Overview
- Headquarters
- Fresno, CA
- Total Firm Assets
- $869 million
- Average High-Net-Worth Client Portfolio Size
- $3.2 million
Fee Structure
Primary Fee Schedule (ADV PART 2A - WRAP FEE BROCHURE)
| 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
- High-Net-Worth Share of Firm Assets
- 63.44%
- Number of High-Net-Worth Clients
- 170
- Total Client Accounts
- 2,338
- Discretionary Accounts
- 2,338
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Pension Consulting, Investment Advisor Selection
Regulatory Filings
- SEC CRD Number
- 293514
Additional Brochure: ADV PART 2A - FIRM BROCHURE (2026-03-30)
View Document Text
FORM ADV PART 2A
BROCHURE
986 W. Alluvial Ave., Suite 101
Fresno, CA 93711
Kevin Hook, Joshua Carpenter, and Derek Elrod
Managing Members
https://www.bridgewealth.com
Telephone: (559) 432-6100
March 30, 2026
Please note that the use of the term "registered investment adviser" and description of our firm and/or
our associates as "registered" does not imply a certain level of skill or training. Clients are encouraged
to review this Brochure and Brochure Supplements for our firm's associates who advise clients for
more information on the qualifications of our firm and our employees. Our e-mail for regulatory
compliance is Info@bridgewealth.com.
This brochure provides information about the qualifications and business practices of Bridgewealth
Advisory Group, LLC. If clients have any questions about the contents of this brochure, please contact
us at (559) 432-6100. The information in this brochure has not been approved or verified by the United
States Securities and Exchange Commission or by any State Securities Authority. Additional
information about our firm is also available on the SEC's website at www.adviserinfo.sec.gov by
searching CRD #293514.
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Item 2 Summary of Material Changes
Bridgewealth Advisory Group, LLC is required to make clients aware of information that has changed
since the last annual update to the Firm Brochure ("Brochure") and that may be important to them.
Clients can then determine whether to request the full brochure for review in its entirety and/or to
contact us with questions about the changes.
Since the filing of our last annual updating amendment, dated March 21, 2025 we no material changes
to report.
Please contact us at (559) 432-6100 if you would like to receive a complete copy of this Disclosure
Brochure provided at no charge.
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Item 3 Table of Contents
Item 1 Cover Page
Item 2 Summary of Material Changes
Item 3 Table of Contents
Item 4 Advisory Business
Item 5 Fees and Compensation
Item 6 Performance-Based Fees and Side-By-Side Management
Item 7 Types of Clients
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Item 9 Disciplinary Information
Item 10 Other Financial Industry Activities and Affiliations
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Item 12 Brokerage Practices
Item 13 Review of Accounts
Item 14 Client Referrals and Other Compensation
Item 15 Custody
Item 16 Investment Discretion
Item 17 Voting Client Securities
Item 18 Financial Information
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Item 4 Advisory Business
Bridgewealth Advisory Group, LLC ("Bridgewealth", "Firm" or "Company") manages assets for different
types of clients to help meet their financial goals while remaining sensitive to risk tolerance and time
horizons through our Comprehensive Portfolio Management Wrap Program, described in our Wrap
Fee Program Brochure. In addition, we provide Financial Planning and Consulting services and
Retirement Plan Consulting services as described below.
Our firm is dedicated to providing individuals and other types of clients with a wide array of investment
advisory services. Our firm is a limited liability company formed under the laws of the State of
California in 2018 and has been in business as an investment adviser since that time. Our firm is
wholly owned by Derek Elrod, Joshua Carpenter, and Kevin Hook.
The following paragraphs describe our services, fees, conflicts of interest and other information you
need to know. Refer to the description of each investment advisory service listed below for information
on how we tailor our advisory services to your individual needs. As used in this brochure, the words
"we," "our," and "us" refer to Bridgewealth Advisory Group, LLC and the words "you," "your," and
"client" refer to you as either a client or prospective client of our firm.
As a fiduciary, it is our duty to always act in the client's best interest. This is accomplished in part by
knowing our client. Our firm has established a service-oriented advisory practice with open lines of
communication for many different types of clients to help meet their financial goals while remaining
sensitive to risk tolerance and time horizons. Working with clients to understand their investment
objectives while educating them about our process, facilitates the kind of working relationship we
value.
Types of Advisory Services Offered
Portfolio Management Services Offered Through a Wrap Fee Program
Refer to Form ADV Part 2A, Appendix 1, Wrap Brochure for details about Wrap Fee Program. We do
not offer portfolio management services in a non-wrap program.
Financial Planning and Consulting
Our firm provides standalone financial planning and consulting services to clients for the management
of financial resources based upon an analysis of current situation, goals, and objectives. Financial
planning services will typically 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 investment planning, retirement planning, estate planning, charitable planning, education
planning, corporate and personal tax planning, cost segregation study, corporate structure, real estate
analysis, mortgage/debt analysis, insurance analysis, lines of credit evaluation, or business and
personal financial planning.
Written financial plans or financial consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the clients. Implementation
of the recommendations will be at the discretion of the client. Our firm provides clients with a summary
of their financial situation, and observations for financial planning engagements. Financial
consultations are not typically accompanied by a written summary of observations and
recommendations, as the process is less formal than the planning service. Assuming that all the
information and documents requested from the client are provided promptly, plans or consultations are
typically completed within 6 months of the client signing a contract with our firm. Clients are under no
obligation to use our firm, or its representatives, for the implementation of any part of the financial
plan. You are free to select other providers.
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Retirement Plan Consulting
Our firm provides retirement plan consulting services to employer plan sponsors and their fiduciaries
based upon the needs of the plan and the services requested by the plan sponsor or named fiduciary
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 advise including all or some of the following:
• Establishing an Investment Policy Statement – Our firm will assist in the development of a
•
statement that summarizes the investment goals and objectives along with the broad strategies
to be employed to meet the objectives.
Investment Options – Our firm will work with the Plan Sponsor to evaluate existing investment
options and make recommendations for appropriate changes.
•
• Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation
models to aid Participants in developing strategies to meet their investment objectives, time
horizon, financial situation and tolerance for risk.
Investment Monitoring – Our firm will monitor the performance of the investments and notify the
client in the event of over/underperformance of investment selections, and we will evaluate
possible updates in times of market volatility.
In general, these services may include an existing plan review and analysis, plan-level advice
regarding fund selection and investment options, education services to plan participants, investment
performance monitoring, and/or ongoing consulting. These retirement plan consulting services will
generally be non-discretionary and advisory in nature. The ultimate decision to act on behalf of the
plan shall remain with the plan sponsor or other named fiduciary.
We are also available to assist with participant enrollment meetings and provide investment-related
educational seminars to plan participants on such topics as diversification, asset allocation, risk
tolerance and investment time horizons. Our educational seminars may include other investment-
related topics specific to the particular plan.
We may also provide additional types of retirement plan consulting services to plans on an individually
negotiated basis. All services, whether discussed above or customized for the plan based upon
requests from the plan fiduciaries (which may include additional plan-level or participant-level services)
shall be detailed in a written agreement and be consistent with the parameters set forth in the plan
documents.
Either party to the retirement plan consulting agreement may terminate the agreement upon written
notice to the other party in accordance with the terms of the agreement for services. The retirement
plan consulting fees will be prorated for the quarter in which the termination notice is given and any
unearned, prepaid fees will be refunded to the client.
In providing services for retirement plan consulting, our firm does not provide any advisory services
with respect to the following types of assets: employer securities, real estate (excluding real estate
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
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accounts, our firm acknowledges its fiduciary standard within the meaning of Section 3(21) or 3(38) of
ERISA as designated by the Retirement Plan Consulting Agreement with respect to the provision of
services described therein.
Participation in Wrap Fee Programs
Our firm manages and sponsors a wrap fee program, as further described in Part 2A, Appendix 1 (the
"Wrap Fee Program Brochure"). Our firm offers individualized investment advice to our Portfolio
Management clients solely through the Wrap Fee Program.
Regulatory Assets Under Management
As of December 31, 2025, we provide continuous management services for $868,922,370 in client
assets managed on a discretionary basis. We also manage $9,700,000 in client assets on a non-
continuous basis.
Types of Investments
We primarily offer advice on mutual funds, exchange-traded funds (ETFs), stocks, and bonds. Refer to
the Methods of Analysis, Investment Strategies and Risk of Loss below for additional disclosures on
this topic. In addition, we sometimes offer interval funds as a suitable investment for some clients.
These funds impose liquidity restrictions and offer periodic repurchase options to their shareholders of
three, six or twelve months. See additional information under Item 8, Methods of Analysis, Investment
Strategies and Risk of Loss.
Additionally, we may advise you on various types of investments based on your stated goals and
objectives. We may also provide advice on any type of investment held in your portfolio at the inception
of our advisory relationship.
Since our investment strategies and advice are based on each client's specific financial situation, the
investment advice we provide to you may be different or conflicting with the advice we give to other
clients regarding the same security or investment.
IRA Rollover Recommendations
For purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02")
where applicable, we are providing the following acknowledgment to you. When we provide
investment advice to you regarding your retirement plan account or individual retirement account, we
are fiduciaries within the meaning of Title I of
the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which
are laws governing retirement accounts. The way we make money creates some conflicts with your
interests, so we operate under a special rule that requires us to act in your best interest and not put our
interest ahead of yours. Under this special rule's provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent
advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
• Charge no more than is reasonable for our services; and
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• Give you basic information about conflicts of interest.
We benefit financially from the rollover of your assets from a retirement account to an account that we
manage or provide investment advice, because the assets increase our assets under management
and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in
your best interest.
Electronic Delivery of Regulatory Notices and Correspondence
Upon written client authorization, Bridgewealth may deliver any required regulatory notices and
disclosures or correspondence via email. Bridgewealth shall have completed all delivery requirements
upon the forwarding of such document, disclosure, notice or correspondence to the Client's last
provided email address (or upon advising the Client via email that such document is available on
Bridgewealth's public website). Client may, at any time, notify Bridgewealth in writing that it does not
wish to receive electronic communications and instead wishes to receive paper communications for no
additional cost.
Item 5 Fees and Compensation
Compensation for Our Advisory Services
Financial Planning and Consulting
Our firm charges on an hourly basis for financial planning and consulting services. The total estimated
fee, as well as the ultimate fee charged, is based on the scope and complexity of our engagement with
the client. The maximum hourly fee to be charged will not exceed $250. Our firm generally requires a
deposit of 50% of the expected amount payable upon execution of the financial planning agreement
with the balance due upon delivery of the financial plan or consultation. The agreement ends upon
delivery of the financial plan or consultation and no additional deliverables are provided unless the
client requests an updated financial plan in the future. A new agreement will be executed at that time
and the fees will be agreed upon at the time of execution of the new agreement. We do not require
prepayment of financial planning fees in excess of $1,200 more than six months in advance.
Financial planning is included with our wrap account program and is not charged separately. Details of
our fees and the payment requirements are outlined in your Agreement with Bridgewealth.
Retirement Plan Consulting
Our Retirement Plan Consulting services are billed on a fee based on the percentage of plan assets.
The total estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of
our engagement with the client. Fees will not exceed 1.75% of plan assets. The fee paying
arrangements will be determined on a case-by-case basis and will be detailed in the signed consulting
agreement. Details of our fees and the payment requirements are outlined in your Agreement with
Bridgewealth.
Fees are calculated based on the exact number of days in the quarter. For example a client with a fee
of 1% and an account value of $500,000 will pay fees for the second quarter (91 days) based on the
following calculation: ((500,000 X 1%) / 365) * 91 = $1246.58.
Additional Information
The fees charged are calculated as described above, and are not charged on the basis of a share of
capital gains upon, or capital appreciation of, the funds, or any portion of the funds of an advisory
Client (15 U.S.C.§80b-5(a)(1)). Our fees are negotiable at our discretion. Fees are based on such
things as the overall complexity of your financial situation and your financial planning, as well as the
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account value and number of accounts. A portion of the fee received is paid to your financial
professional. The cost for financial planning is included in the Program Fee you pay to us on a
quarterly basis. The specific fee we agree on is outlined in your Portfolio Management Agreement.
