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WELLINGTON INVESTMENT ADVISORS WRAP BROCHURE
Wellington Investment Advisors (CRD 283853), brochure dated March 24, 2026. Text extracted from the firm's SEC Form ADV Part 2 brochure.
View firm on SEC ↗ · Current Form ADV (PDF) ↗
Wellington Investment Advisors
121 E. 6th Street
Suite 2
Bloomington, Indiana 47408
Telephone: 812-333-0874
March 24, 2026
www.wellingtoninvestmentadvisors.com
FORM ADV PART 2A - APPENDIX 1
WRAP BROCHURE
This brochure provides information about the qualifications and business practices of Wellington
Investment Advisors. If you have any questions about the contents of this brochure, contact us at 812-
333-0874. The information in this brochure has not been approved or verified by the United States
Securities and Exchange Commission (“SEC”) or by any state securities authority.
Additional information about Wellington Investment Advisors is available on the SEC's website at
www.adviserinfo.sec.gov.
Wellington Investment Advisors is a registered investment adviser. Registration with the SEC or any
state securities authority does not imply a certain level of skill or training.
Item 2 Summary of Material Changes
There have been no material changes to this Wrap Brochure since the date of the last annual
amendment noted below.
The material changes discussed above are only those changes that have been made to this brochure
since the firm’s last annual update of the brochure. The date of the last annual update of the brochure
was March 25, 2025.
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Item 3 Table of Contents
Item 2 Summary of Material Changes ................................................................................... 2
Item 3 Table of Contents ....................................................................................................... 3
Item 4 Services, Fees, and Compensation ............................................................................ 4
Item 5 Account Requirements and Types of Clients ............................................................. 6
Item 6 Portfolio Manager Selection and Evaluation ............................................................... 6
Item 7 Client Information Provided to Portfolio Managers ..................................................... 9
Item 8 Client Contact with Portfolio Managers ...................................................................... 9
Item 9 Additional Information ............................................................................................... 10
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Item 4 Services, Fees, and Compensation
Description of Firm
Wellington Investment Advisors is an SEC registered investment adviser (since June 2021) primarily
based in Bloomington, Indiana. We are organized as a corporation under the laws of the State of
Indiana. Prior to registration with the SEC, we had been providing investment advisory services since
2016 as a state registered investment advisor. Paul Bullock is the principal owner of the firm.
As used in this brochure, the words "we," "our," and "us" refer to Wellington Investment Advisors and
the words "you," "your," and "client" refer to you as a client or prospective client of our firm. Also, you
may see the term Associated Person in this brochure. Our Associated Persons are our firm's officers,
employees, and all individuals providing investment advice on behalf of our firm.
While we are a portfolio manager and sponsor to a wrap fee program, note that this wrap fee program
is no longer available to new clients of our firm.
We offer portfolio management services through a wrap-fee program ("Program") as described in this
wrap fee program brochure to existing clients. We are the sponsor and investment adviser for the
Program. A wrap-fee program is a type of investment program that provides clients with asset
management and brokerage services for one all-inclusive fee. If you participate in our wrap fee
program, you will pay our firm a single fee, which includes money management fees, certain
transaction costs, and custodial and administrative costs. You are not charged separate fees for the
respective components of the total services. We receive a portion of the wrap fee for our services. The
overall cost you will incur if you participate in our wrap fee program may be higher or lower than you
might incur by separately purchasing the types of securities available in the Program.
Prior to becoming a client under the Program, you will be required to enter into a separate written
agreement with us that sets forth the terms and conditions of the engagement and describes the scope
of the services to be provided, and the fees to be paid.
Client Investment Process
We provide discretionary and non-discretionary portfolio management services in accordance with
your individual investment objectives. If you participate in our discretionary portfolio management
services, we require you to grant our firm discretionary authority to manage your account. Subject to a
grant of discretionary authorization, we have the authority and responsibility to formulate investment
strategies on your behalf. This authorization includes deciding which securities to buy and sell, when to
buy and sell, and in what amounts, in accordance with your investment program, without obtaining
your prior consent or approval for each transaction. Discretionary authority is typically granted by the
investment advisory agreement you sign with our firm and/or through trading authorization forms. You
may limit our discretionary authority (for example, limiting the types of securities that can be purchased
for your account) by providing our firm with your restrictions and guidelines in writing.
