multiple client
accounts
3. Provide pricing and other market data
4. Facilitate payment of our fees from our clients’ accounts
5. Assist with back-office functions, recordkeeping, and client reporting
Services That Generally Benefit Only Us
Schwab also offers other services intended to help us manage and further develop our
business enterprise. These services include:
1. Subsidized pricing on Accredited Investment Fiduciary® (AIF®) Designation made
available to affiliated persons of Blossom
2. Educational conferences and events
3. Consulting on technology, compliance, legal, and business needs
4. Publications and conferences on practice management and business succession
5. Access to employee benefits providers, human capital consultants, and insurance
providers
Schwab provides some of these services itself. In other cases, it will arrange for third-party
vendors to provide the services to us. Schwab has also discounted or waived its fees for some
of these services or paid all or a part of a third party’s fees in the past and may do so again in
the future. Schwab may also provide us with other benefits, such as occasional business
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entertainment of our personnel.
Our Interest in Schwab’s Services
The availability of these services from Schwab benefits us because we do not have to produce
or purchase them. These services are not contingent upon us committing any specific amount
of business to Schwab in trading commissions. We believe that our selection of Schwab as
custodian and broker is in the best interests of our clients.
Brokerage for Client Referrals
Blossom does not receive client referrals from any broker-dealer or third party in exchange
for using that broker-dealer or third party.
Directed Brokerage
Blossom will not allow clients to direct us to use a specific broker-dealer to execute
transactions. Clients must use the broker-dealers that we recommend. Not all investment
advisers require their clients to trade through specific brokerage firms. By requiring clients
to use Schwab, Blossom believes we may be able to more effectively manage the client’s
portfolio, achieve favorable execution of client transactions, and lower the overall costs to
the portfolio. Client accounts will always be held in the name of the client and never in
Blossom’s name. Even though clients maintain accounts at Schwab, we can still use other
brokers to execute trades for client accounts.
Since we require most of our clients to maintain their accounts with Schwab, it is also
important for clients to consider and compare the significant differences between having
assets custodied at another broker-dealer, bank, or other custodian prior to opening an
account with us. Some of these differences include but are not limited to; total account costs,
trading freedom, transaction fees/commission rates, and security and technology services.
Blossom generally will not recommend a broker-dealer/custodian to individuals in existing
employer-sponsored plan accounts.
Aggregation with Client Orders
Blossom generally aggregates transactions in like securities among client accounts as well as
with accounts of Blossom and our personnel. Aggregation presents a conflict of interest as
we may have an incentive to allocate more favorable executions to our own accounts or the
accounts of our personnel. Our policies to address this conflict are as follows:
1. We disclose our aggregation policies in this brochure;
2. We will not aggregate transactions unless we believe that aggregation is consistent
with our duty to seek best execution (which includes the duty to seek best price) for
our clients. The trade also needs to be consistent with the terms of our investment
advisory agreement with each client that has an account included in the aggregation;
3. We will not favor any account over any other account. This includes accounts of
Blossom or any of our personnel. Each account in the aggregated order will
participate at the average share price for all of our transactions in a given security on
a given business day (per custodian). All accounts will pay their individual transaction
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costs;
4. Transactions in the same security placed throughout the trading day may be priced
differently for certain groups of accounts based on several factors, which may include
the following:
a. By portfolio manager/strategy - BWM’s portfolio managers place trades for
one or more of the firm’s strategies throughout each trading day and
generally allocate blocks of shares only for the strategy/s they are
responsible for managing (Note: portfolio managers trading for more than
one strategy aggregate shares in the same security at the same time among
all the strategies they manage). For example, Manager A may enter an order
for a block of shares and send the participating account allocations to each
custodian before Manager B places a trade in the same security later that day.
In this case, the shares of the same security traded by Manager B will receive
different pricing than those traded by Manager A, which may be better or
worse according to the markets at the time the order is executed. In addition,
at times, a portfolio manager may “work” a trade for a specific security
throughout the course of a day and then, in an effort to treat clients equally,
average the share price among all participating accounts after market close.
Irrespective of the above, all clients will be treated fairly and equally, and no
allocation will be made in a manner designed to benefit any account or group
of accounts.
