View Document Text
Item 1: Cover Page
Part 2A of Form ADV: Firm Brochure
March 2025
CRD# 169832
www.bwam.net
16150 Main Circle Drive, Suite 210
Chesterfield, MO 63017
Firm Contact:
Robert Balice
Chief Compliance Officer
This brochure provides information about the qualifications and business practices of Bridgewater
Asset Management LLC. If you have any questions about the contents of this brochure, please contact
us by telephone at (636) 536-9936. The information in this brochure has not been approved or
verified by the United States Securities and Exchange Commission or by any State Securities
Authority.
Additional information about Bridgewater Asset Management LLC also is available on the SEC’s
website at www.adviserinfo.sec.gov.
Please note that the use of the term “registered investment adviser” and description of Bridgewater
Asset Management LLC and/or our associates as “registered” does not imply a certain level of skill or
training. You are encouraged to review this Brochure and Brochure Supplements for our firm’s
associates who advise you for more information on the qualifications of our firm and our employees.
Item 2: Material Changes
Bridgewater Asset Management LLC is required to advise you of any material changes to our Firm
Brochure (“Brochure”) from our last annual update, identify those changes on the cover page of our
Brochure or on the page immediately following the cover page, or in a separate communication
accompanying our Brochure.
Since the last annual amendment filed on 02/20/2024, the following changes have been made:
Our firm has updated our fee schedule to include additional breakpoints for our Asset Management
and Wrap Asset Management services.
ADV Part 2A – Firm Brochure
Page 2
Bridgewater Asset Management, LLC
Item 3: Table of Contents
Item 1: Cover Page .................................................................................................................................................................. 1
Item 2: Material Changes ...................................................................................................................................................... 2
Item 3: Table of Contents ..................................................................................................................................................... 3
Item 4: Advisory Business.................................................................................................................................................... 4
Item 5: Fees & Compensation ............................................................................................................................................. 8
Item 6: Performance-Based Fees & Side-By-Side Management ......................................................................... 12
Item 7: Types of Clients & Account Requirements .................................................................................................. 12
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ................................................................. 13
Item 9: Disciplinary Information..................................................................................................................................... 15
Item 10: Other Financial Industry Activities & Affiliations .................................................................................. 15
Item 11: Code of Ethics, Participation or Interest in ............................................................................................... 16
Client Transactions & Personal Trading ...................................................................................................................... 16
Item 12: Brokerage Practices ........................................................................................................................................... 17
Item 13: Review of Accounts or Financial Plans ....................................................................................................... 21
Item 14: Client Referrals & Other Compensation ..................................................................................................... 21
Item 15: Custody .................................................................................................................................................................... 22
Item 16: Investment Discretion ....................................................................................................................................... 22
Item 17: Voting Client Securities ..................................................................................................................................... 22
Item 18: Financial Information ........................................................................................................................................ 23
ADV Part 2A – Firm Brochure
Page 3
Bridgewater Asset Management, LLC
Item 4: Advisory Business
We are dedicated to providing individuals and other types of clients with a wide array of investment
advisory services. Our firm is a limited liability company formed in the State of Missouri. Our firm
has been in business as an investment adviser since 2014. Effective July 1, 2022, Bridgewater Asset
Management LLC is a wholly-owned subsidiary of Bridgewater HoldCo, LLC, which is in turn majority
owned by Bridgewater Legacy Partners, LLC. The Principal Officers of these entities are Robert Balice
and Thomas Ross.
Description of the Types of Advisory Services We Offer.
Asset Management:
We emphasize continuous and regular account supervision. As part of our asset management service,
we create a portfolio, consisting of individual stocks or bonds, exchange traded funds (“ETFs”), options,
mutual funds and other public securities or investments. The client’s individual investment strategy is
tailored to their specific needs and may include some or all of the previously mentioned securities. Each
portfolio will be initially designed to meet a particular investment goal, which we determine to be in the
client’s best interest. Once the appropriate portfolio has been determined, we review the portfolio at
least quarterly and if necessary, rebalance the portfolio based upon the client’s individual needs, stated
goals and objectives. Each client has the opportunity to place reasonable restrictions on the types of
investments to be held in the portfolio in their advisory agreement.
Financial Planning & Consulting:
We provide a variety of financial planning or consulting services to individuals and high net worth
individuals; trusts, estates or charitable organizations; and pension and profit sharing plans
regarding the management of their financial resources based upon an analysis of the client’s current
situation, goals, and objectives. 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 may encompass one or more of the following areas:
• Cash Flow & Debt Management – This involves advice with respect to cash accounts,
financial obligations, and cash management.
• Risk Management & Insurance Planning – This includes risk management associated
with advisory recommendations based on the combination of insurance types that best
meet a client’s specific needs, e.g. life, health, disability, and long-term care, and others as
appropriate.
•
Investment Planning – This involves advice with respect to asset selection and
allocation, as well as investment income accumulation techniques. Evaluations are made
of existing and, when applicable, potential investments in terms of their economic and tax
characteristics as well as their suitability for meeting client’s objectives. Tax
consequences and their implications are identified and evaluated in general terms.
• Retirement Planning – This involves advice with respect to alternatives and techniques
for accumulating wealth for retirement income or advice relative to appropriate
ADV Part 2A – Firm Brochure
Page 4
Bridgewater Asset Management, LLC
distributions of assets following retirement. Tax implications and consequences are
identified and evaluated in general terms.
• Education Planning – This includes alternatives and strategies with respect to the
complete or partial funding of college or other post-secondary education experience. Tax
consequences and their implications are identified and evaluated in general terms.
• Estate Planning – This service involves advice with respect to property ownership,
distribution strategies, estate tax reduction, and tax payment techniques. It involves a
discussion of gifts, trusts, etc. and the disposition of business interests. Tax consequences
and their implications are identified and evaluated. At the request of the Client, our firm
will engage the client’s chosen personal estate attorney or planner, with regard to
advising the wealth management of the estate planning.