Additional Fees and Expenses
Bridgewealth does not offer a non-wrap program where clients pay transaction fees for trades
executed by their chosen custodian via individual transaction charges.
Clients participating in our Wrap Fee Program, also pay holdings charges imposed by the chosen
custodian for certain investments, charges imposed directly by a mutual fund, index fund, or exchange-
traded fund, which are disclosed in the fund's prospectus and include fund management fees, initial or
deferred sales charges, mutual fund sales loads, 12b-1 fees, surrender charges, and other fund
expenses, mark-ups and mark-downs, spreads paid to market makers, fees for trades executed away
from custodian, wire transfer fees and other fees and taxes on brokerage accounts and securities
transactions. In addition, IRA and qualified retirement plan fees are imposed by account custodians.
Neither our firm nor our affiliated persons receive a portion of these fees. Securities for which you paid
a commission are not included in advisory accounts so you do not pay advisory fees in addition to
commissions on these securities.
Clients in the Wrap Fee Program will not incur transaction costs for trades by their chosen custodian.
More information about this can be found in our separate Wrap Fee Program Brochure.
Termination and Refunds
Financial Planning and Consulting clients are able to terminate their agreement at any time before the
delivery of a financial plan by providing written notice. For purposes of calculating refunds, all work
performed by us up to the point of termination shall be calculated at the hourly fee currently in effect.
Clients will receive a pro-rata refund of unearned fees based on the time and effort expended by our
firm. Incomplete financial plans will not be provided to the client upon termination of the agreement.
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 30 days' written notice to terminate billing. Billing will terminate 30 days after
receipt of the written 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. If fees are prepaid, a pro rata refund will be
calculated for partial months and unearned, prepaid fees will be promptly refunded.
Compensation for the Sale of Securities or Other Investment Products
Representatives of our firm are registered representatives of APW Capital, Inc. ("APW"), member
FINRA/SIPC. In addition, these individuals may also be licensed insurance agents with a variety of
firms. As such they are able to accept compensation for the sale of securities, other investment
products, or insurance products, including distribution or service ("trail" or "12b-1") fees from the sale of
mutual funds. Clients should be aware that the practice of accepting commissions for the sale of
securities and insurance products presents a conflict of interest and gives our firm and our
representatives an incentive to recommend products based on the compensation received. Our firm
generally addresses commissionable sales conflicts that arise by disclosing the compensation to the
client and explaining to clients that these sales create an incentive to recommend based on the
compensation to be earned. When we recommend commissionable mutual funds, we document why
available "no load" funds are not a more suitable solution. We do not purchase commissionable
securities or insurance products in our clients' advisory accounts although some products may be
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purchased outside of the advisory account, if in the client's best interest. If purchased outside of your
advisory account, we will earn only a commission on the product(s) you purchase and not an advisory
fee.
Bridgewealth eliminates this conflict of interest because it does not receive 12b-1 fees from
investments in clients' advisory accounts. Although the mutual fund share class purchased may pay
12b-1 fees they are not shared with Bridgewealth or its representatives. At all times Bridgewealth
strives to choose the share class that is in the client's best interest.
You are under no obligation, contractually or otherwise, to purchase securities products through any
person affiliated with our firm.
Item 6 Performance-Based Fees and Side-By-Side Management
Our firm does not charge performance-based fees or engage in side-by-side management of accounts.
Item 7 Types of Clients
Minimum Account Size
Bridgewealth does not impose a minimum account size or charge a minimum annual fee.
Types of Clients
Our clients are comprised of individuals, high net worth individuals and their families, trusts, estates or
charitable organizations, retirement plans, and small businesses.
Investment Restrictions
Clients may set reasonable restrictions on the investment of the assets in their wrap accounts,
including the types of securities that should not be purchased, or if already held, securities that should
not be sold. Bridgewealth must agree to these restrictions.
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
We use the following methods of analysis in formulating our investment advice and/or managing client
assets:
Fundamental Analysis: The analysis of a business's financial statements (usually to analyze the
business's assets, liabilities, and earnings), health, and its competitors and markets. When analyzing a
stock, futures contract, or currency using fundamental analysis there are two basic approaches one
can use: bottom up analysis and top down analysis. The terms are used to distinguish such analysis
from other types of investment analysis, such as quantitative and technical. Fundamental analysis is
performed on historical and present data, but with the goal of making financial forecasts. There are
several possible objectives: (a) to conduct a company stock valuation and predict its probable price
evolution; (b) to make a projection on its business performance; (c) to evaluate its management and
make internal business decisions; (d) and/or to calculate its credit risk.; and (e) to find out the intrinsic
value of the share.
When the objective of the analysis is to determine what stock to buy and at what price, there are two
basic methodologies investors rely upon: (a) Fundamental analysis maintains that markets may
misprice a security in the short run but that the "correct" price will eventually be reached. Profits can be
made by purchasing the mispriced security and then waiting for the market to recognize its "mistake"
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and reprice the security.; and (b) Technical analysis maintains that all information is reflected already
in the price of a security. Technical analysts analyze trends and believe that sentiment changes
predate and predict trend changes. Investors' emotional responses to price movements lead to
recognizable price chart patterns. Technical analysts also analyze historical trends to predict future
price movement. Investors can use one or both of these different but complementary methods for stock
picking. This presents a potential risk, as the price of a security can move up or down along with the
overall market regardless of the economic and financial factors considered in evaluating the stock.
Investment Strategies We Use
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:
Alternative Investments: Hedge funds, commodity pools, Real Estate Investment Trusts ("REITs"),
Business Development Companies ("BDCs"), Delaware Statutory Trusts ("DSTs"), Private Equity,
Private Credit, Private REITs, and other alternative investments involve a high degree of risk and can
be illiquid due to restrictions on transfer and lack of a secondary trading market. They can be highly
leveraged, speculative and volatile, and an investor could lose all or a substantial amount of an
investment. Alternative investments may lack transparency as to share price, valuation and portfolio
holdings. Complex tax structures often result in delayed tax reporting. Compared to mutual funds,
hedge funds and commodity pools are subject to less regulation and often charge higher fees.
Alternative investment managers typically exercise broad investment discretion and may apply similar
strategies across multiple investment vehicles, resulting in less diversification.
Asset Allocation: The implementation of an investment strategy that attempts to balance risk versus
reward by adjusting the percentage of each asset in an investment portfolio according to the investor's
risk tolerance, goals and investment time frame. Asset allocation is based on the principle that different
assets perform differently in different market and economic conditions. A fundamental justification for
asset allocation is the notion that different asset classes offer returns that are not perfectly correlated,
hence diversification reduces the overall risk in terms of the variability of returns for a given level of
expected return. Although risk is reduced as long as correlations are not perfect, it is typically forecast
(wholly or in part) based on statistical relationships (like correlation and variance) that existed over
some past period. Expectations for return are often derived in the same way.
An asset class is a group of economic resources sharing similar characteristics, such as riskiness and
return. There are many types of assets that may or may not be included in an asset allocation strategy.
The "traditional" asset classes are stocks (value, dividend, growth, or sector-specific [or a "blend" of
any two or more of the preceding]; large-cap versus mid-cap, small-cap or micro-cap; domestic, foreign
[developed], emerging or frontier markets), bonds (fixed income securities more generally: investment-
grade or junk [high-yield]; government or corporate; short-term, intermediate, long-term; domestic,
foreign, emerging markets), and cash or cash equivalents. Allocation among these three provides a
starting point.
There are several types of asset allocation strategies based on investment goals, risk tolerance, time
frames and diversification. The most common forms of asset allocation are: strategic, dynamic, tactical,
and core-satellite.
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
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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. Bonds
with longer rates of maturity tend to have greater interest rate risks.
Certain additional risk factors relating to debt securities include: (a) When interest rates are declining,
investors have to reinvest their interest income and any return of principal, whether scheduled or
unscheduled, at lower prevailing rates.; (b) Inflation causes tomorrow's dollar to be worth less than
today's; in other words, it reduces the purchasing power of a bond investor's future interest payments
and principal, collectively known as "cash flows." Inflation also leads to higher interest rates, which in
turn leads to lower bond prices.; (c) Debt securities may be sensitive to economic changes, political
and corporate developments, and interest rate changes. Investors can also expect periods of
economic change and uncertainty, which can result in increased volatility of market prices and yields of
certain debt securities. For example, 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. (d) Debt securities may contain redemption or call provisions entitling their issuers to redeem
them at a specified price on a date prior to maturity. If an issuer exercises these provisions in a lower
interest rate market, the account would have to replace the security with a lower yielding security,
resulting in decreased income to investors. Usually, a bond is called at or close to par value. This
subjects investors that paid a premium for their bond risk of lost principal. In reality, prices of callable
bonds are unlikely to move much above the call price if lower interest rates make the bond likely to be
called.; (e) If the issuer of a debt security defaults on its obligations to pay interest or principal or is the
subject of bankruptcy proceedings, the account may incur losses or expenses in seeking recovery of
amounts owed to it.; (f) There may be little trading in the secondary market for particular debt
securities, which may affect adversely the account's ability to value accurately or dispose of such debt
securities. Adverse publicity and investor perceptions, whether or not based on fundamental analysis,
may decrease the value and/or liquidity of debt securities.
Our firm attempts to reduce the risks described above through diversification of the client's portfolio
and by credit analysis of each issuer, as well as by monitoring broad economic trends and corporate
and legislative developments, but there can be no assurance that our firm will be successful in doing
so. Credit ratings for debt securities provided by rating agencies reflect an evaluation of the safety of
principal and interest payments, not market value risk. The rating of an issuer is a rating agency's view
of past and future potential developments related to the issuer and may not necessarily reflect actual
outcomes. There can be a lag between the time of developments relating to an issuer and the time a
rating is assigned and updated.
Exchange Traded Funds ("ETFs"): An ETF is a type of Investment Company (usually, an open-end
fund or unit investment trust) whose primary objective is to achieve the same return as a particular
market index. The vast majority of ETFs are designed to track an index, so their performance is close
to that of an index mutual fund, but they are not exact duplicates. A tracking error, or the difference
between the returns of a fund and the returns of the index, can arise due to differences in composition,
management fees, expenses, and handling of dividends. ETFs benefit from continuous pricing; they
can be bought and sold on a stock exchange throughout the trading day. Because ETFs trade like
stocks, you can place orders just like with individual stocks - such as limit orders, good until-canceled
orders, stop loss orders etc. They can also be sold short. Traditional mutual funds are bought and
redeemed based on their net asset values ("NAV") at the end of the day. ETFs are bought and sold at
the market prices on the exchanges, which resemble the underlying NAV but are independent of it.
However, arbitrageurs will ensure that ETF prices are kept very close to the NAV of the underlying
securities. Although an investor can buy as few as one share of an ETF, most buy in board lots.
Anything bought in less than a board lot will increase the cost to the investor. Anyone can buy any ETF
no matter where in the world it trades. This provides a benefit over mutual funds, which generally can
only be bought in the country in which they are registered.
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One of the main features of ETFs are their low annual fees, especially when compared to traditional
mutual funds. The passive nature of index investing, reduced marketing, and distribution and
accounting expenses all contribute to the lower fees. However, individual investors must pay a
brokerage commission to purchase and sell ETF shares; for those investors who trade frequently, this
can significantly increase the cost of investing in ETFs. That said, with the advent of low-cost
brokerage fees, small or frequent purchases of ETFs are becoming more cost efficient.
Fixed Income: Fixed income is a type of investing or budgeting style for which real return rates or
periodic income is received at regular intervals and at reasonably predictable levels. Fixed income
investors are typically retired individuals who rely on their investments to provide a regular, stable
income stream. This demographic tends to invest heavily in fixed-income investments because of the
reliable returns they offer. Fixed income investors who live on set amounts of periodically paid income
face the risk of inflation eroding their spending power.