5. Before entering an aggregated order, we will prepare a written statement (the
“Allocation Statement”) specifying the participating accounts and how we intend to
allocate the order among those accounts;
6. If the aggregated order is filled entirely, we will allocate shares among clients
according to the Allocation Statement; if the order is partially filled, we will generally
allocate it pro-rata according to the Allocation Statement. However, we may allocate
the order differently than specified in the Allocation Statement if all client accounts
receive fair and equitable treatment. Examples include but are not limited to:
a. When only a small percentage of the order is executed, with respect to
purchase allocations, allocations may be given to accounts high in cash;
b. With respect to sale allocations, allocations may be given to accounts low in
cash;
c. We may allocate shares to the account with the smallest order, or to the
smallest position, or to an account that is out of line with respect to security or
sector weightings, relative to other portfolios with similar mandates;
d. We may allocate to one account when that account has limitations in its
investment guidelines prohibiting it from purchasing other securities that we
expect to produce similar investment results and that can be purchased by
other accounts in the block;
e. If an account reaches an investment guideline limit and cannot participate in
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an allocation, we may reallocate shares to other accounts. For example, this
may be due to unforeseen changes in an account’s assets after an order is
placed;
In any case, we will explain the reasons for a different allocation in writing, which the
CCO must approve;
7. If an aggregated order is partially filled and we allocate it differently than the
Allocation Statement specifies, no participating account may purchase or sell the
security for a reasonable period following the execution of the block trade. This only
applies when the participating account sells or receives more shares than it would
have if the aggregated order had been completely filled;
8. Our books and records will separately reflect each aggregated order and the
securities held by, bought, and sold for each client account;
9. Funds and securities of clients participating in an aggregated order will be deposited
with one or more qualified custodians. Clients’ cash and securities will not be held
collectively any longer than is necessary to settle the trade on a delivery versus
payment basis. Following settlement, cash or securities held collectively for clients
will be delivered out to the qualified custodian as soon as practical;
10. We do not receive additional compensation or remuneration of any kind as a result
of aggregating orders; and
11. We will provide individual investment advice and treatment to each client’s account.
Item 13 – Review of Accounts
Review of Accounts
Investment Management Services
We manage client portfolios on a continuous basis and George A. Salter II, CEO and James E.
Salter, COO generally review each client’s investment account on at least an annual basis.
Accounts are reviewed in the context of each client's stated investment objectives and
guidelines. More frequent reviews may be triggered by material changes in variables such as
the client's individual circumstances, or the market, political or economic environment.
Meetings with clients to discuss investment accounts will be scheduled on a mutually agreed
upon basis. Triggering factors that stimulate the review of a client’s account during
interim annual periods include, but are not limited to, the client’s request for an additional
review and/or
the additional deposit of funds into the account.
Rebalancing
BWM offers periodic ‘rebalancing’ of client portfolios so that in the face of fluctuating market
prices, each client’s portfolio remains at what we deem to be a reasonable allocation suitable
with the client’s stated objective.
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Financial Planning Services
Clients that have contracted with the firm for financial planning services will be provided
with a review and update to their plan upon their request at our planning rate of $250 per
hour. BWM waives these fees for clients that have engaged us for Investment Management
Services with portfolios holding $1 million or more in assets under our management.
Retirement Plan Consulting Services
Retirement Plan Consulting clients receive reviews of their retirement plans by James Salter,
COO, George Salter, CEO, and Craig Braemer, Portfolio Manager, at least annually for the
duration of the service. Our firm also provides ongoing services where clients are met upon
their request to discuss updates to their plans, changes in their circumstances, etc., at a
frequency that is mutually agreed to between the advisor and the Plan. Retirement Plan
Consulting clients do not receive written or verbally updated reports regarding their plans
unless they choose to engage our firm for ongoing services.
Reports to Clients
Investment Management Services
Clients will receive monthly statements directly from their account custodian(s).
Additionally, Blossom provides Investment Management Services clients with a quarterly
report that provides rate of return for each investment account and a total portfolio rate of
return. These reports are posted to the client web portal provided by Advyzon.
Item 14 – Client Referrals and Other Compensation
Outside Referrals
BWM may refer clients to unaffiliated professionals for specific needs, such as insurance,
mortgage brokerage, real estate sales, and estate planning, legal, and/or tax/accounting
services. In turn, these professionals may refer clients to BWM for investment
management/financial planning needs. We do not have any agreements with individuals or
companies that we refer clients to, and we do not receive any compensation for these
referrals. However, it could be concluded that BWM is receiving an indirect economic benefit
from the arrangement, as the relationships are mutually beneficial. For example, there could
be an incentive for us to recommend services of firms who refer clients to BWM.