• Tax Planning – Tax planning is referred to the client’s chosen personal tax advisor. Our
firm may offer advice as to how tax laws may affect various financial decisions, e.g.
acquisitions, pension strategy, investing in new opportunities or consolidation of existing
investments, and individual taxation issues, among others.
• Business Succession Planning – This includes alternatives and strategies with respect
to continuity or disposition of the business upon the business owners’ retirement, death,
disability, or decision to sell. Tax implications and consequences are identified and
evaluated.
• Consolidation of Finances – As a result of performing some or all of the services listed
in points 1 through 8 above, our firm may be able to recommend strategies or methods
for consolidating the client’s financial situation in order for the client to manage their
financial situation more easily and to obtain efficiency, cost savings, and diversification.
Our written financial plans or financial consultations rendered to clients usually include
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. It should also be noted that we refer clients to an
accountant, attorney or other specialist, as necessary for non-advisory related services. For written
financial planning engagements, we provide our clients with a written summary of their financial
situation, observations, and recommendations. For financial consulting engagements, we usually do
not provide our clients with a written summary of our observations and recommendations as the
process is less formal than our planning service unless requested to do so. Plans or consultations are
completed within six (6) months of the client signing a contract with us, assuming that all the
information and documents we request from the client are provided to us promptly. Implementation
of the recommendations will be at the discretion of the client.
We are required to disclose to our financial planning clients that a conflict of interest exists between
us and our clients. The client is under no obligation to act upon the investment adviser’s
recommendation. If the client elects to act on our recommendations, the client is under no obligation
to effect the transaction through us. Implementation of the recommendations will be at the discretion
of the client.
ADV Part 2A – Firm Brochure
Page 5
Bridgewater Asset Management, LLC
Pension Consulting:
We provide pension consulting services to employer plan sponsors on a one-time or ongoing basis.
Pension consulting services consist of assisting employer plan sponsors in establishing, monitoring
and reviewing their company's participant-directed retirement plan. As the needs of the plan sponsor
dictate, areas of advising could include: investment options, plan structure and participant education.
All pension consulting services shall be in compliance with the applicable state law(s) regulating
pension consulting services. This applies to client accounts that are pension 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 we accept appointments to provide
our services to such accounts, we acknowledge that we are a fiduciary within the meaning of Section
3(21) of ERISA (but only with respect to the provision of services described in section 1 of the
Pension Consulting Agreement).
LPL Financial Sponsored Advisory Programs:
Our firm may provide advisory services through certain programs sponsored by LPL Financial
(“LPL”), a registered investment adviser and broker-dealer. Below is a brief description of each LPL
advisory program available to our firm. For more information regarding the LPL programs, including
more information on the advisory services and fees that apply, the types of investments available in
the programs and the conflicts of interest presented by the programs please see the LPL Financial
Form ADV Part 2 or the applicable program’s Appendix 1 (wrap fee program brochure) and the
applicable client agreement.
Optimum Market Portfolios Program (OMP)
OMP offers clients the ability to participate in a professionally managed asset allocation program
using Optimum Funds Class I shares. Under OMP, client will authorize LPL on a discretionary basis
to purchase and sell Optimum Funds pursuant to investment objectives chosen by the client. Advisor
will assist the client in determining the suitability of OMP for the client and assist the client in setting
an appropriate investment objective. Advisor will have discretion to select a mutual fund asset
allocation portfolio designed by LPL consistent with the client’s investment objective. LPL will have
discretion to purchase and sell Optimum Funds pursuant to the portfolio selected for the client. LPL
will also have authority to rebalance the account.
A minimum account value of $15,000 is required for OMP.
Personal Wealth Portfolios Program (PWP)
PWP offers clients an asset management account using asset allocation model portfolios designed by
LPL. Advisor will have discretion for selecting the asset allocation model portfolio based on client’s
investment objective. Advisor will also have discretion for selecting third party money managers
(PWP Advisors) or mutual funds within each asset class of the model portfolio. LPL will act as the
overlay portfolio manager on all PWP accounts and will be authorized to purchase and sell on a
discretionary basis mutual funds and equity and fixed income securities.
A minimum account value of $250,000 is required for PWP.
ADV Part 2A – Firm Brochure
Page 6
Bridgewater Asset Management, LLC
Model Wealth Portfolios Program (MWP)
MWP offers clients a professionally managed mutual fund asset allocation program. We will obtain
the necessary financial data from the client, assist the client in determining the suitability of the MWP
program and assist the client in setting an appropriate investment objective. The Advisor will initiate
the steps necessary to open an MWP account and have discretion to select a model portfolio designed
by LPL’s Research Department consistent with the client’s stated investment objective. LPL’s
Research Department is responsible for selecting the mutual funds within a model portfolio and for
making changes to the mutual funds selected.
The client will authorize LPL to act on a discretionary basis to purchase and sell mutual funds
(including in certain circumstances exchange traded funds) and to liquidate previously purchased
securities. The client will also authorize LPL to effect rebalancing for MWP accounts.
In the future, the MWP program may make available model portfolios designed by strategists other
than LPL’s Research Department. If such models are made available, Advisor will have discretion to
choose among the available models designed by LPL and outside strategists.
A minimum account value of $50,000 is required for MWP.
Manager Access Select Program
Manager Access Select provides clients access to the investment advisory services of professional
portfolio management firms for the individual management of client accounts. Advisor will assist
client in identifying a third party portfolio manager (Portfolio Manager) from a list of Portfolio
Managers made available by LPL. The Portfolio Manager manages client’s assets on a discretionary
basis. Advisor will provide initial and ongoing assistance regarding the Portfolio Manager selection
process.
A minimum account value of $100,000 is required for Manager Access Select, however, in certain
instances, the minimum account size may be lower or higher.
Tailoring of Advisory Services
We offer individualized investment advice to clients utilizing our Asset Management service.
Additionally, we offer general investment advice to clients utilizing our Financial Planning &
Consulting and Pension Consulting, services.