This Program allows you to choose an investment option that employs a model portfolio developed by
our firm that is diversified among investment styles and/or asset classes. We will use the information
we gather to develop a strategy that enables our firm to customize an investment portfolio for you in
accordance with your risk tolerance and investment objectives. Once we construct an investment
portfolio for you, or select a model portfolio, we will monitor your portfolio's performance and re-
balance your investments as required by changes in market conditions and in your financial
circumstances.
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Wrap Fee
Our fee for portfolio management services is based on a percentage of your assets we
manage. Our advisory fees are based on the schedule below.
Assets Under Management Annual Fee
Up to $1,000,000
$1,000,001 to $2,000,000
$2,000,001 to $3,000,000
Over $3,000,000
2.0%
1.5%
1.0%
Negotiable
This fee is negotiable will be billed and payable quarterly in advance based on the account balance at
end of the billing period. If the portfolio management agreement is executed at any time other than the
first day of a calendar month, our fees will apply on a pro rata basis, which means that the advisory fee
is payable in proportion to the number of days in the month for which you are a client.
We will deduct our fee directly from your account through the qualified custodian holding your funds
and securities. We will deduct our advisory fee only when the following requirements are met:
• You provide our firm with written authorization permitting the fees to be paid directly from your
account held by the qualified custodian.
• The qualified custodian agrees to send you a statement, at least quarterly, indicating all
amounts dispersed from your account including the amount of the advisory fee paid directly to
our firm.
Since Wellington Investment Advisors wrap program does not include outside investment managers,
Wellington Investment Advisors retains all of the wrap program fee charged to clients.
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.
Additional Fees And Expenses
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.
The wrap program fees that you pay to our firm for portfolio management services are separate and
distinct from the fees and expenses charged by mutual funds, exchange traded funds, or variable
insurance products (described in each fund's or variable product’s prospectus) to their shareholders.
These fees will generally include a management fee and other fund or variable product’s expenses. To
fully understand the total cost you will incur, you should review all the fees charged by mutual funds,
exchange traded funds, our firm, and others.
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Wrap Fee Program Disclosures
• The benefits under a wrap fee program depend, in part, upon the size of the Account, the
management fee charged, and the number of transactions likely to be generated in the
Account. For example, a wrap fee program may not be suitable for Accounts with little trading
activity. In order to evaluate whether a wrap fee program is suitable for you, you should
compare the Program Fee and any other costs of the Program with the amounts that would be
charged by other advisers, broker-dealers, and custodians, for advisory fees, brokerage and
other execution costs, and custodial services comparable to those provided under the Program.
• As the Advisor absorbs certain transaction costs in wrap fee accounts, the Advisor may have a
financial incentive not to place transaction orders in those accounts since doing so increases its
transaction costs. Thus, an incentive exists to place trades less frequently in a wrap fee
arrangement.
• In considering the investment programs described in this brochure, you should be aware that
participating in a wrap fee program may cost more or less than the cost of purchasing advisory,
brokerage, and custodial services separately from other advisers or broker-dealers.
• Our firm and Associated Persons receive compensation as a result of your participation in the
Program. This compensation may be more than the amount our firm or the Associated Persons
would receive if you paid separately for investment advice, brokerage, and other services.
Accordingly, a conflict of interest exists because our firm and our Associated Persons have a
financial incentive to recommend the Program.
• Similar advisory services may be available from other registered investment advisers for lower
fees.
Investment advisor representatives of Wellington Investment Advisors are the individuals that
recommend to clients to invest in either our wrap program or non-wrap investment services. The
compensation of the investment advisor representatives does not vary for recommending the wrap
program versus our non-wrap services. Therefore, there is no compensation incentive to recommend
one program over another.
Item 5 Account Requirements and Types of Clients
We offer investment advisory services to individuals (other than high net worth individuals), high net
worth individuals, charitable organizations, corporations, and other business entities.