BWM only refers clients to professionals we believe are competent and qualified in their
field, but it is ultimately the client’s responsibility to evaluate the provider, and solely the
client’s decision whether to engage a recommended firm. Clients are under no obligation to
purchase any products or services through these professionals, and BWM has no control
over the services provided by another firm. Clients who choose to engage these professionals
will sign a separate agreement with the other firm. Fees charged by the other firm are
separate from and in addition to fees charged by BWM. BWM does not receive any portion
of fees paid to outside professionals.
If the client desires, BWM will work with these professionals or the client’s other advisors
(such as an accountant or attorney) to help ensure that the provider understands the client’s
financial plan/investments and to coordinate services for the client. BWM does not share
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information with an unaffiliated professional unless first authorized by the client.
Schwab Support Products and Services
We receive an economic benefit from Schwab 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 Schwab. These products and services, how they benefit us, and
the related conflicts of interest are described above (see Item 12 – Brokerage
Practices).We do not base particular investment advice, such as buying particular
securities for our clients, on the availability of Schwab’s products and services to us.
Item 15 – Custody
Blossom has limited custody of our clients’ funds or securities when the client authorizes us
to deduct our management fees directly from the client’s account. As previously disclosed in
Item 5 – Fees and Compensation, BWM directly debits advisory fees from client accounts.
As part of this billing process, the client's custodian is advised of the amount of the fee to be
deducted from that client's account. On at least a quarterly basis, the custodian is required
to send to the client a statement showing all transactions within the account during the
reporting period. Because the custodian does not calculate the amount of the fee to be
deducted, it is important for clients to carefully review their custodial statements to verify
the accuracy of the calculation, among other things. Clients should contact BWM directly if
they believe that there may be an error in their statement.
Blossom is also deemed to have custody of clients’ funds or securities when clients have
standing authorizations with their custodian to move money from a client’s account to a
third-party (“SLOA”) and under that SLOA authorize us to designate the amount or timing of
transfers with the custodian. The SEC has set forth a set of standards intended to protect
client assets in such situations, which we follow.
Item 16 – Investment Discretion
Discretionary Management
BWM generally receives discretionary authority from the client at the outset of an advisory
relationship to select the identity and amount of securities to be bought and sold. In all cases,
however, such discretion is to be exercised in a manner consistent with the stated
investment objectives for the particular client account. When selecting securities and
determining amounts, BWM observes the investment policies, limitations, and restrictions of
the clients for which it advises. For registered investment companies, BWM’s authority to
trade securities may also be limited by certain federal securities and tax laws that require
diversification of investments and favor the holding of investments once made. Investment
guidelines and restrictions must be provided to BWM in writing.
Non-Discretionary Management
For non-discretionary investment advisory services provided to participant-directed
retirement plans, BWM assists the retirement plan client in making decisions about the
selection, retention, removal, and addition of plan investment options to be made available
under the plan. The retirement plan client retains and exercises final decision-making
implementation (or rejection) of BWM's
authority and responsibility
for
the
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recommendations and advice.
Item 17 – Voting Client Securities
Proxy Voting
As a matter of firm policy and practice, BWM does not have any authority to, and does not
vote proxies on behalf of, advisory clients. Clients retain the responsibility for receiving and
voting proxies for any and all securities maintained in client portfolios.
ERISA
For accounts subject to ERISA, an authorized plan fiduciary other than BWM will retain proxy
voting authority. Our investment advisory agreement and/or the plan’s written documents
will evidence and outline this authority.
Mutual Funds
The investment adviser that manages the assets of a registered investment company (i.e.,
mutual fund) generally votes proxies issued on securities held by the mutual fund.
Class Actions
Blossom does not instruct or give advice to clients on whether or not to participate as a
member of class action lawsuits and will not automatically file claims on the client’s behalf.
However, if a client notifies us that they wish to participate in a class action, we will provide
the client with any transaction information pertaining to the client’s account needed for the
client to file a proof of claim in a class action.
Tender Offers
BWM sometimes provides advice to clients regarding tender offers associated with positions
held in client accounts. Furthermore, BWM generally communicates the firm's position.
Item 18 – Financial Information
Registered investment advisers are required in this Item to provide you with certain
financial information or disclosures about BWM’s financial condition. BWM has no financial
commitment that impairs its ability to meet contractual and fiduciary commitments to
clients and has not been the subject of a bankruptcy proceeding.