Each client has the opportunity to place reasonable restrictions on the types of investments to be held
in the portfolio. Restrictions on investments in certain securities or types of securities may not be
possible due to the level of difficulty this would entail in managing the account. Restrictions would
be limited to our Asset Management service. We do not manage assets through our other services.
Participation in Wrap Fee Programs
We offer wrap fee programs as further described in Part 2A, Appendix 1 (the “Wrap Fee Program
Brochure”) of our Brochure. Our wrap fee and non-wrap fee accounts are managed on an
individualized basis according to the client’s investment objectives, financial goals, risk tolerance, etc.
We do not manage wrap fee accounts in a different fashion than non-wrap fee accounts. As further
described in our Wrap Fee Program Brochure, we receive a portion of the wrap fee for our services.
ADV Part 2A – Firm Brochure
Page 7
Bridgewater Asset Management, LLC
Regulatory Assets Under Management
As of December 31, 2024, we manage $298,102,300 on a discretionary basis and $348,893 on a non-
discretionary basis.
Item 5: Fees & Compensation
We are required to disclose that lower fees for comparable services may be available from other
sources. Please note that unless a client has received the firm’s disclosure brochure at least 48 hours
prior to signing the investment advisory contract, the investment advisory contract may be
terminated by the client within five (5) business days of signing the contract without incurring any
advisory fees.
How We Are Compensated for Our Advisory Services
Assets Under Management is defined as the accumulated total of all accounts held within a client
household. Other non-advisory assets may be included by the advisor at their discretion.
Asset Management:
Assets Under Management
$0 to $250,000
$250,000 to $499,999
$500,000 to $999,999
$1,000,000 to $1,999,999
$2,000,000 to $3,999,999
$4,000,000 to $7,999,999
$8,000,000 to $15,999,999
Over $16,000,000
Maximum Annual Percentage of
Assets Charge
1.50%
1.25%
1.00%
0.90%
0.85%
0.80%
0.75%
0.70%
When establishing the asset charge for a specific account, the advisor will consider various factors
which include the size of the account, trading frequency and transactions cost imposed. There are
instances when the advisor will assess a lower asset charge to offset the cost of transaction charges
or the selection of higher share classes which do not assess a transaction charge. The goal being to
establish a total cost that is equivalent or lower than the asset management schedule above.
Our fees may be negotiable. Our firm bills on cash unless indicated otherwise in writing. Fees will be
automatically deducted from your managed account. In rare cases, we will agree to direct bill clients.
Clients custodied with LPL Financial (“LPL”):
Our firm’s fees are billed on a pro-rata annualized basis quarterly in advance based on the
value of your account on the last day of the previous quarter. Our fees may be negotiable.
ADV Part 2A – Firm Brochure
Page 8
Bridgewater Asset Management, LLC
Fees will be automatically deducted from your managed account*. LPL will make quarterly
adjustments for deposits and withdrawals in client accounts. As part of this process, you
understand and acknowledge the following:
a) LPL Financial as the custodian sends statements at least quarterly to Clients showing
all disbursements for their account, including the amount of the advisory fees paid to
our firm;
b) The Client has provided written authorization permitting fees to be directly paid by
these terms;
c) LPL Financial calculates the advisory fees and deducts them from the Client’s account.
Clients custodied with Charles Schwab & Co., Inc. (“Schwab”):
Our firm’s fees are billed on a pro-rata basis quarterly in arrears based on the value of the
account(s) on the market value of the account at the end of the quarter. Adjustments will be
made for deposits and withdrawals during the quarter. As part of this process, you
understand and acknowledge the following:
a) The client’s independent custodian sends statements at least quarterly showing the
market values for each security included in the Assets and all account disbursements,
including the amount of the advisory fees paid to our firm;
b) Clients will provide authorization permitting our firm to be directly paid by these terms.
Our firm will send an invoice directly to the custodian; and
c) If our firm sends a copy of our invoice to the client, a legend urging the comparison of
information provided in our statement with those from the qualified custodian will be
included.
We will review your annual percentage of assets charge at least annually to determine consistency
with the fee schedule shown above.
If you wish to terminate our services, you need to contact us in writing and state that you wish to
cancel the Asset Management service. Upon receipt of your letter of termination, we will proceed to
close out your account and process a pro-rata refund of unearned advisory fees, if applicable. For the
purposes of calculating refunds, all work performed by us up to the point of termination shall be
calculated by dividing the advisory fee by the number of the days of the quarter. We’ll multiply that
rate by the number of days before you terminate our service to determine the amount of your refund.
Financial Planning & Consulting:
We charge on an hourly or flat fee basis for financial planning and consulting services. The total
estimated fee, as well as the ultimate fee that we charge you, is based on the scope and complexity of
our engagement with you. Our hourly fees are $250 and our flat fees range from $1,000 to $10,000.
We require a retainer of fifty-percent (50%) of the ultimate financial planning or consulting fee with
the remainder of the fee directly billed to you and due to us within thirty (30) days of your financial
plan being delivered or consultation rendered to you. In all cases, we will not require a retainer
exceeding $1,200 when services cannot be rendered within 6 (six) months.
Hourly Fees: Our hourly fees are negotiable, and will not exceed $500. Projects spanning more than
three months will be billed quarterly. The items addressed in a modular plan or general consulting
ADV Part 2A – Firm Brochure
Page 9
Bridgewater Asset Management, LLC
services may include one or more of the services listed above. The amount of time spent will depend
on the complexity of the request and all services will be completed within six months. The total
number of hours will be estimated prior to the engagement and will be specified in our firm’s
Financial Planning & Consulting Agreement for hourly services. The client will be invoiced directly
for hourly fees.
• Example: A client meets with our firm to discuss basic financial consulting issues and seeks
general investment advice relating to broad issues such as retirement planning and education
planning. The meeting lasts 2 hours and follow up research takes 2 hours. At $350 per hour,
the client would be charged a $700 retainer at the time of the initial meeting (350 x 2 hours)
and an additional $700 upon completion of the engagement ($350 x 2 hours). Our firm will
perform all financial consulting work before six months expire.