Some examples of fixed-income investments include treasuries, money market instruments, corporate
bonds, asset-backed securities, municipal bonds and international bonds. The primary risk associated
with fixed income investments is the borrower defaulting on his payment. Other considerations include
exchange rate risk for international bonds and interest rate risk for longer dated securities. The most
common type of fixed-income security is a bond. Bonds are issued by federal governments, local
municipalities and major corporations. Fixed income securities are recommended for investors seeking
a diverse portfolio; however, the percentage of the portfolio dedicated to fixed income depends on your
own personal investment style. There is also an opportunity to diversify the fixed income component of
a portfolio. Riskier fixed income products, such as junk bonds and longer-dated products, should
comprise a lower percentage of your overall portfolio.
The interest payment on fixed-income securities is considered regular income and is determined based
on the creditworthiness of the borrower and current market rates. In general, bonds and fixed-income
securities with longer-dated maturities pay a higher rate, also referred to as the coupon rate, because
they are considered riskier. The longer the security is on the market, the more time it has to lose its
value and/or default. At the end of the bond term, or at bond maturity, the borrower returns the amount
borrowed, also referred to as the principal or par value.
Interval Funds
An interval fund is a type of investment company that periodically offers to repurchase its shares from
shareholders. That is, the fund periodically offers to buy back a stated portionof its shares from
shareholders. Shareholders are not required to accept these offers and sell their shares back to the
fund.
Legally, interval funds are classified as closed-end funds, but they are very different from traditional
closed-end funds in that:
• Their shares typically do not trade on the secondary market. Instead, their shares are subject to
periodic repurchase offers by the fund at a price based on net asset value.
• They are permitted to (and many interval funds do) continuously offer their shares at a price
based on the fund's net asset value.
An interval fund will make periodic repurchase offers to its shareholders, generally every three, six, or
twelve months, as disclosed in the fund's prospectus and annual report. The interval fund also will
periodically notify its shareholders of the upcoming repurchase dates. When the fund makes a
repurchase offer to its shareholders, it will specify a date by which shareholders must accept the
repurchase offer. The actual repurchase will occur at a later, specified date.
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The price that shareholders will receive on a repurchase will be based on the per share NAV
determined as of a specified (and disclosed) date. This date will occur sometime after the close of
business on the date that shareholders must submit their acceptances of the repurchase offer (but
generally not more than 14 days after the acceptance date).
Note that interval funds are permitted to deduct a redemption fee from the repurchase proceeds, not to
exceed 2% of the proceeds. The fee is paid to the fund, and generally is intended to compensate the
fund for expenses directly related to the repurchase. Interval funds may charge other fees as well.
Interval funds are only suitable for certain Bridgewealth clients and the client must be comfortable with
the liquidity restrictions for the money they invest in interval funds. Full disclosure must be made to the
clients before the time of purchase and the recommendation must be in the client's best interest.
Long-Term Purchases: Our firm may buy securities for your account and hold them for a relatively
long time (more than a year) in anticipation that the security's value will appreciate over a long horizon.
The risk of this strategy is that our firm could miss out on potential short-term gains that could have
been profitable to your account, or it's possible that the security's value may decline sharply before our
firm make a decision to sell.
Short-Term Purchases: When utilizing this strategy, our firm may also purchase securities with the
idea of selling them within a relatively short time (typically a year or less). Our firm does this in an
attempt to take advantage of conditions that our firm believes will soon result in a price swing in the
securities our firm purchase.
Mutual Funds: A mutual fund is a company that pools money from many investors and invests the
money in a variety of differing security types based the objectives of the fund. The portfolio of the fund
consists of the combined holdings it owns. Each share represents an investor's proportionate
ownership of the fund's holdings and the income those holdings generate. The price that investors pay
for mutual fund shares is the fund's per share net asset value ("NAV") plus any shareholder fees that
the fund imposes at the time of purchase (such as sales loads). Investors typically cannot ascertain the
exact make-up of a fund's portfolio at any given time, nor can they directly influence which securities
the fund manager buys and sells or the timing of those trades. With an individual stock, investors can
obtain real-time (or close to real-time) pricing information with relative ease by checking financial
websites or by calling a broker or your investment adviser. Investors can also monitor how a stock's
price changes from hour to hour—or even second to second. By contrast, with a mutual fund, the price
at which an investor purchases or redeems shares will typically depend on the fund's NAV, which is
calculated daily after market close.
The benefits of investing through mutual funds include: (a) Mutual funds are professionally managed
by an investment adviser who researches, selects, and monitors the performance of the securities
purchased by the fund; (b) Mutual funds typically have the benefit of diversification, which is an
investing strategy that generally sums up as "Don't put all your eggs in one basket." Spreading
investments across a wide range of companies and industry sectors can help lower the risk if a
company or sector fails. Some investors find it easier to achieve diversification through ownership of
mutual funds rather than through ownership of individual stocks or bonds.; (c) Some mutual funds
accommodate investors who do not have a lot of money to invest by setting relatively low dollar
amounts for initial purchases, subsequent monthly purchases, or both.; and (d) At any time, mutual
fund investors can readily redeem their shares at the current NAV, less any fees and charges
assessed on redemption. Mutual funds also have features that some investors might view as
disadvantages: (a) Investors must pay sales charges, annual fees, and other expenses regardless of
how the fund performs. Depending on the timing of their investment, investors may also have to pay
taxes on any capital gains distribution they receive. This includes instances where the fund went on to
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perform poorly after purchasing shares.; (b) Investors typically cannot ascertain the exact make-up of a
fund's portfolio at any given time, nor can they directly influence which securities the fund manager
buys and sells or the timing of those trades.; and (c) With an individual stock, investors can obtain real
time (or close to real time) pricing information with relative ease by checking financial websites or by
calling a broker or your investment adviser. Investors can also monitor how a stock's price changes
from hour to hour—or even second to second. By contrast, with a mutual fund, the price at which an
investor purchases or redeems shares will typically depend on the fund's NAV, which the fund might
not calculate until many hours after the investor placed the order. In general, mutual funds must
calculate their NAV at least once every business day, typically after the major U.S. exchanges close.
When investors buy and hold an individual stock or bond, the investor must pay income tax each year
on the dividends or interest the investor receives. However, the investor will not have to pay any capital
gains tax until the investor actually sells and makes a profit. Mutual funds are different. When an
investor buys and holds mutual fund shares, the investor will owe income tax on any ordinary
dividends in the year the investor receives or reinvests them. Moreover, in addition to owing taxes on
any personal capital gains when the investor sells shares, the investor may have to pay taxes each
year on the fund's capital gains. That is because the law requires mutual funds to distribute capital
gains to shareholders if they sell securities for a profit, and cannot use losses to offset these gains.
Real Estate Investment Trusts ("REITs"): REITs primarily invest in real estate or real estate related
loans. Equity REITs own real estate properties, while mortgage REITs hold construction, development
and/or long-term mortgage loans. Changes in the value of the underlying property of the trusts, the
creditworthiness of the issuer, property taxes, interest rates, tax laws, and regulatory requirements,
such as those relating to the environment all can affect the values of REITs. Both types of REITs are
dependent upon management skill, the cash flows generated by their holdings, the real estate market
in general, and the possibility of failing to qualify for any applicable passthrough tax treatment or failing
to maintain any applicable exemptive status afforded under relevant laws.
Delaware Statutory Trusts ("DSTs"): DSTs are structured to take advantage of the tax deferral
opportunity permitted by Section 1031 of the United States Internal Revenue Code. Investments in
DSTs are available only to accredited investors. Each DST has features that may create other tax
consequences for the investor, such as state tax obligations or generation of passive income.
Limitations on withdrawal rights create a higher liquidity risk and as such, investments in DSTs should
be viewed as a long-term investment. The duration of such investments is more sensitive to interest
rates and includes the possibility of more volatility than other investments. Clients should carefully
review all DST Private Placement Memorandum, prospectuses and other offering documents as
provided by the Advisor prior to investing. The taxable nature of DSTs may change over time, based
on changes to law and government interpretation of the taxable considerations of assets.
Private Placements: A private placement (nonpublic offering) is an illiquid security sold to qualified
investors and are not publicly traded nor registered with the Securities and Exchange
Commission. Private placements generally carry a higher degree of risk due to illiquidity. Most
securities that are acquired in a private placement will be restricted securities and must be held for an
extended amount of time and therefore cannot be sold easily. The range of risks are dependent on the
nature of the partnership and are disclosed in the offering documents.
Limited Partnerships: 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 has management authority and
unlimited liability. 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 their
liability is limited to the amount of their capital commitment. Profits are divided between general and
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limited partners according to an arrangement formed at the creation of the partnership. The range of
risks are dependent on the nature of the partnership and disclosed in the offering documents if
privately placed. Publicly traded limited partnership have similar risk attributes to equities. However,
like privately placed limited partnerships their tax treatment is under a different tax regime from
equities. You should speak to your tax adviser in regard to their tax treatment.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear. While movements in
the stock market may create gains in the account(s), it is also possible that movements in the stock
market may create a loss in the account(s). It is important that clients understand the risks associated
with investing in the stock market, and that their assets are appropriately diversified in investments.
Clients are encouraged to ask our firm any questions regarding their risk tolerance.
Company Risk: When investing in stock positions, there is always a certain level of company or
industry specific risk that is inherent in each investment. This is also referred to as unsystematic risk
and can be reduced through appropriate diversification. There is the risk that the company will perform
poorly or have its value reduced based on factors specific to the company or its industry. For example,
if a company's employees go on strike or the company receives unfavorable media attention for its
actions, the value of the company may be reduced.
Credit Risk: Credit risk can be a factor in situations where an investment's performance relies on a
borrower's repayment of borrowed funds. With credit risk, an investor can experience a loss or
unfavorable performance if a borrower does not repay the borrowed funds as expected or required.
Investment holdings that involve forms of indebtedness (i.e. borrowed funds) are subject to credit risk.
Defensive Strategy Risk: Defensive strategies are primarily used in periods of high volatility or
economic uncertainty and aimed at reducing exposure to the equity market. Our goal is simply to help
our clients achieve their financial goals, regardless of market conditions. If our firm forecasts a
prolonged and substantial downturn for the equity markets, it may adopt a defensive strategy for
clients' growth allocation by investing substantially in money market securities and/or short term fixed
income securities. There can be no guarantee that our firm will accurately forecast any prolonged and
substantial downturn in the equity markets, or that the use defensive techniques would be successful
in avoiding losses. The use of defensive strategies could result in a negative outcome for a client. A
few negative consequences could be high turnover re-entry in the same security at a higher rice, loss
of growth if the equity markets move up, high tax liability within taxable accounts and higher trading
cost.
Economic Risk: The prevailing economic environment is important to the health of all businesses.
Some companies, however, are more sensitive to changes in the domestic or global economy than
others. These types of companies are often referred to as cyclical businesses. Countries in which a
large portion of businesses are in cyclical industries are thus also very economically sensitive and
carry a higher amount of economic risk. If an investment is issued by a party located in a country that
experiences wide swings from an economic standpoint or in situations where certain elements of an
investment instrument are hinged on dealings in such countries, the investment instrument will
generally be subject to a higher level of economic risk.
ETF and Mutual Fund Risks: When investing in an ETF or mutual fund, you will bear additional
expenses based on your pro rata share of the ETF's or mutual fund's operating expenses, including
the potential duplication of management fees. The risk of owning an ETF or mutual fund generally
reflects the risks of owning the underlying securities the ETF or mutual fund holds. Clients will also
incur brokerage costs when purchasing ETFs.
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Fixed Income Securities Risk: Typically, the values of fixed-income securities change inversely with
prevailing interest rates. Therefore, a fundamental risk of fixed-income securities is interest rate risk,
which is the risk that their value will generally decline as prevailing interest rates rise, which may cause
your account value to likewise decrease, and vice versa. How specific fixed income securities may
react to changes in interest rates will depend on the specific characteristics of each security. Fixed-
income securities are also subject to credit risk, prepayment risk, valuation risk, and liquidity risk.
Credit risk is the chance that a bond issuer will fail to pay interest and principal in a timely manner, or
that negative perceptions of the issuer's ability to make such payments will cause the price of a bond to
decline.
Liquidity Risk: Certain assets may not be readily converted into cash or may have a very limited
market in which they trade. Thus, you may experience the risk that your investment or assets within
your investment may not be able to be liquidated quickly, thus, extending the period of time by which
you may receive the proceeds from your investment. Liquidity risk can also result in unfavorable pricing
when exiting (i.e. not being able to quickly get out of an investment before the price drops significantly)
a particular investment and therefore, can have a negative impact on investment returns.