Under no circumstances do we require or solicit payment of fees in excess of $1,200 per
client more than six months in advance of services rendered. Therefore, we are not required
to include a financial statement.
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Part 2B of Form ADV: Brochure Supplements
Item 1 – Cover Page
Information Pertaining to:
George A. Salter II
James E. Salter
Craig Braemer
Blossom Wealth Management, LLC
PO Box 125
Alamo, CA 94507
Tel: (925) 946-9999
Fax: (877) 665-8765
www.blossomwm.com
March 26, 2026
This Brochure Supplement provides information about George A. Salter II, James E. Salter,
and Craig Braemer that supplements the Blossom Wealth Management brochure. You should
have received a copy of that Brochure. Please contact James E. Salter at (925) 833-9999 or
via email at james@blossomwm.com if you did not receive BWM’s Brochure or if you have
any questions about the contents of this supplement. Additional information about the above
named individuals is available on the SEC’s website at www.adviserinfo.sec.gov.
Description of Professional Designations Used in this Brochure Supplement*
1Accredited Investment Fiduciary
The Accredited Investment Fiduciary (“AIF®”) designation is issued by the Center for Fiduciary Studies.
To earn the designation, each AIF® candidate must complete either a web-based or a capstone program,
pass a final certification exam, and complete a minimum of 6 hours of continuing education per year.
AIF® designees must also sign and agree to abide by a code of ethics. More information regarding the
AIF is available at http://www.fi360.com/main/designations_aif.jsp.
2Chartered Financial Analyst
The Chartered Financial Analyst® (“CFA®”) designation is sponsored by the CFA Institute. To earn a CFA
charter, candidates must have four years of qualified investment work experience, become a member of
CFA Institute, pledge to adhere to the CFA Institute Code of Ethics and Standards of Professional
Conduct on an annual basis, apply for membership to a local CFA member society, and complete the CFA
Program. The CFA Program is organized into three levels, each culminating in a six-hour exam. The three
proctored course exams correspond to three 250-hour self-study levels. Completing the Program takes
most candidates between two and five years. More information regarding the CFA is available at
https://www.cfainstitute.org.
3CERTIFIED FINANCIAL PLANNERTM
Certain persons, as identified in this Supplement below, are certified for financial planning services in the
United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). Therefore, they may
refer to themselves as CERTIFIED FINANCIAL PLANNER™ professionals or CFP® professionals and may use
these and CFP Board’s other certification marks (the “CFP Board Certification Marks”). The CFP®
certification is voluntary. No federal or state law or regulation requires financial planners to hold the CFP®
certification. You may find more information about the CFP® certification at www.CFP.net.
CFP® professionals have met CFP Board’s high standards for education, examination, experience, and
ethics. To become a CFP® professional, an individual must fulfill the following requirements:
• Education – Earn a bachelor’s degree or higher from an accredited college or university
and complete CFP Board-approved coursework at a college or university through a CFP
Board Registered Program. The coursework covers the financial planning subject areas
CFP Board has determined are necessary for the competent and professional delivery of
financial planning services, as well as a comprehensive financial plan development
capstone course. A candidate may satisfy some of the coursework requirement through
other qualifying credentials. CFP Board implemented the bachelor’s degree or higher
requirement in 2007 and the financial planning development capstone course requirement
in March 2012. Therefore, a CFP® professional who first became certified before those
dates may not have earned a bachelor’s or higher degree or completed a financial planning
development capstone course.
• Examination – Pass the comprehensive CFP® Certification Examination. The examination is
designed to assess an individual’s ability to integrate and apply a broad base of financial
planning knowledge in the context of real-life financial planning situations.
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• Experience – Complete 6,000 hours of professional experience related to the personal
financial planning process, or 4,000 hours of apprenticeship experience that meets
additional requirements.
• Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP®
Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics
and Standards of Conduct (“Code and Standards”), which sets forth the ethical and
practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics
requirements to remain certified and maintain the right to continue to use the CFP Board
Certification Marks:
• Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a
commitment to CFP Board, as part of the certification, to act as a fiduciary, and therefore,
act in the best interests of the client, at all times when providing financial advice and
financial planning. CFP Board may sanction a CFP® professional who does not abide by this
commitment, but CFP Board does not guarantee a CFP® professional's services. A client
who seeks a similar commitment should obtain a written engagement that includes a
fiduciary obligation to the client.