Fixed Fees: Our fixed fees are negotiable, and will not exceed $3000. Depending on circumstances,
fees for Financial Planning & Consulting Services are offered to clients for small consulting projects
or as part of an annual retainer program. Such services include any combination of the above-listed
services, periodic reviews, revisions/updates to the financial plan, and day-to- day consulting as
required. Fixed fees may require 50% as the initial retainer and the balance due upon completion.
• Example: A client with limited financial investing history and modest assets who contracts
with our firm for a single service listed above would be charged a fee of $250, because of
limited document review and fewer consulting options. A client with maximum complexity
who contracted Bridgewater Asset Management LLC for all services listed above which may
require forty or more hours of Adviser’s time would be charged an annual service fee of
$3,000. Adviser will outline a six-month service plan and charge client 50% as an initial
retainer. Adviser’s services will be completed within six months
Either party may terminate the Financial Planning & Consulting service at any time by providing
written notice. For purposes of calculating refunds, all work performed by us up to the point of
termination shall be calculated at our hourly fee currently in effect. You will receive a pro-rata refund
of unearned fees based on the time and effort expended by our firm and Planner.
Pension Consulting:
We charge on an hourly or flat fee basis for pension consulting services. The total estimated fee, as
well as the ultimate fee that we charge you, is based on the scope and complexity of our engagement
with you. Our hourly fees are $250 and our flat fees range from $1,000 to $10,000. Flat fees will
charged annually for ongoing pension consulting services.
The fee-paying arrangements for pension consulting service will be determined on a case-by-case
basis and will be detailed in the signed Pension Consulting Agreement. The client will be invoiced
directly for the fees.
The Pension Consulting service may be terminated by written notice by either party to the other
party. In the event this service is terminated, we will refund the unearned portion of our advisory fee
to you. For purposes of calculating refunds, all work performed by us up to the point of termination
shall be calculated at our hourly fee currently in effect. The amount will be refunded to your account.
LPL Financial Sponsored Advisory Programs:
ADV Part 2A – Firm Brochure
Page 10
Bridgewater Asset Management, LLC
The maximum fees for the LPL sponsored advisory programs are as follows:
LPL Sponsored Advisory Program
(a) Optimum Market Portfolios Program (OMP)
(b) Personal Wealth Portfolios Program (PWP)
(c) Model Wealth Portfolios Program (MWP)
(d) Manager Access Select Program (MAS)
Annual Percentage of Assets Charge
1.50%
2.00%
2.00%
2.50%*
*Similar services may be secured from other advisors for less expense.
The fees for LPL’s Financial Sponsored Advisory Programs are billed on a pro-rata annualized basis
quarterly in advance based on the value of your account on the last day of the previous quarter. LPL
serves as program sponsor, investment adviser and broker-dealer for the LPL advisory programs. Our
firm and LPL may share in the account fee and other fees associated with program accounts.
Our firm’s fees are billed on a pro-rata annualized basis quarterly in advance based on the value of
your account on the last day of the previous quarter. Management fees will be deducted from the
client’s managed account, upon a signed Account Application Form. The ultimate management fee is
indicated on the Account Application Form. Our firm does not have the authority to instruct LPL
Financial to change or deduct fees without written client consent. LPL Financial sends a quarterly
statement showing all fees deducted from the clients accounts.
Conflicts of Interest
Transactions in LPL advisory program accounts are effected through LPL as the executing broker-
dealer. Advisor receives compensation as a result of a client’s participation in an LPL program.
Depending on, among other things, the size of the account, changes in its value over time, the ability
to negotiate fees or commissions, and the number of transactions, the amount of this compensation
may be more or less than what the Advisor would receive if the client participated in other programs,
whether through LPL or another sponsor, or paid separately for investment advice, brokerage and
other services. In order to mitigate this conflict of interest, we will fulfill our fiduciary duty by acting
in the client’s best interest.
Other Types of Fees & Expenses
Non-Wrap fee Clients will incur transaction charges for trades executed in their accounts. These
transaction fees are separate from our fees and will be disclosed by the firm that the trades are
executed through. Charles Schwab & Co., Inc. (“Schwab”) does not charge transaction fees for U.S.
listed equities and exchange traded funds. LPL Financial offers a trading platform with select
exchange traded funds (“ETFs”) that do not charge transaction fees. The no-transaction-fee ETF
trading platform is available to clients participating in LPL Financial’s Strategic Wealth Management
(“SWM”) and Strategic Asset Management (“SAM”) programs. Clients will be subject to transaction
fees charged by LPL Financial for ETFs not included in LPL Financial’s platform and for other types
of securities. The limited number of ETFs available on LPL Financial’s no-transaction fee platform
may have higher overall expenses than other types of securities and ETFs not included in the
platform. Other major custodians have eliminated transaction fees for all ETFs and U.S. listed equities,
so clients may pay more for investing in the same securities at LPL Financial.
ADV Part 2A – Firm Brochure
Page 11
Bridgewater Asset Management, LLC
Also, clients will pay the following separately incurred expenses, which we do not receive any part
of: charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be
disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses).
Wrap fee clients will receive our Form ADV, Part 2A, Appendix 1 (the “Wrap Fee Program Brochure”).
Wrap fee clients will not incur transaction costs for trades. More information about this is disclosed
in our separate Wrap Fee Program Brochure.
Commissionable Securities Sales
In order to sell securities for a commission, our supervised persons are registered representatives of
LPL, member FINRA/SIPC. Our supervised persons may accept compensation for the sale of
securities or other investment products, including distribution or service (“trail”) fees from the sale
of mutual funds. You should be aware that the practice of accepting commissions for the sale of
securities:
1. Presents a conflict of interest and gives our firm and/or our supervised persons an incentive to
recommend investment products based on the compensation received, rather than on your
needs. We address commissionable sales conflicts that arise:
a. when explaining to clients that commissionable securities sales creates an incentive to
recommend products based on the compensation we and/or our supervised persons may
earn;
b. when recommending commissionable mutual funds, explaining that “no-load” funds are
also available.