Operational Risk: Operational risk can be experienced when an issuer of an investment product is
unable to carry out the business it has planned to execute. Operational risk can be experienced as a
result of human failure, operational inefficiencies, system failures, or the failure of other processes
critical to the business operations of the issuer or counter party to the investment.
Options Risk: Options on securities may be subject to greater fluctuations in value than an investment
in the underlying securities. Purchasing and writing put and call options are highly specialized activities
and entail greater than ordinary investment risks. Past Performance: Charting and technical analysis
are often used interchangeably. Technical analysis generally attempts to forecast an investment's
future potential by analyzing its past performance and other related statistics. In particular, technical
analysis often times involves an evaluation of historical pricing and volume of a particular security for
the purpose of forecasting where future price and volume figures may go. As with any investment
analysis method, technical analysis runs the risk of not knowing the future and thus, investors should
realize that even the most diligent and thorough technical analysis cannot predict or guarantee the
future performance of any particular investment instrument or issuer thereof.
Strategy Risk: There is no guarantee that the investment strategies discussed herein will work under
all market conditions and each investor should evaluate his/her ability to maintain any investment
he/she is considering in light of his/her own investment time horizon. Investments are subject to risk,
including possible loss of principal.
Description of Material, Significant or Unusual Risks
Our firm generally invests client cash balances in money market funds, FDIC Insured Certificates of
Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, our
firm tries to achieve the highest return on client cash balances through relatively low-risk conservative
investments. In most cases, at least a partial cash balance will be maintained in a money market
account so that our firm may debit advisory fees for our services related to our Comprehensive
Portfolio Management services, as applicable.
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.
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Item 10 Other Financial Industry Activities and Affiliations
Representatives of our firm are registered representatives of APW, member FINRA/SIPC, and licensed
insurance agents. As a result of these transactions, they receive normal and customary commissions.
A conflict of interest exists as these commissionable securities sales create an incentive to recommend
products based on the compensation earned. To mitigate this potential conflict, our firm will
not buy products that pay us commissions in advisory accounts.
Item 11 Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Description of Our Code of Ethics
We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code
of Ethics includes guidelines for professional standards of conduct for persons associated with our
firm. Our goal is to protect your interests at all times and to demonstrate our commitment to our
fiduciary duties of honesty, good faith, and fair dealing with you. All persons associated with our firm
are expected to adhere strictly to these guidelines. Persons associated with our firm are also required
to report any violations of our Code of Ethics. Additionally, we maintain and enforce written policies
reasonably designed to prevent the misuse or dissemination of material, nonpublic information about
you or your account holdings by persons associated with our firm.
Clients or prospective clients may obtain a copy of our Code of Ethics by contacting us at the
telephone number on the cover page of this brochure.
Personal Trading Practices
Our firm or persons associated with our firm may buy or sell the same securities that we recommend to
you or securities in which you are already invested. A conflict of interest exists in such cases because
we have the ability to trade ahead of you and potentially receive more favorable prices than you will
receive. To mitigate this conflict of interest, it is our policy that neither our firm nor persons associated
with our firm shall have priority over your account in the purchase or sale of securities.
Item 12 Brokerage Practices
Clients with only financial planning or consulting agreements with Bridgewealth are free to hold their
accounts at the custodian of their choice.
For retirement plan clients, plan assets may be held at the custodian or broker-dealer selected by the
retirement plan's fiduciary(ies).
Research and Other Soft Dollar Benefits
We do not have any soft dollar arrangements.
Economic Benefits
We receive no economic benefits from custodians for financial planning clients. If retirement plan
clients' plan assets are held at Pershing Advisor Services, LLC ("PAS"), our recommended custodian,
we do receive economic benefits.
As a registered investment adviser, we have access to the institutional platform of PAS. As such, we
will also have access to research products and services from PAS and their affiliates or other firms
they choose to partner with. These products may include financial publications, information about
particular companies and industries, research software, and other products or services that provide
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lawful and appropriate assistance to our firm in the performance of our investment decision-making
responsibilities. Such research products and services are provided to all investment advisers that
utilize the institutional services platforms of these firms, and are not considered to be paid for with soft
dollars. However, you should be aware that the commissions charged by a particular broker for a
particular transaction or set of transactions may be greater than the amounts another broker-dealer
who did not provide research services or products might charge. Some benefits are helpful only to us;
some are direct benefits for you; and some benefits are available to both our firm and our clients.
Brokerage for Client Referrals
We do not receive client referrals from PAS or other broker-dealers in exchange for cash or other
compensation, such as brokerage services or research.
Directed Brokerage
We do not generally allow directed brokerage although we may make an exception in certain
circumstances.
Non-Affiliated Broker-Dealer
Persons providing investment advice on behalf of our firm who are registered representatives of APW
Capital, Inc. must recommend APW Capital, Inc. to you for commissionable securities transactions but
not for advisory services. These individuals are subject to applicable rules that restrict them from
conducting securities transactions for brokerage accounts away from APW Capital, Inc. unless APW
Capital, Inc. provides the representative with written authorization to do so. These registered
representatives have the written authorization to use PAS as the custodian for Bridgewealth's advisory
accounts. You may utilize the broker-dealer of your choice for your advisory accounts and have no
obligation to purchase or sell securities through PAS as we recommend. However, if you do not use
PAS we may not be able to accept your account.
Aggregated Trades
We have the ability to combine multiple orders for shares of the same securities purchased for
discretionary advisory accounts we manage (this practice is commonly referred to as "aggregated or
block trading"). We will then distribute a portion of the shares to participating accounts in a fair and
equitable manner. Generally, participating accounts will pay a fixed transaction cost regardless of the
number of shares transacted. In certain cases, each participating account pays an average price per
share for all transactions and pays a proportionate share of all transaction costs on any given day. In
the event an order is only partially filled, the shares will be allocated to participating accounts in a fair
and equitable manner, typically in proportion to the size of each client's order. Accounts owned by our
firm or persons associated with our firm may participate in aggregated trading with your accounts;
however, they will not be given preferential treatment.
Item 13 Review of Accounts
Financial planning clients do not receive reviews of their written plans unless they take action to
schedule a financial consultation with us. Our firm does not provide ongoing services to financial
planning only clients, but are willing to meet with such clients upon their request to discuss updates to
their plans, changes in their circumstances, etc. Financial planning clients do not receive written or
verbal updated reports regarding their financial plans unless they separately engage our firm for a
post-financial plan meeting or an update to their initial written financial plan.
Retirement Plan Consulting clients receive reviews of their retirement plans for the duration of the
service. Our firm also provides ongoing services where we meet with clients at your request to discuss
updates to your plans, changes in financial circumstances, etc. Retirement Plan Consulting clients do
not receive written or verbal updated reports regarding their plans unless specified in their agreement.
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In addition, we send quarterly reports to some clients. Verbal reports to clients take place on at least
an annual basis when our wrap account clients are contacted. In addition, clients have the ability to
sign into their client portal on Black Diamond to view reports provided by Bridgewealth.
We strongly suggest meeting in-person, on the telephone, or via electronic means at least once a year
to review your accounts together, learn if your financial situation has changed, and to determine if
changes need made to your current holdings. We realize that some clients prefer to meet less
frequently.
Item 14 Client Referrals and Other Compensation
Our firm does not directly or indirectly compensate anyone for client referrals, nor does it receive direct
or indirect compensation from anyone for client referrals
Item 15 Custody
Our firm does not have custody of client funds or securities, other than the ability to withdraw our fees
from a client's account as mentioned in Item 5, Fees and Compensation, or as outlined below for third-
party standing letters of authorization. Our clients receive account statements directly from their
qualified custodian. We provide quarterly reports to most clients. These are in addition to the account
statements you receive from your custodian, and they are not meant as a replacement for your
custodian's statements.
Third-Party Standing Letters of Authorization ("SLOAs")
Our firm, or persons associated with our firm, may effect wire transfers from client accounts to one or
more third parties designated, in writing, by the client without obtaining written client consent for each
separate, individual transaction, as long as the client has provided us with written authorization to do
so. Such written authorization is known as a Standing Letter of Authorization provides authorization for
more than one transaction to the same third-party. An adviser with authority to conduct such third-
party transactions on a client\'s behalf technically has access to client assets under SEC regulations,
and therefore has custody of the client\'s assets in any related accounts.
We are not required to obtain a surprise annual audit as long as we meet the following criteria:
1. You provide a written, signed instruction to the qualified custodian that includes the third party's
name and address or account number at a custodian;
2. You authorize us in writing to direct transfers to the third party either on a specified schedule or
from time to time;
3. Your qualified custodian verifies your authorization (e.g., signature review) and provides a
transfer of funds notice to you promptly after each transfer;
4. You can terminate or change the instruction;
5. We have no authority or ability to designate or change the identity of the third party, the
address, or any other information about the third party;
6. We maintain records showing that the third party is not a related party to us nor located at the
same address as us; and
7. Your qualified custodian sends you, in writing, an initial notice confirming the instruction and an
annual notice reconfirming the instruction.
We hereby confirm that we meet the above criteria.
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Item 16 Investment Discretion
Investment discretion is not provided to Bridgewealth for financial planning only clients.
Item 17 Voting Client Securities
Our firm does not vote proxies on behalf of client accounts. Clients will receive proxies or other
solicitations directly from their custodian or a transfer agent.
Item 18 Financial Information
We have not filed a bankruptcy petition at any time in the past ten years.
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Primary Brochure: ADV PART 2A - WRAP FEE BROCHURE (2026-03-30)
View Document Text
PART 2A - APPENDIX 1
WRAP FEE PROGRAM BROCHURE
986 W. Alluvial Ave., Suite 101
Fresno, CA 93711
Kevin Hook, Joshua Carpenter, and Derek Elrod
Managing Members
https://www.bridgewealth.com
Telephone: (559) 432-6100
March 30, 2026
This brochure provides information about the qualifications and business practices of Bridgewealth
Advisory Group, LLC. If you have any questions about the contents of this brochure, contact us at 559-
431-0060. 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 Bridgewealth Advisory Group, LLC is available on the SEC's website at
www.adviserinfo.sec.gov.
Bridgewealth Advisory Group, LLC is a registered investment adviser. Registration with the United
States Securities and Exchange Commission or any state securities authority does not imply a certain
level of skill or training.
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Item 2 Summary of Material Changes
Bridgewealth Advisory Group, LLC is required to make clients aware of information that has changed
since the last annual update to the Wrap Brochure ("Wrap Brochure") and that may be important to
them. Clients can then determine whether to request the full brochure for review in its entirety and/or to
contact us with questions about the changes.
Since the filing of our last annual updating amendment, dated March 21, 2025 we have no material
changes to report.
Please contact us at (559) 432-6100 if you would like to receive a complete copy of our Wrap
Brochure. A copy will be provided at no charge.
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Item 3 Table of Contents
Item 1 Cover Page
Item 2 Summary of Material Changes
Item 3 Table of Contents
Item 4 Services, Fees, and Compensation
Item 5 Account Requirements and Types of Clients
Item 6 Portfolio Manager Selection and Evaluation
Item 7 Client Information Provided to Portfolio Managers
Item 8 Client Contact with Portfolio Managers
Item 9 Additional Information
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Item 4 Services, Fees, and Compensation
Description of Firm
Bridgewealth Advisory Group, LLC ("Bridgewealth", "Firm" or "Company") manages assets for different
types of clients to help meet their financial goals while remaining sensitive to risk tolerance and time
horizons. As a fiduciary, it is our duty to always act in the client's best interest. This is accomplished in
part by knowing the client. Our firm has established a service-oriented advisory practice with open
lines of communication. Working with clients to understand their investment objectives while educating
them about our process, facilitates the kind of working relationship we value.
Our firm sponsors and offers a wrap fee program, which allows clients to pay a single fee for
investment advisory services and associated custodial transaction costs. Transaction fees are paid by
our firm via individual transaction charges and not by you. Because our firm absorbs these client
transaction fees, an incentive exists for us to limit trading activities in client accounts. We do not offer a
non-wrap account where clients pay the custodial transaction costs.