• Continuing Education – Complete 30 hours of continuing education every two years to
maintain competence, demonstrate specified levels of knowledge, skills, and abilities, and
keep up with developments in financial planning. Two of the hours must address the Code
and Standards.
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George A. Salter II
Item 2 – Educational Background and Business Experience
George A. Salter II, Member, CEO – born 1974
Education:
● University of San Diego, School of Law, San Diego, CA, 2001, Juris Doctor
● Dominican University of California, San Rafael, CA, 1999, Master in Business
Administration – Pacific Basin Studies and Sustainable Management
● Dominican University of California, San Rafael, CA, 1997, Bachelor of Arts in Political
Science
Securities Examinations and Licenses:
● FINRA Series 7 – 04/02 (General Securities Representative Examination
● FINRA Series 66 – 06/02 (Investment Company and Variable Contract Products
Representative Examination)
● FINRA Series 79 – 11/12 (Investment Banking Representative)
Licensing:
● California State Insurance – Variable Contracts, Life, Accident, and Health. California
Insurance License Number 0D64714
Professional Designations:
●
3CERTIFIED FINANCIAL PLANNER™ CFP®
Business Background:
● Blossom Wealth Management, LLC, Alamo, CA – 06/09 to Present, CEO & Member
● Blossom Ventures, LLC, Alamo, CA – 01/12 to 12/20, Partner
● KW Securities Corporation, Larkspur, CA – 11/13 to 09/22, Registered
Representative
● Wingman Retirement, LLC, Alamo, CA – 01/15 to 12/15, Founding Member
● Instream Partners, Menlo Park, CA – 10/13 to 10/14, Registered Representative
● Fallbrook Capital Securities Corp., West Hills, CA – 06/11 to 10/13, Registered
Representative
● Dominican University of California, San Rafael, CA – 02/09 to 01/12, Adjunct Faculty
● Morgan Stanley Smith Barney, Walnut Creek, CA – 06/09 to 06/09, Registered
Representative
● Citigroup Global Markets, Inc., Walnut Creek, CA – 08/05 to 06/09, Financial
Advisor
● Merrill Lynch, Pierce, Fenner & Smith, Inc., Oakland, CA – 09/03 to 08/05, Financial
Advisor
Biography:
George’s education began when he earned a soccer scholarship to Dominican University of
California in San Rafael. First, George pursued his Bachelor of Arts in Political Science. He
then stayed at Dominican to study business, graduating with an MBA in International
Finance/Sustainable Development. Realizing how often legal issues arise in the business
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world, George completed his education at the University of San Diego, School of Law. He
earned his J.D. in December 2001. These graduate studies laid the foundation for the global
investment program that George runs today. Whether working for a gold mine in Ghana,
traveling extensively through Spain and Brazil, or learning about winegrowing in the
Rhinegau region of Germany, George was constantly aware of the interconnected global
economy. We believe that these experiences, combined with advanced research on
behavioral finance during law school, have given George a truly unique perspective on
financial planning and wealth migration.
George has been a financial advisor since February 2002. Over the years, he has assisted his
clients and his colleagues’ clients in creating and implementing complex estate and business
succession plans. He is a CERTIFIED FINANCIAL PLANNER™, CFP®.
Today, George helps business owners, corporate executives, and other individuals manage
their assets. Consistent with his sustainable background, George is an advisor who
incorporates triple bottom line investment principles during portfolio creation. He believes
that the companies able to compete in the 21st century will be conscious about how they
impact society and the environment in addition to potentially being profitable financially.
Outside the office, George is active with several non-profits and community organizations.
George previously was an adjunct faculty member at Dominican, teaching a personal finance
course. He sits on two Business Advisory Boards: the first at his alma mater and the second
at Benedictine College in Atchison, Kansas. In his free time, George is a soccer enthusiast,
inspired chef, and house project extraordinaire. He and his wife Nicole live in Alamo, CA with
their two sons, Heathcliff and Julian.
Community Commitments:
● Flight to Freedom Community event director (2012 – Present)
● Advisory Board for School of Business and International Studies at Dominican
University of California (2009 – 2015)
● Dominican University of California Business Association (DUCBA) speaker, organizer,
and contributor (2009 – 2015)
● Dominican University of California Athletics Booster Club Member (2010 – 2015)
● Mustang Soccer Assistant – Parent Volunteer (2009 – 2015)
Item 3 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal
or disciplinary events that would be material to your evaluation of each supervised person
providing investment advice. No information is applicable to this Item.