2. In no way prohibits you from purchasing investment products recommended by us through other
brokers or agents which are not affiliated with us. As a fiduciary, we put our client’s interests
ahead of our own.
Termination & Refunds
In the event that you wish to terminate our services, we will refund the unearned portion of our
advisory fee to you. You need to contact us in writing and state that you wish to terminate our
services. Upon receipt of your letter of termination, we will proceed to close out your account and
process a pro-rata refund of unearned advisory fees.
Item 6: Performance-Based Fees & Side-By-Side Management
Our firm does not charge performance-based fees.
Item 7: Types of Clients & Account Requirements
We have the following types of clients:
•
Individuals and High Net Worth Individuals;
ADV Part 2A – Firm Brochure
Page 12
Bridgewater Asset Management, LLC
• Trusts, Estates or Charitable Organizations; and
• Pension and Profit Sharing Plans.
Our requirements for opening and maintaining accounts or otherwise engaging us:
• We require a minimum household balance of $100,000 for our Asset Management service.
This minimum account balance requirement may be negotiable.
• We charge a minimum fee of $1,000 for Financial Planning & Consulting and Pension
Consulting.
• A minimum account value of $15,000 is required for Optimum Market Portfolios Program
(OMP).
• A minimum account value of $250,000 is required for Personal Wealth Portfolios Program
(PWP).
• A minimum account value of $50,000 is required for Model Wealth Portfolios Program
(MWP).
• A minimum account value of $100,000 is required for Manager Access Select, however, in
certain instances, the minimum account size may be lower or higher.
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
Methods of Analysis
We use the following methods of analysis in formulating our investment advice and/or managing
client assets:
Charting. In this type of technical analysis, we review charts of market and security activity in an
attempt to identify when the market is moving up or down and to predict when how long the trend
may last and when that trend might reverse.
Fundamental Analysis. We attempt to measure the intrinsic value of a security by looking at
economic and financial factors (including the overall economy, industry conditions, and the financial
condition and management of the company itself) to determine if the company is underpriced
(indicating it may be a good time to buy) or overpriced (indicating it may be time to sell).
Fundamental analysis does not attempt to anticipate market movements. This presents a potential
risk, as the price of a security can move up or down along with the overall market regardless of the
economic and financial factors considered in evaluating the stock.
Technical Analysis. We analyze past market movements and apply that analysis to the present in an
attempt to recognize recurring patterns of investor behavior and potentially predict future price
movement. Technical analysis does not consider the underlying financial condition of a company.
This presents a risk in that a poorly-managed or financially unsound company may underperform
regardless of market movement.
Cyclical Analysis. In this type of technical analysis, we measure the movements of a particular stock
against the overall market in an attempt to predict the price movement of the security.
Investment Strategies We Use:
ADV Part 2A – Firm Brochure
Page 13
Bridgewater Asset Management, LLC
We use the following strategies in managing client accounts, provided that such strategies are
appropriate to the needs of the client and consistent with the client's investment objectives, risk
tolerance, and time horizons, among other considerations.
Strategic Asset Allocation. The Strategic asset allocation models are geared more for long term
growth, but still have variations from the benchmark indexes. Variations will be driven by our long-
term views on the market and our assessment of how the market is assessing potential downside
risks as well as upside potential. The Strategic portfolios seek to capitalize on secular, as opposed to
cyclical, investment opportunities and attempt to achieve their objectives over a three- to five-year
period.
Tactical Asset Allocation. Tactical asset allocation model portfolios seek to maximize excess returns
over a shorter time horizon than other portfolios we manage. This portfolio is structured for more
active management, and may be preferable for investors who place a greater value on excess returns,
and are willing to accept higher volatility. We may implement a wide variety of investment products
in order to seek a profit in up or down markets. These may include different investment vehicle types,
such as mutual funds and exchange-traded products (exchange-traded funds, exchange-traded notes,
and closed-end funds) that will provide exposure to the most attractive sectors of the market. Since
this portfolio seeks to capitalize on movements in the market, the Tactical portfolio is frequently
traded in order to incorporate strategies that may present greater capital appreciation opportunities
based on shorter time horizons and near-term catalysts.
Long-term purchases. When utilizing this strategy, we may purchase securities with the idea of
holding them for a relatively long time (held for at least a year). A risk in a long-term purchase
strategy is that by holding the security for this length of time, we may not take advantages of short-
term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security
may decline sharply in value before we make the decision to sell. We employ this sub-strategy when
we believe the securities to be well valued and/or we want exposure to a particular asset class over
time, regardless of the current projection for this class.
Short-term purchases. When utilizing this strategy, we may also purchase securities with the idea
of selling them within a relatively short time (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.
Option Writing. We may 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. 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 us 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 will 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 your
portfolio.
We use "covered calls", in which we sell an option on security you own. In this strategy, you receive
a fee for making the option available, and the person purchasing the option has the right to buy the
ADV Part 2A – Firm Brochure
Page 14
Bridgewater Asset Management, LLC
security from you at an agreed-upon price.
We use a "spreading strategy", in which we purchase two or more option contracts (for example, a
call option that you buy and a call option that you sell) for the same underlying security. This
effectively puts you on both sides of the market, but with the ability to vary price, time and other
factors.
Risk of Loss
Securities investments are not guaranteed and you may lose money on your investments. We ask that
you work with us to help us understand your tolerance for risk. Investing in securities involves risk
of loss that clients should be prepared to bear. While the stock market may increase and your
account(s) could enjoy a gain, it is also possible that the stock market may decrease and your
account(s) could suffer a loss. It is important that you understand the risks associated with investing
in the stock market, are appropriately diversified in your investments, and ask us any questions you
may have.