Depending on your account or portfolio trading activity, you may pay more or less by using our wrap
fee services than you would pay if using a non-wrap account.
Regulatory Assets Under Management
As of December 31, 2025, we provide continuous management services for $868,922,370 in client
assets managed on a discretionary basis. We also manage $9,700,000 in client assets on a non-
continuous basis.
A. Our Wrap Advisory Services
Comprehensive Portfolio Management Wrap Program ("Wrap Fee Program")
We offer discretionary portfolio management services through our Wrap Fee Program. Our investment
advice is tailored to meet our clients' needs and investment objectives.
As part of our portfolio management services, in addition to other types of investments (see
disclosures below in this section), we will invest your assets according to one or more model portfolios
developed by our firm. These models are designed for investors with varying degrees of risk tolerance
ranging from a more aggressive investment strategy to a more conservative investment approach.
Financial Planning
Clients participating in the Wrap Comprehensive Portfolio Management Program also receive financial
planning.
Based upon an analysis of current situation, goals, and objectives, financial planning services will
typically 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 investment
planning, retirement planning, estate planning, charitable planning, education planning, corporate and
personal tax planning, cost segregation study, corporate structure, real estate analysis, mortgage/debt
analysis, insurance analysis, lines of credit evaluation, or business and personal financial planning.
Written financial plans or financial consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the clients. Implementation
of the recommendations will be at the discretion of the client. Our firm provides clients with a summary
of their financial situation, and observations for financial planning engagements. Financial
consultations are not typically accompanied by a written summary of observations and
recommendations, as the process is less formal than the planning service. Assuming that all the
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information and documents requested from the client are provided promptly, plans or consultations are
typically completed within 6 months of the client signing a contract with our firm. Clients are under no
obligation to use our firm, or its representatives, for the implementation of any part of the financial plan.
Program Fee
Our annual fee for the Wrap Fee Program does not exceed 1.75% ("Program" or "Advisory" Fee)
depending upon the market value of your assets under our management and the type and complexity
of the asset management services provided. Assets in each of your advisory accounts are included in
the fee assessment unless specifically identified in writing for exclusion. Our annual Program Fee is
billed and payable, quarterly in arrears, based on the balance at end of billing period. The specific fee
we agree on is outlined in your Portfolio Management Agreement.
Program fees are calculated based on the exact number of days in the quarter. For example a client
with a fee of 1% and an account value of $500,000 will pay fees for the second quarter (91 days)
based on the following calculation: ((500,000 X 1%) / 365) * 91 = $1246.58.
The fees charged are calculated as described above, and are not charged on the basis of a share of
capital gains upon, or capital appreciation of, the funds, or any portion of the funds of an advisory
Client (15 U.S.C.§80b-5(a)(1)). Our fees are negotiable at our discretion. Fees are based on such
things as the overall complexity of your financial situation and your financial planning, as well as the
account value and number of accounts. A portion of the fee received is paid to your financial
professional. The cost for financial planning is included in the Program Fee you pay to us on a
quarterly basis.
B. Wrap Programs May Cost you More
Participation in a wrap program may cost you more or less than purchasing the services separately
and paying transaction/trading costs in addition to an Program Fee.
C. Other Costs Not Included in Your Program Fee
The Program Fee includes the costs of brokerage commissions for transactions executed through the
Qualified Custodian (or a broker-dealer designated by the Qualified Custodian), and charges relating to
the settlement, clearance, or custody of securities in the Account. The Program Fee does not include
mark-ups and mark-downs, dealer spreads or other costs associated with the purchase or sale of
securities, interest, taxes, or other costs, such as national securities exchange fees, charges for
transactions not executed through the Qualified Custodian, costs associated with exchanging
currencies, wire transfer fees, or other fees required by law or imposed by third parties. The Account
will be responsible for these additional fees and expenses.
In addition to our Program Fees above, clients also pay charges imposed directly by a mutual fund,
index fund, or ETF as disclosed in the fund's prospectus. These are typically fund management fees,
initial or deferred sales charges, mutual fund sales loads, 12b-1 fees, surrender charges, and other
fund expenses. In addition, the custodian may charge mark-ups and mark-downs, spreads paid to
market makers, fees for trades executed away from custodian, wire transfer fees and other fees and
taxes on brokerage accounts and securities transactions. Our firm does not receive a portion of these
fees. You will also pay annual account fees for some accounts such as IRAs or retirement accounts.
Upon account opening, you will receive a list of fees from PAS. You should retain this list for future
reference.
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D. Compensation is Shared with your Financial Professional
Your financial professional will receive a portion of the fee you pay to us. As a client, you should be
aware that the wrap fee charged by our firm may be higher (or lower) than those charged by others in
the industry, and that it may be possible to obtain the same or similar services from other firms at lower
(or higher) rates. A client may be able to obtain some or all of the types of services available through
our firm's wrap fee program on an individual basis through other firms and, depending on the
circumstances, the aggregate of any separately paid fees may be lower or higher than the annual fees
shown above. This presents a conflict of interest as your financial professional may earn more than if
a non-wrap account option was presented.
Termination of Advisory Agreements
Subject to the terms of any Wrap Fee Program Agreement ("Agreement"), the Agreement may be
terminated by the Client or us upon written notice to the other. If the Agreement is terminated after the
effective date, any prepaid, but unearned Advisory Fees for the final calendar period of the Agreement
shall be prorated based on the number of days the Agreement was in effect during such calendar
period. The prepaid, unearned portion of the Advisory Fees, if any, shall be refunded to Client within 30
days. Any earned but unpaid Advisory Fees owed to Bridgewealth will become immediately due and
payable upon termination of the Agreement.
After an Agreement has been terminated, Client will be charged commissions, sales charges, and
transaction, clearance, settlement, and custodial charges, at prevailing rates, by the Custodian and
any executing or carrying broker-dealer. Client will be responsible for monitoring all transactions and
assets, and Bridgewealth has no obligation to monitor or make recommendations with respect to any
account or assets.
Types of Investments
Managed accounts are invested in a portfolio allocated among various asset classes as appropriate for
your financial situation. The investment types include mutual funds, money market funds, closed-end
funds, exchange-traded funds ("ETFs"), common and preferred stocks, real estate investment trusts
("REITs"), business development companies, non-traded closed end funds, and direct obligations
issued or guaranteed by the U.S. Treasury, government agencies, or government sponsored entities. If
appropriate, "sweep" arrangements are used where cash balances are transferred into money market
funds. money market deposit accounts, or bank accounts for cash management purposes, which may
be advised by or maintained with the account's qualified custodian ("Custodian") or an affiliate of the
Custodian. Not all investment types are appropriate for all clients and selections are made based on
the client's individual risk tolerance, investment objectives, investment experience and their financial
situation and goals.
In addition, we sometimes offer interval funds as a suitable investment for some clients. These funds
impose liquidity restrictions and offer periodic repurchase options to their shareholders of three, six or
twelve months.
Investment Discretion
For clients in our Wrap Fee Program, Bridgewealth must be provided with investment discretion on
behalf of the client, pursuant to an executed advisory agreement and any documentation required by
the selected Custodian. By granting investment discretion, our firm is authorized to execute securities
transactions, determine which securities, and the amount of those securities, that will be bought and
sold. Discretionary authority is typically granted by the investment advisory agreement you sign with
our firm, a power of attorney, or trading authorization forms from the Custodian.
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Custodian for Wrap Accounts
We recommend the brokerage and custodial services of Pershing Advisor Solutions LLC ("PAS" or
"Custodian"). Per SEC regulations, your assets must be maintained in an account at a "qualified
custodian," generally a broker-dealer or bank. PAS meets these requirements to serve as a qualified
custodian. In recognition of the value of the services the Custodian provides, you may pay
higher account costs than those available elsewhere. Our selection of PAS is based on many factors,
including the level of services provided, the custodian's financial stability, and the cost of services
provided by the custodian to our clients, which includes the yield on cash sweep choices,
commissions, custody fees and other fees or expenses.
While you are free to choose any broker-dealer or other service provider as your custodian, we
recommend that you establish an account with PAS. We may not be able to manage your investments
if you select another custodian. PAS provides benefits to our firm, including but not limited to market
information and administrative services that help our firm manage client accounts. We believe
that PAS provides quality execution services for our clients at competitive prices but do not rely on
price as the sole factor for our consideration in evaluating best execution. We also consider the quality
of the brokerage services provided by PAS, including the value of the firm's reputation, execution
capabilities, commission rates, and responsiveness to our clients and our firm. In recognition of the
value of the services provided by PAS, you may pay higher commissions and/or trading costs than
those that may be available elsewhere.
Account Reviews
We send quarterly reports to some clients. Verbal reports to clients take place on at least an annual
basis when our wrap account clients are contacted. In addition, clients have the ability to sign into their
client portal on Black Diamond to view reports provided by Bridgewealth.
We strongly suggest meeting in-person, on the telephone, or via electronic means at least once a year
to review your accounts together, learn if your financial situation has changed, and to determine if
changes need made to your current holdings. We realize that some clients prefer to meet less
frequently.
Item 5 Account Requirements and Types of Clients
Minimum Account Size and Program Fee
Bridgewealth does not impose a minimum account size or a minimum annual Program Fee.
Types of Clients
Wrap Fee Program clients are comprised of individuals, high net worth individuals and their families,
trusts, estates or charitable organizations, retirement plans, and small businesses.
Item 6 Portfolio Manager Selection and Evaluation
A. Selection and Review of Portfolio Managers
Our firm's investment adviser representatives, also referred to as financial professionals, act as
portfolio managers for this Wrap Fee Program. Other investment advisory firms may charge the same
or lower fees than our firm for similar services. We do not recommend the services of other portfolio
managers.
1. We do not calculate the performance of our portfolio managers or compare their performance
against other unaffiliated portfolio managers.
2. The performance information for clients' accounts is calculated by an independent third party
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through technology we have purchased. We do not verify or validate its accuracy.
3. We do not review our portfolio managers' performance information and believe it is calculated
on a uniform and consistent basis.
B. Our Related Persons Act as Portfolio Managers
Our financial professionals serve as the portfolio managers for clients' accounts. Because each
financial professional follows different investment strategies and styles, and adjusts their investment
selections depending on their Clients' personal and financial situation, and the investment objective,
risk tolerance, liquidity needs, and investment time horizon of the account they are
managing. Consequently, it is expected that the levels of volatility, fees, expenses, returns, and
performance will, and do, vary significantly among Managed Accounts managed by the same financial
professional and among accounts managed by different financial professionals.
Bridgewealth monitors client accounts, however, Bridgewealth does not direct or mandate the
investment strategies or styles used by the financial professionals. Since investment strategies and
advice are based on each client's specific financial situation, the investment advice provided to you is
often different or conflicting with the advice our financial professionals give to other Clients regarding
the same security or investment.
C. Performance-Based Fees & Side-By-Side Management:
Our firm does not charge performance-based fees or participate in side-by-side management.
Services Tailored to Individual Needs of Clients
Services provided through the Wrap Fee Program are tailored to the individual needs of the Client.
Clients participating in the Wrap Fee Program will provide account profile information about the Client's
financial and investment situation so the portfolio manager is able to develop a suitable model portfolio
for the Client. This account profile typically includes (to the extent relevant to the particular Client and
Managed Account), information about the Client's personal and family situation, investment
experience, and the investment objective, tolerance for risk, income and liquidity needs, investment
time horizon, and other factors requested by the financial professional.
Investment Restrictions
Clients may set reasonable restrictions on the investment of the assets in their wrap accounts,
including the types of securities that should not be purchased, or if already held, securities that should
not be sold. Bridgewealth must agree to these restrictions.
Non-Wrap Programs
Bridgewealth does not offer non-wrap portfolio management services its clients.
We Receive a Portion of Your Program Fee
As the portfolio manager and sponsor of the Wrap Fee Program, Bridgewealth receives a portion of the
Program Fee you pay us. And as disclosed, we also share a portion of the Program Fee with your
financial professional. We also pay the transaction/trading costs charged by the custodian from your
Program Fee.