Item 4 – Other Business Activities
● George A. Salter II is a licensed insurance agent with the State of California. 1
hour/mo.
● George A. Salter II currently serves on the Business Advisory Board for Follr, Inc. 1
hour/mo.
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Item 5 – Additional Compensation
In addition to George Salter’s compensation from his regular salary and ownership of BWM,
he also receives commissions from the sale of insurance products, as described above in Item
4 – Other Business Activities.
Item 6 – Supervision
George A. Salter II, CEO, and James E. Salter, COO, are responsible for all supervision and
monitoring of investment advice offered to clients. George can be reached at 925-946-9999
and James can be reached at 925-833-9999.
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James E. Salter
Item 2 – Educational Background and Business Experience
James E. Salter, Member, COO, CCO – born 1978
Education:
● Dominican University of California, San Rafael, CA, 2002, Master in Business
Administration - Global Strategic Management
● Dominican University of California, San Rafael, CA, 2001, Bachelor of Arts in
Business – Concentration in International Business
Securities Examinations and Licenses:
● FINRA Series 7 – 12/06 (General Securities Representative Examination)
● FINRA Series 24 – 11/16 (General Securities Principal Examination)
● FINRA Series 66 – 03/07 (Investment Company and Variable Contract Products
Representative Examination)
● FINRA Series 79 – 03/12 (Investment Banking Representative)
Licensing:
● California State Insurance – Variable Contracts, Life, Accident, and Health. California
Insurance License Number 0F75024
Professional Designations:
●
1Accredited Investment Fiduciary® (AIF®)
Business Background:
● Blossom Wealth Management, LLC, Alamo, CA – 06/09 to Present, Member, Chief
Compliance Officer, and Chief Operating Officer
● Blossom Ventures, LLC, Alamo, CA – 01/12 to 12/20, Partner
● KW Securities Corporation, Larkspur, CA – 11/13 to 09/22, Registered
Representative
● Wingman Retirement, LLC, Alamo, CA – 01/15 to 12/15, Founding Member
● Instream Partners, Menlo Park, CA – 10/13 to 10/14, Registered Representative
● Fallbrook Capital Securities Corp., West Hills, CA – 06/11 to 10/13, Registered
Representative
● Dominican University of California, San Rafael, CA – 02/09 to 01/12, Adjunct Faculty
● Morgan Stanley Smith Barney, Walnut Creek, CA – 06/09 to 06/09, Registered
Representative
● Citigroup Global Markets, Inc., Walnut Creek, CA – 03/07 to 06/09, Financial
Advisor
Biography:
James joined the team in 2007 and has been a financial advisor since February 2002. Over
the years, he has assisted his clients and his colleagues’ clients to create and implement
complex estate and business succession plans. As a financial advisor, James is also an
Accredited Investment Fiduciary® (AIF®). Prior to becoming a financial advisor, he spent
seven years developing web-based businesses and working as a family wealth manager in
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Berkeley. He provides investment planning and asset management strategies for
institutions, trusts, endowments, corporate executives, and high-net-worth families.
James graduated Summa Cum Laude from Dominican University of California with a
Bachelor of Arts in Business Administration and a Concentration in International Business.
He also earned his MBA in Global Strategic Management with a focus on sustainable
development. While attending Dominican, James played on the Men’s basketball team in the
California Pacific Conference. In 2009, he was asked to return to Dominican as an adjunct
instructor in the business department. He previously taught a course titled, “General
Principles in Personal Finance.” In addition, James serves on the Alumni Board, where he
focuses on career development by arranging internships.
Originally from San Diego, James has lived in the Bay Area since 1997. He enjoys meeting
entrepreneurs and clean tech professionals to learn more about their businesses. On the
weekend, he can be found playing his guitar, snowboarding, cycling, trail running, scuba
diving, golfing, and planning adventure photography. Like his two older brothers, James is
an Eagle Scout who astounds his wife by tirelessly working on projects at their San Ramon
home. James and his wife Allison live in San Ramon, CA with their three children Isabella,
Evangeline and Sterling.