Item 9: Disciplinary Information
There are no legal or disciplinary events that are material to the evaluation of our advisory business
or the integrity of our management.
Item 10: Other Financial Industry Activities & Affiliations
Representatives of our firm are registered representatives of LPL, member FINRA/SIPC and licensed
to sell insurance products. They may offer securities or products and receive normal and customary
commissions as a result of securities transactions. A conflict of interest arises as these
commissionable securities sales create an incentive to recommend products based on the
compensation. In order to mitigate this conflict of interest, we fulfill our fiduciary duty by putting our
client’s interests ahead of our own.
Neither the Company nor any of our management persons (except as disclosed above) are registered,
or have an application pending to register as a broker-dealer, futures commission merchant,
commodity pool operator, commodity trading advisor or as an associated person of the foregoing
entities.
In addition, neither the Company nor any of our management persons have any relationship or
arrangement that is material to our advisory business or to our clients that we or any of our
management persons have with any related person that is, under common control and ownership, a:
Investment company or other pooled investment vehicle,
• Municipal securities dealer, or government securities dealer or broker,
•
• Other investment adviser or financial planner,
• Futures commission merchant (or commodity pool operator or commodity trading advisor),
• Banking or thrift institution,
• Accountant or accounting firm,
ADV Part 2A – Firm Brochure
Page 15
Bridgewater Asset Management, LLC
Insurance company or agency,
• Lawyer or law firm,
•
• Pension consultant, or
• Real estate broker or dealer or
• Sponsor or syndicator of limited partnerships.
We do not receive compensation directly or indirectly from other investment advisers nor have other
business relationships with other investment advisers for whom we have referred our clients.
Item 11: Code of Ethics, Participation or Interest in
Client Transactions & Personal Trading
We recognize that the personal investment transactions of members and employees of our firm demand
the application of a high Code of Ethics and require that all such transactions be carried out in a way that
does not endanger the interest of any client. At the same time, we believe that if investment goals are
similar for clients and for members and employees of our firm, it is logical and even desirable that there
be common ownership of some securities.
Therefore, in order to mitigate conflicts of interest, we have in place a set of procedures (including a pre-
clearing procedure) with respect to transactions effected by our members, officers and employees for
their personal accounts1. In order to monitor compliance with our personal trading policy, we have a
quarterly securities transaction reporting system for all of our associates.
Furthermore, our firm has established a Code of Ethics which applies to all of our associated persons. An
investment adviser is held by law to a fiduciary standard. As a fiduciary, it is an investment adviser’s
responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest
of each of our clients at all times. We have a fiduciary duty to all clients. Our fiduciary duty is considered
the core underlying principle for our Code of Ethics which also includes Insider Trading and Personal
Securities Transactions Policies and Procedures. We require all of our supervised persons to conduct
business with the highest level of ethical standards and to comply with all federal and state securities
laws at all times. Upon employment or affiliation and at least annually thereafter, all supervised persons
will sign an acknowledgement that they have read, understand, and agree to comply with our Code of
Ethics. Our firm and supervised persons must conduct business in an honest, ethical, and fair manner
and avoid all circumstances that might negatively affect or appear to affect our duty of complete loyalty
to all clients. This disclosure is provided to give all clients a summary of our Code of Ethics. However, if
a client or a potential client wishes to review our Code of Ethics in its entirety, a copy will be provided
promptly upon request.
Related persons of our firm may buy or sell securities and other investments that are also
recommended to clients. In order to minimize this conflict of interest, our related persons will place
client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which
is available upon request.
1 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse,
his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our
associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect
beneficial interest in.
ADV Part 2A – Firm Brochure
Page 16
Bridgewater Asset Management, LLC
Related persons of our firm may buy or sell securities for themselves at or about the same time they buy
or sell the same securities for client accounts. In order to minimize this conflict of interest, our related
persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a
copy of which is available upon request. Further, our related persons will refrain from buying or selling
the same securities within 24 hours prior to buying or selling for our clients.
Item 12: Brokerage Practices
Custodian & Brokers Used
Charles Schwab & Co., Inc.
Our firm does not maintain custody of client assets (although our firm may be deemed to have
custody of client assets if give the authority to withdraw assets from client accounts. See Item 15
Custody, below). Client assets must be maintained in an account at a “qualified custodian,” generally
a broker-dealer or bank. Our firm recommends that clients use the Schwab Advisor Services division
of Charles Schwab & Co. Inc. (“Schwab”), a FINRA-registered broker-dealer, member SIPC, as the
qualified custodian. Our firm is independently owned and operated, and not affiliated with Schwab.
Schwab will hold client assets in a brokerage account and buy and sell securities when instructed.
While our firm recommends that clients use Schwab as custodian/broker, clients will decide whether
to do so and open an account with Schwab by entering into an account agreement directly with them.
Our firm does not open the account. Even though the account is maintained at Schwab, our firm can
still use other brokers to execute trades, as described in the next paragraph.
How Brokers/Custodians Are Selected
Our firm seeks 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. A wide range of factors are considered, including, but not limited to:
•
•
•
combination of transaction execution services along with asset custody services (generally
without a separate fee for custody)
capability to execute, clear and settle trades (buy and sell securities for client accounts)
capabilities to facilitate transfers and payments to and from accounts (wire transfers, check
requests, bill payment, etc.)
• breadth of investment products made available (stocks, bonds, mutual funds, exchange
traded funds (ETFs), etc.)
• availability of investment research and tools that assist in making investment decisions
•
quality of services
competitiveness of the price of those services (commission rates, margin interest rates, other
fees, etc.) and willingness to negotiate them
reputation, financial strength and stability of the provider
•
• prior service to our firm and our other clients
• availability of other products and services that benefit our firm, as discussed below (see
“Products & Services Available from Schwab”)
Custody & Brokerage Costs
ADV Part 2A – Firm Brochure
Page 17
Bridgewater Asset Management, LLC
Schwab generally does not charge a separate for custody services, but is compensated by charging
commissions or other fees to clients on trades that are executed or that settle into the Schwab
account. In addition to commissions, Schwab charges a flat dollar amount as a “prime broker” or
“trade away” fee for each trade that our firm has executed by a different broker-dealer but where the
securities bought or the funds from the securities sold are deposited (settled) into a Schwab account.