Voting Client Securities
Our firm does not accept the proxy authority to vote client securities. Clients will receive proxies or
other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to
our firm, our firm will forward them to the appropriate client and ask the party who sent them to mail
them directly to the client in the future. Clients may call, write or email us to discuss questions they
may have about particular proxy votes or other solicitations.
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Class Action Lawsuits
Similarly, we do not advise or exercise rights, make elections, or take other actions with respect to
legal proceedings involving companies whose securities are or were held for a Client's account, such
as asserting claims or voting in bankruptcy or reorganization proceedings, or filing "proofs of claim" in
class action litigation.
If desired, a Client may instruct us in writing to forward to the Client or a third party any materials we
receive pertaining to such matters. Upon our receipt of such written instructions, we will use
reasonable efforts to forward such materials in a timely manner. In the absence of a written request,
we will discard such materials. Written instructions should be sent by email to ausdal@ausdal.com, or
by mail to the address shown on the cover page of this Brochure.
Methods of Analysis, Investment Strategies & Risk of Loss:
We use the following methods of analysis in formulating our investment advice and/or managing client
assets:
Fundamental Analysis: The analysis of a business's financial statements (usually to analyze the
business's assets, liabilities, and earnings), health, and its competitors and markets. When analyzing a
stock, futures contract, or currency using fundamental analysis there are two basic approaches one
can use: bottom up analysis and top down analysis. The terms are used to distinguish such analysis
from other types of investment analysis, such as quantitative and technical. Fundamental analysis is
performed on historical and present data, but with the goal of making financial forecasts. There are
several possible objectives: (a) to conduct a company stock valuation and predict its probable price
evolution; (b) to make a projection on its business performance; (c) to evaluate its management and
make internal business decisions; (d) and/or to calculate its credit risk.; and (e) to find out the intrinsic
value of the share.
When the objective of the analysis is to determine what stock to buy and at what price, there are two
basic methodologies investors rely upon: (a) Fundamental analysis maintains that markets may
misprice a security in the short run but that the "correct" price will eventually be reached. Profits can be
made by purchasing the mispriced security and then waiting for the market to recognize its "mistake"
and reprice the security.; and (b) Technical analysis maintains that all information is reflected already
in the price of a security. Technical analysts analyze trends and believe that sentiment changes
predate and predict trend changes. Investors' emotional responses to price movements lead to
recognizable price chart patterns. Technical analysts also analyze historical trends to predict future
price movement. Investors can use one or both of these different but complementary methods for stock
picking. This presents a potential risk, as the price of a security can move up or down along with the
overall market regardless of the economic and financial factors considered in evaluating the stock.
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:
Alternative Investments: Hedge funds, commodity pools, Real Estate Investment Trusts ("REITs"),
Business Development Companies ("BDCs"), and other alternative investments involve a high degree
of risk and can be illiquid due to restrictions on transfer and lack of a secondary trading market. They
can be highly leveraged, speculative and volatile, and an investor could lose all or a substantial
amount of an investment. Alternative investments may lack transparency as to share price, valuation
and portfolio holdings. Complex tax structures often result in delayed tax reporting. Compared to
mutual funds, hedge funds and commodity pools are subject to less regulation and often charge higher
fees. Alternative investment managers typically exercise broad investment discretion and may apply
similar strategies across multiple investment vehicles, resulting in less diversification.
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Asset Allocation: The implementation of an investment strategy that attempts to balance risk versus
reward by adjusting the percentage of each asset in an investment portfolio according to the investor's
risk tolerance, goals and investment time frame. Asset allocation is based on the principle that different
assets perform differently in different market and economic conditions. A fundamental justification for
asset allocation is the notion that different asset classes offer returns that are not perfectly correlated,
hence diversification reduces the overall risk in terms of the variability of returns for a given level of
expected return. Although risk is reduced as long as correlations are not perfect, it is typically forecast
(wholly or in part) based on statistical relationships (like correlation and variance) that existed over
some past period. Expectations for return are often derived in the same way.
An asset class is a group of economic resources sharing similar characteristics, such as risk and
return. There are many types of assets that may or may not be included in an asset allocation strategy.
The "traditional" asset classes are stocks (value, dividend, growth, or sector-specific or a "blend" of any
two or more of the preceding; large-cap versus mid-cap, small-cap or micro-cap; domestic, foreign
(developed, emerging or frontier markets), bonds (fixed income securities more generally investment-
grade or high-yield; government or corporate; short-term, intermediate, long-term; domestic, foreign,
emerging markets), and cash or cash equivalents. Allocation among these three provides a starting
point.
There are several types of asset allocation strategies based on investment goals, risk tolerance, time
frames and diversification. The most common forms of asset allocation are: strategic, dynamic, tactical,
and core-satellite.
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. Bonds with longer rates of maturity tend
to have greater interest rate risks.
Certain additional risk factors relating to debt securities include: (a) When interest rates are declining,
investors have to reinvest their interest income and any return of principal, whether scheduled or
unscheduled, at lower prevailing rates.; (b) Inflation causes tomorrow's dollar to be worth less than
today's; in other words, it reduces the purchasing power of a bond investor's future interest payments
and principal, collectively known as "cash flows." Inflation also leads to higher interest rates, which in
turn leads to lower bond prices.; (c) Debt securities may be sensitive to economic changes, political
and corporate developments, and interest rate changes. Investors can also expect periods of
economic change and uncertainty, which can result in increased volatility of market prices and yields of
certain debt securities. For example, 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. (d) Debt securities may contain redemption or call provisions entitling their issuers to redeem
them at a specified price on a date prior to maturity. If an issuer exercises these provisions in a lower
interest rate market, the account would have to replace the security with a lower yielding security,
resulting in decreased income to investors. Usually, a bond is called at or close to par value. This
subjects investors that paid a premium for their bond risk of lost principal. In reality, prices of callable
bonds are unlikely to move much above the call price if lower interest rates make the bond likely to be
called.; (e) If the issuer of a debt security defaults on its obligations to pay interest or principal or is the
subject of bankruptcy proceedings, the account may incur losses or expenses in seeking recovery of
amounts owed to it.; (f) There may be little trading in the secondary market for particular debt
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securities, which may affect adversely the account's ability to value accurately or dispose of such debt
securities. Adverse publicity and investor perceptions, whether or not based on fundamental analysis,
may decrease the value and/or liquidity of debt securities.
Our firm attempts to reduce the risks described above through diversification of the client's portfolio
and by credit analysis of each issuer, as well as by monitoring broad economic trends and corporate
and legislative developments, but there can be no assurance that our firm will be successful in doing
so. Credit ratings for debt securities provided by rating agencies reflect an evaluation of the safety of
principal and interest payments, not market value risk. The rating of an issuer is a rating agency's view
of past and future potential developments related to the issuer and may not necessarily reflect actual
outcomes. There can be a lag between the time of developments relating to an issuer and the time a
rating is assigned and updated.
Exchange Traded Funds ("ETFs"): An ETF is a type of Investment Company (usually, an open-end
fund or unit investment trust) whose primary objective is to achieve the same return as a particular
market index. The vast majority of ETFs are designed to track an index, so their performance is close
to that of an index mutual fund, but they are not exact duplicates. A tracking error, or the difference
between the returns of a fund and the returns of the index, can arise due to differences in composition,
management fees, expenses, and handling of dividends. ETFs benefit from continuous pricing; they
can be bought and sold on a stock exchange throughout the trading day. Because ETFs trade like
stocks, you can place orders just like with individual stocks - such as limit orders, good- until-canceled
orders, stop loss orders etc. They can also be sold short. Traditional mutual funds are bought and
redeemed based on their net asset values ("NAV") at the end of the day. ETFs are bought and sold at
the market prices on the exchanges, which resemble the underlying NAV but are independent of it.
However, arbitrageurs will ensure that ETF prices are kept very close to the NAV of the underlying
securities. Although an investor can buy as few as one share of an ETF, most buy in board lots.
Anything bought in less than a board lot will increase the cost to the investor. Anyone can buy any ETF
no matter where in the world it trades. This provides a benefit over mutual funds, which generally can
only be bought in the country in which they are registered.
One of the main features of ETFs are their low annual fees, especially when compared to traditional
mutual funds. The passive nature of index investing, reduced marketing, and distribution and
accounting expenses all contribute to the lower fees. However, individual investors must pay a
brokerage commission to purchase and sell ETF shares; for those investors who trade frequently, this
can significantly increase the cost of investing in ETFs. That said, with the advent of low-cost
brokerage fees, small or frequent purchases of ETFs are becoming more cost efficient.
Fixed Income: Fixed income is a type of investing or budgeting style for which real return rates or
periodic income is received at regular intervals and at reasonably predictable levels. Fixed income
investors are typically retired individuals who rely on their investments to provide a regular, stable
income stream. This demographic tends to invest heavily in fixed income investments because of the
reliable returns they offer. Fixed income investors who live on set amounts of periodically paid income
face the risk of inflation eroding their spending power.
Some examples of fixed income investments include treasuries, money market instruments, corporate
bonds, asset-backed securities, municipal bonds and international bonds. The primary risk associated
with fixed income investments is the borrower defaulting on his payment. Other considerations include
exchange rate risk for international bonds and interest rate risk for longer-dated securities. The most
common type of fixed income security is a bond. Bonds are issued by federal governments, local
municipalities and major corporations. Fixed income securities are recommended for investors seeking
a diverse portfolio; however, the percentage of the portfolio dedicated to fixed income depends on your
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own personal investment style. There is also an opportunity to diversify the fixed income component of
a portfolio. Riskier fixed income products, such as junk bonds and longer-dated products, should
comprise a lower percentage of your overall portfolio.
The interest payment on fixed income securities is considered regular income and is determined based
on the creditworthiness of the borrower and current market rates. In general, bonds and fixed income
securities with longer-dated maturities pay a higher rate, also referred to as the coupon rate, because
they are considered riskier. The longer the security is on the market, the more time it has to lose its
value and/or default. At the end of the bond term, or at bond maturity, the borrower returns the amount
borrowed, also referred to as the principal or par value.
Stocks: A common stock is a security that represents ownership in a corporation. Holders of common
stock exercise control by electing a board of directors and voting on corporate policy. Investing in
individual common stocks provides us with more control of what you are invested in and when that
investment is made. Having the ability to decide when to buy or sell helps us time the taking of gains or
losses. Common stocks, however, bear a greater amount of risk when compared to certificate of
deposits, preferred stock and bonds. It is typically more difficult to achieve diversification when
investing in individual common stocks. Additionally, common stockholders are on the bottom of the
priority ladder for ownership structure; if a company goes bankrupt, the common stockholders do not
receive their money until the creditors and preferred shareholders have received their respective share
of the leftover assets.
Long-Term Purchases: Our firm may buy securities for your account and hold them for a relatively long
time (more than a year) in anticipation that the security's value will appreciate over a long horizon. The
risk of this strategy is that our firm could miss out on potential short-term gains that could have been
profitable to your account, or it's possible that the security's value may decline sharply before our firm
make a decision to sell.
Margin Transactions: You may purchase stocks, mutual funds, and/or other securities for your portfolio
with money borrowed from your brokerage account on margin. We do not recommend the use of
margin in your advisory accounts and do not charge advisory fees on the margin balance, should you
choose to do so. This allows you to purchase more stock than you would be able to with your
available cash, and allows us to purchase stock without selling other holdings. Margin accounts and
transactions are risky and not appropriate for every client. The potential risks associated with these
transactions are (1) You can lose more funds than are deposited into the margin account; (2) the
forced sale of securities or other assets in your account; (3) the sale of securities or other assets
without contacting you; and (4) you may not be entitled to choose which securities or other assets in
your account(s) are liquidated or sold to meet a margin call.