James is a passionate traveler. He has visited Argentina, Australia, Austria, The Bahamas,
Barbados, Bolivia, Brazil, the British Virginia Islands, Canada, Chile, China, Costa Rica,
Croatia, Cuba, Curacao, The Czech Republic, Denmark, Dominica, Egypt, Estonia, Fiji, Finland,
France, Germany, Greece, Guatemala, Hong Kong, Hungary, India, Italy, Jamaica, Kenya,
Liechtenstein, Malaysia, Malta, Mexico, The Netherlands, New Zealand, Nicaragua, Norway,
Panama, Paraguay, Peru, Poland, Portugal, Russia, Singapore, Slovakia, Spain, Sweden,
Switzerland, Tanzania, Thailand, Turkey, Uruguay, the United Kingdom, the U.S. Virgin
Islands, and Vatican City.
Community Commitments:
● Flight to Freedom Community event director (2012 – Present)
● Dominican University of California Business Association (DUCBA) speaker, organizer,
and contributor (2009 – 2015)
● Dominican University of California Athletics Booster Club Member (2010 – 2015)
Item 3 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal
or disciplinary events that would be material to your evaluation of each supervised person
providing investment advice. No information is applicable to this Item.
Item 4 – Other Business Activities
●
James E. Salter is a licensed insurance agent with the State of California. 5 hours/mo.
●
James E. Salter currently serves on the Business Advisory Board for Follr, Inc. 1
hour/mo.
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Item 5 – Additional Compensation
In addition to James Salter’s compensation from his regular salary and ownership of BWM,
he also receives commissions from the sale of insurance products, as described above in Item
4 – Other Business Activities.
Item 6 – Supervision
George A. Salter II, CEO, and James E. Salter, COO, are responsible for all supervision and
monitoring of investment advice offered to clients. George can be reached at 925-946-9999
and James can be reached at 925-833-9999.
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Craig Braemer
Item 2 – Educational Background and Business Experience
Craig Braemer, Portfolio Manager – born 1959
Education:
● Master in Financial Services from the Golden Gate University, 1990.
● California Polytechnic State University, San Luis Obispo, 1982 Bachelor in Business
Administration – Financial Management and Accounting.
Professional Designations:
●
●
2Chartered Financial Analyst®, CFA®, 1989.
3CERTIFIED FINANCIAL PLANNER™ CFP®.
Business Background:
● Blossom Wealth Management, LLC, Alamo, CA - 02/18 to Present, Portfolio Manager
● HighMark Capital Management, Union Bank, San Francisco, Senior Portfolio Manager,
Executive Director, 6/94 - 2/18.
Biography:
Craig's education began at California Polytechnic State University, San Luis Obispo. During
his five years of college, he received two degrees, one in Financial Management as a B.S. and
the other in Accounting from the Business School. He did this while playing soccer for three
years for the School’s Division Two soccer team. After graduating, he worked a couple of
years in the investment world at Merrill Lynch, but upon leaving Craig decided to improve
his educational background further and build a solid financial and investment foundation for
his future. While working at Franklin Templeton Investments, RWB Advisory Services and
Fisher Investments over the coming 8 years; Craig improved his educational foundation
during these eight years by starting and then completing his Master in Financial Services
from Golden Gate University, acquiring the CERTIFIED FINANCIAL PLANNER™ or CFP®
designation and completing the Chartered Financial Analyst designation or CFA. During a
number of these years, he was working on all three programs simultaneously. In addition to
the additional education background, these original four firms helped Craig build a
significant investment and financial planning base which has been very useful in his career
and in working with clients.
All of this work and education drove him to follow his passion further into the stock market
and investment analysis and he started working at a small investment management firm,
Fisher Investments, as an analyst. After six years, he joined a larger organization, Merus
Capital Management, a division of Bank of California to improve his analytical skills and
follow more specific industries. This firm, after several name changes, became HighMark
Capital Management, owned by Union Bank where he worked for almost 24 years. During
this time, he was a Research Analyst, Assistant Fund Manager - HighMark Growth Fund,
Portfolio Fund Manager - HighMark Growth Fund, Director of Investments, Senior Portfolio
Manager, and Investment Executive. During part of these 24 years, he also ran an investment
strategy called Relative Dividend Yield for both institutional and high net worth clients of
HighMark Capital Management.
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During the second half of his time at HighMark Capital Management he participated on the
firm’s Asset Allocation Committee (AAC) which was the guiding force overseeing the Firm’s
asset allocation for all of their clients. He was a voting member on this committee throughout
his time on the Committee. This combined with his role as Director of Investments led him
to present to groups of clients and participate in other group events representing HighMark.