These fees are in addition to the commissions or other compensation paid to the executing broker-
dealer. Because of this, in order to minimize client trading costs, our firm has Schwab execute most
trades for the accounts.
Products & Services Available from Schwab
Schwab Advisor Services is Schwab’s business serving independent investment advisory firms like
our firm. They provide our firm and 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
manage or administer our client accounts while others help manage and grow our business. Schwab’s
support services are generally available on an unsolicited basis (our firm does not have to request
them) and at no charge to our firm. The availability of Schwab’s products and services is not based
on the provision of particular investment advice, such as purchasing particular securities for clients.
Here is a more detailed description of Schwab’s support services:
Services that Benefit 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 our firm might not otherwise have access or that would
require a significantly higher minimum initial investment by firm clients. Schwab’s services
described in this paragraph generally benefit clients and their accounts.
Services that May Not Directly Benefit Clients
Schwab also makes available other products and services that benefit our firm but may not directly
benefit clients or their accounts. These products and services assist in managing and administering
our client accounts. They include investment research, both Schwab’s and that of third parties. This
research may be used to service all or some substantial number of client accounts, including accounts
not maintained at Schwab. In addition to investment research, Schwab also makes available software
and other technology that:
• provides access to client account data (such as duplicate trade confirmations and account
statements);
facilitates trade execution and allocate aggregated trade orders for multiple client accounts;
facilitates payment of our fees from our clients’ accounts; and
•
• provides pricing and other market data;
•
• assists with back-office functions, recordkeeping and client reporting.
Services that Generally Benefit Only Our Firm
Schwab also offers other services intended to help manage and further develop our business
enterprise. These services include:
• educational conferences and events
ADV Part 2A – Firm Brochure
Page 18
Bridgewater Asset Management, LLC
technology, compliance, legal, and business consulting;
•
• publications and conferences on practice management and business succession; and
• access to employee benefits providers, human capital consultants and insurance providers.
Schwab may provide some of these services itself. In other cases, Schwab will arrange for third-party
vendors to provide the services to our firm. Schwab may also discount or waive fees for some of these
services or pay all or a part of a third party’s fees. Schwab may also provide our firm with other
benefits, such as occasional business entertainment for our personnel.
Irrespective of direct or indirect benefits to our client through Schwab, our firm strives to enhance
the client experience, help clients reach their goals and put client interests before that of our firm or
associated persons.
Our Interest in Schwab’s Services.
The availability of these services from Schwab benefits our firm because our firm does not have to
produce or purchase them. Our firm does not have to pay for these services, and they are not
contingent upon committing any specific amount of business to Schwab in trading commissions or
assets in custody.
In light of our arrangements with Schwab, a conflict of interest exists as our firm may have incentive
to require that clients maintain their accounts with Schwab based on our interest in receiving
Schwab’s services that benefit our firm rather than based on client interest in receiving the best value
in custody services and the most favorable execution of transactions. As part of our fiduciary duty to
our clients, our firm will endeavor at all times to put the interests of our clients first. Clients should
be aware, however, that the receipt of economic benefits by our firm or our related persons creates
a potential conflict of interest and may indirectly influence our firm’s choice of Schwab as a custodial
recommendation. Our firm examined this potential conflict of interest when our firm chose to
recommend Schwab and have determined that the recommendation is in the best interest of our firm’s
clients and satisfies our fiduciary obligations, including our duty to seek best execution.
In seeking best execution, the determinative factor is not the lowest possible cost, but whether the
transaction represents the best qualitative execution, taking into consideration the full range of a
broker-dealer’s services, including the value of research provided, execution capability, commission
rates, and responsiveness. Although our firm will seek competitive rates, to the benefit of all clients,
our firm may not necessarily obtain the lowest possible commission rates for specific client account
transactions. Our firm believes that the selection of Schwab as a custodian and broker is the best
interest of our clients. It is primarily supported by the scope, quality and price of Schwab’s services,
and not Schwab’s services that only benefit our firm.
LPL Financial
Our firm recommends that Clients establish accounts with LPL Financial (“LPL”), member
FINRA/SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. LPL
provides brokerage and custodial services to independent investment advisory firms, including our
firm. For accounts custodied at LPL, LPL is generally compensated by clients through commissions,
trails, or other transaction-based fees for trades that are executed through LPL or that settle into LPL
accounts. For IRA accounts, LPL generally charges account maintenance fees. In addition, LPL also
charges clients miscellaneous fees and charges, such as account transfer fees.
ADV Part 2A – Firm Brochure
Page 19
Bridgewater Asset Management, LLC
While LPL does not participate in, or influence the formulation of, the investment advice our firm
provides, certain supervised persons of our firm are Dually Registered Persons. Dually Registered
Persons are restricted by certain Financial Industry Regulatory Authority (“FINRA”) rules and
policies from maintaining accounts at another custodian or executing transactions in such accounts
through any broker-dealer or custodian that is not approved by LPL. As a result, the use of other
trading platforms must be approved by our firm and LPL.
Clients should also be aware that for accounts where LPL serves as the custodian, our firm is limited
to offering services and investment vehicles that are approved by LPL, and may be prohibited from
offering services and investment vehicles that may be available through other broker-dealers and
custodians, some of which may be more suitable for a client’s portfolio than the services and
investment vehicles offered through LPL. Clients should understand that not all investment advisers
require that Clients custody their accounts and trade through specific broker-dealers.
Benefits Received by Our Personnel
LPL makes available to our firm various products and services designed to assist our firm in
managing and administering client accounts. Many of these products and services may be used to
service all or a substantial number of accounts, including accounts not held with LPL. These include
software and other technology that provide access to client account data (such as trade confirmation
and account statements); facilitate trade execution (and aggregation and allocation of trade orders
for multiple client accounts); provide research, pricing information and other market data; facilitate
payment of our firm’s fees from its clients’ accounts; and assist with back-office functions;
recordkeeping and client reporting.