In general, we do not require a minimum dollar amount to open and maintain an advisory account;
however, we have the right to terminate your account if it falls below a minimum size which, in our sole
opinion, is too small to manage effectively.
We may also combine account values for you and your minor children, joint accounts with your
spouse, and other types of related accounts to meet the stated minimum.
Item 6 Portfolio Manager Selection and Evaluation
The wrap fee program at Wellington Investment Advisors is offered as a pricing option to clients. The
management of client portfolios, whether wrap or non-wrap is the same across all clients. And no
outside managers are used to manage our clients’ assets.
Each client is assigned a Wellington Investment Advisors investment advisor representative when they
become a client. Generally, the investment advisor representative will be the individual who introduces
the client to the firm. Each investment advisor representative at Wellington Investment Advisors is
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responsible for managing the investment accounts of their assigned clients. The Wellington
Investment Advisors investment advisor representative will monitor the client account on an ongoing
basis to ensure that the client needs, goals and objectives are being met.
Performance-Based Fees and Side-by-Side Management
We do not accept performance-based fees or participate in side-by-side management. Performance-
based fees are fees that are based on a share of capital gains or capital appreciation of a client's
account. Side-by-side management refers to the practice of managing accounts that are charged
performance-based fees while at the same time managing accounts that are not charged performance-
based fees. Our fees 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 in your advisory account.
Methods of Analysis, Investment Strategies and Risk of Loss
We may use one or more of the following methods of analysis or investment strategies when providing
investment advice to you:
Charting Analysis - involves the gathering and processing of price and volume pattern information for
a particular security, sector, broad index, or commodity. This price and volume pattern information is
analyzed. The resulting pattern and correlation data is used to detect departures from expected
performance and diversification and predict future price movements and trends.
• Risk: Our charting analysis may not accurately detect anomalies or predict future price
movements. Current prices of securities may reflect all information known about the security
and day-to-day changes in market prices of securities may follow random patterns and may not
be predictable with any reliable degree of accuracy.
Technical Analysis - involves studying past price patterns, trends, and interrelationships in the
financial markets to assess risk-adjusted performance and predict the direction of both the overall
market and specific securities.
• Risk: The risk of market timing based on technical analysis is that our analysis may not
accurately detect anomalies or predict future price movements. Current prices of securities may
reflect all information known about the security and day-to-day changes in market prices of
securities may follow random patterns and may not be predictable with any reliable degree of
accuracy.
Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a
company's financial statements, details regarding the company's product line, the experience and
expertise of the company's management, and the outlook for the company and its industry. The
resulting data is used to measure the true value of the company's stock compared to the current
market value.
• Risk: The risk of fundamental analysis is that information obtained may be incorrect and the
analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's
value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may
not result in favorable performance.
Modern Portfolio Theory (MPT) - a theory of investment which attempts to maximize portfolio
expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of
expected return, by carefully diversifying the proportions of various assets.
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• Risk: Market risk is that part of a security's risk that is common to all securities of the same
general class (stocks and bonds) and thus cannot be eliminated by diversification.
Long-Term Purchases - securities purchased with the expectation that the value of those securities
will grow over a relatively long period of time, generally greater than one year.
• Risk: Using a long-term purchase strategy generally assumes the financial markets will go up
in the long-term which may not be the case. There is also the risk that the segment of the
market that you are invested in or perhaps just your particular investment will go down over
time even if the overall financial markets advance. Purchasing investments long-term may
create an opportunity cost - "locking-up" assets that may be better utilized in the short-term in
other investments.
Short-Term Purchases - securities purchased with the expectation that they will be sold within a
relatively short period of time, generally less than one year, to take advantage of the securities' short-
term price fluctuations.
• Risk: Using a short-term purchase strategy generally assumes that we can predict how
financial markets will perform in the short-term which may be very difficult and will incur a
disproportionately higher amount of transaction costs compared to long-term trading. There are
many factors that can affect financial market performance in the short-term (such as short-term
interest rate changes, cyclical earnings announcements, etc.) but may have a smaller impact
over longer periods of times.