In recent years, Craig focused primarily on managing individual client portfolios and
providing financial planning advice directly with clients ranging from retirees, trusts,
corporate executives, foundations, pension plans while he worked at HighMark Capital
Management. He also continued his research efforts by following two sectors of the S&P 500
Index for HighMark’s internal equity research team. These two sectors were Utilities and Real
Estate Investment Trusts – REITs. His research would be used in building all client individual
stock portfolios in these two sectors by the other 20 portfolio managers. Finally, Craig built
one of HighMark’s first Socially Responsible Investment portfolios with client’s and managed
that client’s money directly. Outside the office, Craig is very active with one non-profit Group,
BetterInvesting.org, and helps in several other community organizations.
Item 3 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal
or disciplinary events that would be material to your evaluation of each supervised person
providing investment advice. No information is applicable to this Item.
Item 4 – Other Business Activities
Craig has been an active participant, and a Director, in a non-profit education group called
BetterInvesting for over 25 years. He works at the local level by visiting local investment
clubs and teaching at local educational events. Since 2015, he has been invited to present and
participate at the organization’s annual BetterInvesting National Conference (BINC) which
is held in different locations around the U.S. This three-day event brings together hundreds
of like-minded individuals to learn and discuss investments and stock ideas.
Item 5 – Additional Compensation
Craig E. Braemer does not receive any additional compensation from third parties for
providing investment advice.
Item 6 – Supervision
George A. Salter II, CEO, and James E. Salter, COO, are responsible for all supervision and
formulation and monitoring of investment advice offered to clients. George can be reached
at 925.946.9999 and James can be reached at 925-833-9999.
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Rev. February 2021
PRIVACY INFORMATION
WHAT DOES BLOSSOM WEALTH MANAGEMENT LLC (“BLOSSOM”)
DO WITH YOUR PERSONAL INFORMATION?
FACTS
Why?
Financial companies choose how they share your personal information.
Federal law gives consumers the right to limit some but not all sharing.
Federal law also requires us to tell you how we collect, share, and protect
your personal information. Please read this notice carefully to understand
what we do.
What?
The types of personal information we collect and share depend on the
product or service you have with us. This information can include:
Investment experience and risk tolerance
● Social Security number and income
● Assets and account balances
●
When you are no longer our customer, we continue to share your
information as described in this notice.
How?
All financial companies need to share customers’ personal information to
run their everyday business. In the section below, we list the reasons
financial companies can share their customers’ personal information; the
reasons Blossom chooses to share; and whether you can limit this sharing.
Reasons we can share your personal
information
Does Blossom
share?
Can you limit
this sharing?
YES
NO
For our everyday business purposes -
as permitted by law
YES
NO
For our marketing purposes - to offer our products and
services to you
For joint marketing with other financial companies
NO
We Don’t Share
NO
We Don’t Share
For our affiliates’ everyday business purposes -
information about your transactions and experiences
NO
We Don’t Share
For our affiliates’ everyday business purposes -
information about your creditworthiness
For nonaffiliates to market to you
NO
We Don’t Share
Questions? Call 925-833-9999 or go to blossomwm.com
Page 2
WHO WE ARE
Who is providing this notice?
Blossom Wealth Management, LLC (“Blossom”)
WHAT WE DO
How does Blossom protect
my personal information?
To protect your personal information from unauthorized
access and use, we use security measures that comply with
federal law. These measures include computer safeguards
and secured files and buildings.
We collect your personal information, for example, when you
How does Blossom collect my
personal information?
seek advice about your investments
tell us about your investment or retirement portfolio
tell us about your investment or retirement earnings
●
● enter into an investment advisory contract
●
●
● give us your contact information
We also collect your personal information from other
companies.
Why can’t I limit all sharing?
Federal law gives you the right to limit only:
●
sharing for affiliates’ everyday business purposes -
information about your creditworthiness
sharing for nonaffiliates to market to you
● affiliates from using your information to market to you
●
State laws and individual companies may give you additional
rights to limit sharing.
DEFINITIONS
Affiliates
Companies related by common ownership or control. They
can be financial and nonfinancial companies.
● Blossom has no affiliates.
Nonaffiliates
Companies not related by common ownership or control.
They can be financial and non-financial companies.
● Blossom does not share with nonaffiliates so they can
market to you.
Joint Marketing
A formal agreement between nonaffiliated financial
companies that together market financial products or
services to you.
● Blossom doesn’t jointly market.