Mutual Funds: A mutual fund is a company that pools money from many investors and invests the
money in a variety of differing security types based the objectives of the fund. The portfolio of the fund
consists of the combined holdings it owns. Each share represents an investor's proportionate
ownership of the fund's holdings and the income those holdings generate. The price that investors pay
for mutual fund shares is the fund's per share net asset value ("NAV") plus any shareholder fees that
the fund imposes at the time of purchase (such as sales loads). Investors typically cannot ascertain the
exact make-up of a fund's portfolio at any given time, nor can they directly influence which securities
the fund manager buys and sells or the timing of those trades. With an individual stock, investors can
obtain real-time (or close to real-time) pricing information with relative ease by checking financial
websites or by calling a broker or your investment adviser. Investors can also monitor how a stock's
price changes from hour to hour—or even second to second. By contrast, with a mutual fund, the price
at which an investor purchases or redeems shares will typically depend on the fund's NAV, which is
calculated daily after market close.
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The benefits of investing through mutual funds include: (a) Mutual funds are professionally managed
by an investment adviser who researches, selects, and monitors the performance of the securities
purchased by the fund; (b) Mutual funds typically have the benefit of diversification, which is an
investing strategy that generally sums up as "Don't put all your eggs in one basket." Spreading
investments across a wide range of companies and industry sectors can help lower the risk if a
company or sector fails. Some investors find it easier to achieve diversification through ownership of
mutual funds rather than through ownership of individual stocks or bonds.; (c) Some mutual funds
accommodate investors who do not have a lot of money to invest by setting relatively low dollar
amounts for initial purchases, subsequent monthly purchases, or both.; and (d) At any time, mutual
fund investors can readily redeem their shares at the current NAV, less any fees and charges
assessed on redemption.
Mutual funds also have features that some investors might view as disadvantages: (a) Investors must
pay sales charges, annual fees, and other expenses regardless of how the fund performs. Depending
on the timing of their investment, investors may also have to pay taxes on any capital gains distribution
they receive. This includes instances where the fund went on to perform poorly after purchasing
shares; (b) Investors typically cannot ascertain the exact make-up of a fund's portfolio at any given
time, nor can they directly influence which securities the fund manager buys and sells or the timing of
those trades; and (c) With an individual stock, investors can obtain real-time (or close to real-time)
pricing information with relative ease by checking financial websites or by calling a broker or your
investment adviser. Investors can also monitor how a stock's price changes from hour to hour—or
even second to second. By contrast, with a mutual fund, the price at which an investor purchases or
redeems shares will typically depend on the fund's NAV, which the fund might not calculate until many
hours after the investor placed the order. In general, mutual funds must calculate their NAV at least
once every business day, typically after the major U.S. exchanges close.
When investors buy and hold an individual stock or bond, the investor must pay income tax each year
on the dividends or interest the investor receives. However, the investor will not have to pay any capital
gains tax until the investor actually sells and makes a profit. Mutual funds are different. When an
investor buys and holds mutual fund shares, the investor will owe income tax on any ordinary
dividends in the year the investor receives or reinvests them. Moreover, in addition to owing taxes on
any personal capital gains when the investor sells shares, the investor may have to pay taxes each
year on the fund's capital gains. That is because the law requires mutual funds to distribute capital
gains to shareholders if they sell securities for a profit, and cannot use losses to offset these gains.
Interval Funds
An interval fund is a type of investment company that periodically offers to repurchase its shares from
shareholders. That is, the fund periodically offers to buy back a stated portionof its shares from
shareholders. Shareholders are not required to accept these offers and sell their shares back to the
fund.
Legally, interval funds are classified as closed-end funds, but they are very different from traditional
closed-end funds in that:
• Their shares typically do not trade on the secondary market. Instead, their shares are subject to
periodic repurchase offers by the fund at a price based on net asset value.
• They are permitted to (and many interval funds do) continuously offer their shares at a price
based on the fund's net asset value.
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An interval fund will make periodic repurchase offers to its shareholders, generally every three, six, or
twelve months, as disclosed in the fund's prospectus and annual report. The interval fund also will
periodically notify its shareholders of the upcoming repurchase dates. When the fund makes a
repurchase offer to its shareholders, it will specify a date by which shareholders must accept the
repurchase offer. The actual repurchase will occur at a later, specified date.
The price that shareholders will receive on a repurchase will be based on the per share NAV
determined as of a specified (and disclosed) date. This date will occur sometime after the close of
business on the date that shareholders must submit their acceptances of the repurchase offer (but
generally not more than 14 days after the acceptance date).
Note that interval funds are permitted to deduct a redemption fee from the repurchase proceeds, not to
exceed 2% of the proceeds. The fee is paid to the fund, and generally is intended to compensate the
fund for expenses directly related to the repurchase. Interval funds may charge other fees as well.
Interval funds are only suitable for certain Bridgewealth clients and the client must be comfortable with
the liquidity restrictions for the money they invest in interval funds. Full disclosure must be made to the
clients before the time of purchase and the recommendation must be in the client's best interest.
Options: An option is a financial derivative that represents a contract sold by one party (the option
writer) to another party (the option holder). The contract offers the buyer the right, but not the
obligation, to buy (call) or sell (put) a security or other financial asset at an agreed-upon price (the
strike price) during a certain period of time or on a specific date (exercise date). Options are extremely
versatile securities. Traders use options to speculate, which is a relatively risky practice, while hedgers
use options to reduce the risk of holding an asset. In terms of speculation, option buyers and writers
have conflicting views regarding the outlook on the performance of a:
• Call Option: Call options give the option to buy at certain price, so the buyer would want the
stock to go up. Conversely, the option writer needs to provide the underlying shares in the
event that the stock's market price exceeds the strike due to the contractual obligation. An
option writer who sells a call option believes that the underlying stock's price will drop relative to
the option's strike price during the life of the option, as that is how he will reap maximum profit.
This is exactly the opposite outlook of the option buyer. The buyer believes that the underlying
stock will rise; if this happens, the buyer will be able to acquire the stock for a lower price and
then sell it for a profit. However, if the underlying stock does not close above the strike price on
the expiration date, the option buyer would lose the premium paid for the call option.
• Put Option: Put options give the option to sell at a certain price, so the buyer would want the
stock to go down. The opposite is true for put option writers. For example, a put option buyer is
bearish on the underlying stock and believes its market price will fall below the specified strike
price on or before a specified date. On the other hand, an option writer who shorts a put option
believes the underlying stock's price will increase about a specified price on or before the
expiration date. If the underlying stock's price closes above the specified strike price on the
expiration date, the put option writer's maximum profit is achieved. Conversely, a put option
holder would only benefit from a fall in the underlying stock's price below the strike price. If the
underlying stock's price falls below the strike price, the put option writer is obligated to purchase
shares of the underlying stock at the strike price.
The potential risks associated with these transactions are that (1) all options expire. The closer the
option gets to expiration, the quicker the premium in the option deteriorates; and (2) Prices can move
very quickly. Depending on factors such as time until expiration and the relationship of the stock price
to the option's strike price, small movements in a stock can translate into big movements in the
underlying options.
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Real Estate Investment Trusts ("REITs"): REITs primarily invest in real estate or real estate-related
loans. Equity REITs own real estate properties, while mortgage REITs hold construction, development
and/or long-term mortgage loans. Changes in the value of the underlying property of the trusts, the
creditworthiness of the issuer, property taxes, interest rates, tax laws, and regulatory requirements,
such as those relating to the environment all can affect the values of REITs. Both types of REITs are
dependent upon management skill, the cash flows generated by their holdings, the real estate market
in general, and the possibility of failing to qualify for any applicable pass- through tax treatment or
failing to maintain any applicable exemptive status afforded under relevant laws.
Short Sales: A short sale is a transaction in which an investor sells borrowed securities in anticipation
of a price decline and is required to return an equal number of shares at some point in the future.
These transactions have a number of risks that make it highly unsuitable for the novice investor. This
strategy has a slanted payoff ratio in that the maximum gain (which would occur if the shorted stock
was to plunge to zero) is limited, but the maximum loss is theoretically infinite (since stocks can in
theory go up infinitely in price). The following risks should be considered: (1) In addition to trading
commissions, other costs with short selling include that of borrowing the security to short it, as well as
interest payable on the margin account that holds the shorted security. (2) The short seller is
responsible for making dividend payments on the shorted stock to the entity from whom the stock has
been borrowed. (3) Stocks with very high short interest may occasionally surge in price. This usually
happens when there is a positive development in the stock, which forces short sellers to buy the
shares back to close their short positions. Heavily shorted stocks are also susceptible to "buy-ins,"
which occur when a broker closes out short positions in a difficult-to-borrow stock whose lenders are
demanding it back. (4) Regulators may impose bans on short sales in a specific sector or even in the
broad market to avoid panic and unwarranted selling pressure. Such actions can cause a spike in
stock prices, forcing the short seller to cover short positions at huge losses. (5) Unlike the "buy-and-
hold" investor who can afford to wait for an investment to work out, the short seller does not have the
luxury of time because of the many costs and risks associated with short selling. Timing is everything
when it comes to shorting. (5) Short selling should only be undertaken by experienced traders who
have the discipline to cut a losing short position, rather than add to it hoping that it will eventually work
out.
Short-Term Purchases: When utilizing this strategy, our firm may also purchase securities with the idea
of selling them within a relatively short time (typically a year or less). Our firm does this in an attempt to
take advantage of conditions that our firm believes will soon result in a price swing in the securities our
firm purchase.
Please Note: Investing in securities involves risk of loss that clients should be prepared to bear. While
changes in the stock market may cause gains in your account(s), it is also possible that changes in the
stock market may cause losses in your account(s). It is important that you understand the risks
associated with investing in the stock market, are appropriately diversified in your investments, and ask
any questions you may have.
Company Risk: When investing in stock positions, there is always a certain level of company or
industry specific risk that is inherent in each investment. This is also referred to as unsystematic risk
and can be reduced through appropriate diversification. There is the risk that the company will perform
poorly or have its value reduced based on factors specific to the company or its industry. For example,
if a company's employees go on strike or the company receives unfavorable media attention for its
actions, the value of the company may be reduced.
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Credit Risk: Credit risk can be a factor in situations where an investment's performance relies on a
borrower's repayment of borrowed funds. With credit risk, an investor can experience a loss or
unfavorable performance if a borrower does not repay the borrowed funds as expected or required.
Investment holdings that involve forms of indebtedness (i.e. borrowed funds) are subject to credit risk.
Defensive Strategy Risk: Defensive strategies are primarily used in periods of high volatility or
economic uncertainty and aimed at reducing exposure to the equity market. Our goal is simply to help
our clients achieve their financial goals, regardless of market conditions. If our firm forecasts a
prolonged and substantial downturn for the equity markets, it may adopt a defensive strategy for
clients' growth allocation by investing substantially in money market securities and/or short term fixed
income securities. There can be no guarantee that our firm will accurately forecast any prolonged and
substantial downturn in the equity markets, or that the use defensive techniques would be successful
in avoiding losses. The use of defensive strategies could result in a negative outcome for a client. A
few negative consequences could be high turnover, re-entry in the same security at a higher price, loss
of growth if the equity markets move up, high tax liability within taxable accounts and higher trading
cost.
Economic Risk: The prevailing economic environment is important to the health of all businesses.
Some companies, however, are more sensitive to changes in the domestic or global economy than
others. These types of companies are often referred to as cyclical businesses. Countries in which a
large portion of businesses are in cyclical industries are thus also very economically sensitive and
carry a higher amount of economic risk. If an investment is issued by a party located in a country that
experiences wide swings from an economic standpoint or in situations where certain elements of an
investment instrument are hinged on dealings in such countries, the investment instrument will
generally be subject to a higher level of economic risk.
ETF & Mutual Fund Risk: When investing in an ETF or mutual fund, you will bear additional expenses
based on your pro rata share of the ETF's or mutual fund's operating expenses, including the potential
duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks
of owning the underlying securities the ETF or mutual fund holds. Clients will also incur brokerage
costs when purchasing ETFs.
Fixed Income Securities Risk: Typically, the values of fixed-income securities change inversely with
prevailing interest rates. Therefore, a fundamental risk of fixed-income securities is interest rate risk,
which is the risk that their value will generally decline as prevailing interest rates rise, which may cause
your account value to likewise decrease, and vice versa. How specific fixed income securities may
react to changes in interest rates will depend on the specific characteristics of each security. Fixed-
income securities are also subject to credit risk, prepayment risk, valuation risk, and liquidity risk.