LPL also makes available to our firm other services intended to help manage and further develop our
business. Some of these services assist our firm to better monitor and service program accounts
maintained at LPL. Many of these services, however, benefit only our firm. These support services
and/or products may be provided without cost, at a discount, and/or at a negotiated rate, and include
practice management-related publications; consulting services; attendance at conferences and
seminars, meetings, and other educational and/or social events; marketing support; and other
products and services used by our firm in furtherance of the operation and development of its
investment advisory business.
Where such services are provided by a third party vendor, LPL will either make a payment to our
firm to cover the cost of such services, reimburse our firm for the cost associated with the services,
or pay the third party vendor directly on behalf of our firm.
The products and services described above are provided to our firm as part of its overall relationship
with LPL. While as a fiduciary, our firm endeavors to act in its clients’ best interests, the receipt of
these benefits creates a conflict of interest because our firm’s requirement that Clients custody their
assets at LPL is based in part on the benefit to our firm of the availability of the foregoing products
and services and not solely on the nature, cost or quality of custody or brokerage services provided
by LPL. Our firm’s receipt of some of these benefits may be based on the amount of advisory assets
custodied on the LPL platform.
ADV Part 2A – Firm Brochure
Page 20
Bridgewater Asset Management, LLC
Item 13: Review of Accounts or Financial Plans
We review accounts on at least a quarterly basis for our clients subscribing to our Asset Management
and LPL Sponsored Advisory Programs. The nature of these reviews is to learn whether clients’
accounts are in line with their investment objectives, appropriately positioned based on market
conditions, and investment policies, if applicable. Only Thomas Ross and Rob Balice will conduct
reviews. Verbal reports to clients take place on at least an annual basis when we contact clients who
subscribe to our Asset Management service. We do not provide written reports to clients, unless
asked to do so.
Pension Consulting clients receive reviews of their pension plans for the duration of the pension
consulting service. We also provide ongoing services to Pension Consulting clients where we meet
with such clients upon their request to discuss updates to their plans, changes in their circumstances,
etc. Pension Consulting clients do not receive written or verbal updated reports regarding their
pension plans unless they choose to contract with us for ongoing Pension Consulting services.
Financial Planning clients do not receive reviews of their written plans unless they take action to
schedule a financial consultation with us. We do not provide ongoing services to financial planning
clients, but are willing to meet with such clients upon their request to discuss updates to their plans,
changes in their circumstances, etc.
We may review client accounts more frequently than described above. Among the factors which may
trigger an off-cycle review are major market or economic events, the client’s life events, requests by
the client, etc.
Item 14: Client Referrals & Other Compensation
Charles Schwab & Co., Inc.
Our firm receives economic benefit from Schwab in the form of the support products and services
made available to our firm and other independent investment advisors that have their clients
maintain accounts at Schwab. These products and services, how they benefit our firm, and the related
conflicts of interest are described above (see Item 12 – Brokerage Practices). The availability of
Schwab’s products and services is not based on our firm giving particular investment advice, such as
buying particular securities for our clients.
LPL Financial
Our firm may receive from LPL or a mutual fund company, without cost and/or at a discount non
soft-dollar support services and/or products, to assist us to better monitor and service client
accounts maintained at such institutions. Included within the support services our firm may receive
investment-related research, pricing information and market data, software and other technology
that provide access to client account data, compliance and/or practice management-related
publications, discounted or gratis consulting services, discounted and/or gratis attendance at
conferences, meetings, and other educational and/or social events, marketing support, computer
ADV Part 2A – Firm Brochure
Page 21
Bridgewater Asset Management, LLC
hardware and/or software and/or other products used by us to assist us in our investment advisory
business operations. Our clients do not pay more for investment transactions effected and/or assets
maintained at LPL as result of this arrangement. There is no commitment made by us to LPL or any
other institution as a result of the above arrangement.
In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm does not provide
cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or
endorsements (which include client referrals).
Item 15: Custody
Our firm does not have custody of client funds or securities. All of our clients receive account
statements directly from their qualified custodians at least quarterly upon opening of an account. If
our firm decides to also send account statements to clients, such notice and account statements
include a legend that recommends that the client compare the account statements received from the
qualified custodian with those received from our firm. Clients are encouraged to raise any questions
with us about the custody, safety or security of their assets and our custodial recommendations.
We encourage our clients to raise any questions with us about the custody, safety or security of their
assets. The custodians we do business with will send you account statements listing your account
balance(s), transaction history and any fee debits or other fees taken out of your account.
Item 16: Investment Discretion
Clients have the option of providing our firm with investment discretion on their behalf, pursuant to
an executed investment advisory client agreement. By granting investment discretion, our firm is
authorized to execute securities transactions, determine which securities are bought and sold, and
the total amount to be bought and sold. Should clients grant our firm non-discretionary authority,
our firm would be required to obtain the client’s permission prior to effecting securities transactions.
Limitations may be imposed by the client in the form of specific constraints on any of these areas of
discretion with our firm’s written acknowledgement.
Item 17: Voting Client Securities
We do not and will not accept the proxy authority to vote client securities. Clients will receive proxies
or other solicitations directly from their custodian or a transfer agent. In the event that proxies are
sent to our firm, we will forward them on to you and ask the party who sent them to mail them
directly to you in the future. Clients may call, write or email us to discuss questions they may have
about particular proxy votes or other solicitations.
ADV Part 2A – Firm Brochure
Page 22
Bridgewater Asset Management, LLC
Item 18: Financial Information
Our firm does not require the prepayment of more than $1,200 in fees when services cannot be
rendered within 6 months. Our firm has never been the subject of a bankruptcy proceeding.
ADV Part 2A – Firm Brochure
Page 23
Bridgewater Asset Management, LLC