Credit risk is the chance that a bond issuer will fail to pay interest and principal in a timely manner, or
that negative perceptions of the issuer's ability to make such payments will cause the price of a bond to
decline.
Liquidity Risk: Certain assets may not be readily converted into cash or may have a very limited market
in which they trade. Thus, you may experience the risk that your investment or assets within your
investment may not be able to be liquidated quickly, thus, extending the period of time by which you
may receive the proceeds from your investment. Liquidity risk can also result in unfavorable pricing
when exiting (i.e. not being able to quickly get out of an investment before the price drops significantly)
a particular investment and therefore, can have a negative impact on investment returns.
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Operational Risk: Operational risk can be experienced when an issuer of an investment product is
unable to carry out the business it has planned to execute. Operational risk can be experienced as a
result of human failure, operational inefficiencies, system failures, or the failure of other processes
critical to the business operations of the issuer or counter party to the investment.
Options Risk: Options on securities may be subject to greater fluctuations in value than an investment
in the underlying securities. Purchasing and writing put and call options are highly specialized activities
and entail greater than ordinary investment risks.
Past Performance: Charting and technical analysis are often used interchangeably. Technical analysis
generally attempts to forecast an investment's future potential by analyzing its past performance and
other related statistics. In particular, technical analysis often times involves an evaluation of historical
pricing and volume of a particular security for the purpose of forecasting where future price and volume
figures may go. As with any investment analysis method, technical analysis runs the risk of not
knowing the future and thus, investors should realize that even the most diligent and thorough
technical analysis cannot predict or guarantee the future performance of any particular investment
instrument or issuer thereof.
Strategy Risk: There is no guarantee that the investment strategies discussed herein will work under
all market conditions and each investor should evaluate his/her ability to maintain any investment
he/she is considering in light of his/her own investment time horizon. Investments are subject to risk,
including possible loss of principal.
Item 7 Client Information Provided to Portfolio Managers
Client information is not shared with outside portfolio managers since our financial professionals serve
as the portfolio manager.
Item 8 Client Contact with Portfolio Managers
The Client's contact regarding their wrap account is the Client's financial professional. The financial
professional will be available to answer questions about administration of the account and its
investments.
Item 9 Additional Information
Disciplinary Information
There are no legal or disciplinary events to disclose. Free and simple tools are available to research
firms and financial professionals at Investor.gov/CRS, which also provides educational materials about
broker-dealers, investment advisers, and investing.
Financial Industry Activities & Affiliations
Representatives of our firm are registered representatives of APW Capital, Inc., member FINRA/SIPC,
and licensed insurance agents. As a result of these transactions, they receive normal and customary
commissions for transactions done outside of your advisory accounts. A conflict of interest exists as
these commissionable securities sales create an incentive to recommend products based on the
compensation earned. To mitigate this potential conflict, our firm will act in the client's best interest.
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Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
As a fiduciary, it is an investment adviser's responsibility to provide fair and full disclosure of all
material facts and to act solely in the best interest of each of our clients at all times. Our fiduciary duty
is the underlying principle for our firm's Code of Ethics, which includes procedures for personal
securities transaction and insider trading. Our firm requires all representatives to conduct business with
the highest level of ethical standards and to comply with all federal and state securities laws at all
times. Upon employment with our firm, and at least annually thereafter, all representatives of our firm
will acknowledge receipt, understanding and compliance with our firm's Code of Ethics. Our firm and
representatives must conduct business in an honest, ethical, and fair manner and avoid all
circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients.
This disclosure is provided to give all clients a summary of our Code of Ethics. If a client or a potential
client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon request.
Our firm recognizes that the personal investment transactions of our representatives demands the
application of a Code of Ethics with high standards and requires that all such transactions be carried
out in a way that does not endanger the interest of any client. At the same time, our firm also believes
that if investment goals are similar for clients and for our representatives, it is logical, and even
desirable, that there be common ownership of some securities.
In order to prevent conflicts of interest, our firm has established procedures for transactions effected by
our representatives for their personal accounts. In order to monitor compliance with our personal
trading policy, our firm has pre-clearance requirements for IPOs and private placements, and a
quarterly securities transaction reporting system for all of our representatives.
Neither our firm nor a related person recommends, buys or sells for client accounts, securities in which
our firm or a related person has a material financial interest without prior disclosure to the client.
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.
Likewise, related persons of our firm buy or sell securities for themselves at or about the same time
they buy or sell the same securities for client accounts. In order to minimize this conflict of interest, our
related persons will place client interests ahead of their own interests and adhere to our firm's Code of
Ethics, a copy of which is available upon request. Further, our related persons will refrain from buying
or selling the same securities prior to buying or selling for our clients in the same day. If related
persons' accounts are included in a block trade, our related persons will always trade personal
accounts last.
Review of Accounts
Our management personnel or financial advisors review accounts on at least a semi-annual basis for
our Wrap Comprehensive Portfolio Management clients. 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. Our firm 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. Our firm provides
quarterly reports to clients. In addition, other reports are provided during client meetings. You also
have the ability to receive a copy of your current account information.
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We strongly suggest meeting in-person, on the telephone, or via electronic means such as Skype,
Facetime, Zoom or Teams, at least once a year so we may review your accounts with you, learn if your
financial situation has changed, and determine if changes need made to your current holdings. We
realize that some clients prefer to meet less frequently and will honor this request.
Client Referrals
Our firm does not directly or indirectly compensate anyone for client referrals, nor does it receive direct
or indirect compensation from anyone for client referrals.
Financial Information
Our firm is not required to provide additional financial information because:
• Our firm does not require the prepayment of more than $1,200 in fees more than 6 months in
advance.
• Our firm does not have a financial condition or commitment that impairs our ability to meet
contractual and fiduciary obligations to clients.
• Our firm has never been the subject of a bankruptcy proceeding.
Aggregated Trades
Transactions for each client generally will be effected independently, unless we decide to purchase or
sell the same securities for several clients at approximately the same time. We may, but are not
obligated to, combine multiple orders for shares of the same securities purchased for advisory
accounts we manage (this practice is commonly referred to as "aggregated trading"). We will then
distribute a portion of the shares to participating accounts in a fair and equitable manner. Generally,
participating accounts will pay a fixed transaction cost regardless of the number of shares transacted.
In certain cases, each participating account pays an average price per share for all transactions and
pays a proportionate share of all transaction costs on any given day. In the event an order is only
partially filled, the shares will be allocated to participating accounts in a fair and equitable manner,
typically in proportion to the size of each client's order. Accounts owned by our firm or persons
associated with our firm may participate in aggregated trading with your accounts; however, they will
not be given preferential treatment.
We combine multiple orders for shares of the same securities purchased for discretionary accounts;
however, we do not combine orders for non-discretionary accounts. Accordingly, non-discretionary
accounts may pay different costs than discretionary accounts pay. If you enter into non-discretionary
arrangements with our firm, we may not be able to buy and sell the same quantities of securities for
you and you may pay higher commissions, fees, and/or transaction costs than clients who enter into
discretionary arrangements with our firm.
Mutual Fund Share Classes
Mutual funds are sold with different share classes, which carry different cost structures. Each available
share class is described in the mutual fund's prospectus. When we purchase, or recommend the
purchase of, mutual funds for a client, we select the share class that is deemed to be in the client's
best interest, taking into consideration cost, tax implications, and other factors. Typically we purchase
"no load" mutual funds for our clients which have lower internal costs than many other share classes.
Internal fees (costs) impact your rate of return. Higher internal fees have a negative effect on your
investment's rate of return over time. When the fund is available for purchase at net asset value, we
will purchase, or recommend the purchase of, the fund at net asset value. We also review the mutual
funds held in accounts that come under our management to determine whether a more beneficial
share class is available, considering cost, tax implications, and the impact of contingent deferred sales
charges.
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There are times when the best available mutual fund share class for a client has a transaction fee
imposed by the Custodian but a higher cost share class is sold without a transaction fee (i.e., no
transaction fee funds). Even if an additional transaction fee is imposed by the Custodian, if we believe
the share class with the transaction fee is in your best interests, we select that particular share class
for your account. In wrap accounts, we pay the transaction fees imposed by the Custodian - not you -
and always strive to purchase what is in your best interest - not ours. Paying transaction fees could
incentivize us not to trade as frequently as we would if we were not paying the transaction fees in your
wrap account but we strive to always manage your account in your best interest.
Cash Management Fees and Expenses
The Bank Deposit Sweep Program is a core account investment vehicle used to hold cash balances
awaiting reinvestment. The cash balance in a brokerage account at PAS will be automatically
deposited or "swept" into an interest-bearing Bank Deposit Sweep Program account.
An investment in a FDIC-Insured Deposit Program is protected by FDIC insurance and therefore not
protected by Securities Investor Protection Corporation (SIPC). An investment in a money market
mutual fund is not insured or guaranteed by the Federal Deposit Insured Corporation or any other
government agency but is protected by Securities Investor Protection Corporation (SIPC). Although the
funds seek to preserve the value of your investment at $1.00 per share, it is possible to lose money by
investment in the fund.
For additional information on any fund, including investment objectives, risks, charges, and expenses,
please consult the fund's prospectus. Contact your financial organization for the fund prospectus and
read it carefully before investing.
Bridgewealth generally invests Client's cash balances in money market funds, FDIC Insured
Certificates of Deposit, high-grade commercial paper and/or government backed debt instruments. If
possible, Bridgewealth will try to achieve a higher return on Client cash balances through relatively
low-risk and conservative investments. In most cases, at least a partial cash balance will be
maintained in a money market account so that Bridgewealth may debit advisory fees for services
rendered.
Electronic Delivery of Regulatory Notices and Correspondence
Upon written client authorization, Bridgewealth may deliver any required regulatory notices and
disclosures or correspondence via email. Bridgewealth shall have completed all delivery requirements
upon the forwarding of such document, disclosure, notice or correspondence to the Client's last
provided email address (or upon advising the Client via email that such document is available on
Bridgewealth's public website). Client may, at any time, notify Bridgewealth in writing that it does not
wish to receive electronic communications and instead wishes to receive paper communications for no
additional cost.
IRA Rollover Recommendations
For purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02")
where applicable, we are providing the following acknowledgment to you. When we provide
investment advice to you regarding your retirement plan account or individual retirement account, we
are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the
Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we
make money creates some conflicts with your interests, so we operate under a special rule that
requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's
provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent
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advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
We benefit financially from the rollover of your assets from a retirement account to an account that we
manage or provide investment advice, because the assets increase our assets under management
and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in
your best interest.
Custody
Our firm does not have custody of client funds or securities, other than the ability to withdraw our fees
from a client's account as mentioned in Item 5, Fees and Compensation, or as outlined below for third-
party standing letters of authorization. Our clients receive account statements directly from their
qualified custodian. We provide quarterly reports to most clients. These are in addition to the account
statements you receive from your custodian, and they are not meant as a replacement for your
custodian's statements.
Third-Party Standing Letters of Authorization ("SLOAs")
Our firm, or persons associated with our firm, may effect wire transfers from client accounts to one or
more third parties designated, in writing, by the client without obtaining written client consent for each
separate, individual transaction, as long as the client has provided us with written authorization to do
so. Such written authorization is known as a Standing Letter of Authorization provides authorization for
more than one transaction to the same third-party. An adviser with authority to conduct such third-
party transactions on a client\'s behalf technically has access to client assets under SEC regulations,
and therefore has custody of the client\'s assets in any related accounts.
We are not required to obtain a surprise annual audit as long as we meet the following criteria:
1. You provide a written, signed instruction to the qualified custodian that includes the third party's
name and address or account number at a custodian;
2. You authorize us in writing to direct transfers to the third party either on a specified schedule or
from time to time;
3. Your qualified custodian verifies your authorization (e.g., signature review) and provides a
transfer of funds notice to you promptly after each transfer;
4. You can terminate or change the instruction;
5. We have no authority or ability to designate or change the identity of the third party, the
address, or any other information about the third party;
6. We maintain records showing that the third party is not a related party to us nor located at the
same address as us; and
7. Your qualified custodian sends you, in writing, an initial notice confirming the instruction and an
annual notice reconfirming the instruction.
We hereby confirm that we meet the above criteria.
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