Option Writing - a securities transaction that involves selling an option. An option is the right, but not
the obligation, to buy or sell a particular security at a specified price before the expiration date of the
option. When an investor sells an option, he or she must deliver to the buyer a specified number of
shares if the buyer exercises the option. The seller pays the buyer a premium (the market price of the
option at a particular time) in exchange for writing the option.
• Risk: Options are complex investments and can be very risky, especially if the investor does
not own the underlying stock. In certain situations, an investor's risk can be unlimited.
Our investment strategies and advice may vary depending upon each client's specific financial
situation. As such, we determine investments and allocations based upon your predefined objectives,
risk tolerance, time horizon, financial information, liquidity needs, and other various suitability factors.
Your restrictions and guidelines may affect the composition of your portfolio.
We may use short-term trading (in general, selling securities within 30 days of purchasing the same
securities) as an investment strategy when managing your account(s). Short-term trading is not a
fundamental part of our overall investment strategy, but we may use this strategy occasionally when
we determine that it is suitable given your stated investment objectives and tolerance for risk. This may
include buying and selling securities frequently in an effort to capture significant market gains and
avoid significant losses. However, there is a risk that frequent trading can negatively affect investment
performance, particularly through increased brokerage and other transactional costs and taxes.
Tax Considerations
Our strategies and investments may have unique and significant tax implications. However, unless we
specifically agree otherwise, and in writing, tax efficiency is not our primary consideration in the
management of your assets. Regardless of your account size or any other factors, we strongly
recommend that you consult with a tax professional regarding the investing of your assets.
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Moreover, custodians and broker-dealers must report the cost basis of equities acquired in client
accounts on or after January 1, 2011. Your custodian will default to the FIFO (First-In First-Out)
accounting method for calculating the cost basis of your investments. You are responsible for
contacting your tax advisor to determine if this accounting method is the right choice for you. If your tax
advisor believes another accounting method is more advantageous, provide written notice to our firm
immediately and we will alert your account custodian of your individually selected accounting method.
Decisions about cost basis accounting methods will need to be made before trades settle, as the cost
basis method cannot be changed after settlement.
Risk of Loss
Investing in securities involves risk of loss that you should be prepared to bear. We do not represent or
guarantee that our services or methods of analysis can or will predict future results, successfully
identify market tops or bottoms, or insulate clients from losses due to market corrections or declines.
We cannot offer any guarantees or promises that your financial goals and objectives will be met. Past
performance is in no way an indication of future performance.
Recommendation of Particular Types of Securities
We primarily recommend stocks, ETFs, and mutual funds. However, we may advise on other types of
investments as appropriate for you since each client has different needs and different tolerance for
risk. Each type of security has its own unique set of risks associated with it and it would not be possible
to list here all of the specific risks of every type of investment. Even within the same type of
investment, risks can vary widely. However, in very general terms, the higher the anticipated return of
an investment, the higher the risk of loss associated with the investment.
Proxy Voting
We will not vote proxies on behalf of your advisory accounts. At your request, we may offer you advice
regarding corporate actions and the exercise of your proxy voting rights. If you own shares of
applicable securities, you are responsible for exercising your right to vote as a shareholder.
In most cases, you will receive proxy materials directly from the account custodian. However, in the
event we were to receive any written or electronic proxy materials, we would forward them directly to
you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we
would forward any electronic solicitations to vote proxies.
Item 7 Client Information Provided to Portfolio Managers
In order to provide the Program services, we will share your private information with your account
custodian. We may also provide your private information to mutual fund companies and/or private
managers as needed. We will only share the information necessary in order to carry out our obligations
to you in servicing your account. We share your personal account data in accordance with our privacy
policy as described below.
Item 8 Client Contact with Portfolio Managers
Without restriction, you should contact our firm or your advisory representative directly with any
questions regarding your Program account. You should contact your advisory representative with
respect to changes in your investment objectives, risk tolerance, or requested restrictions placed on
the management of your Program assets.
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Item 9 Additional Information
Disciplinary Information
Neither Wellington Investment Advisors nor its management persons have had any legal or disciplinary
events, currently or in the past.
Registrations with Broker-Dealer
Persons providing investment advice on behalf of our firm are registered representatives with Private
Client Services, LLC, a securities broker-dealer, and a member of the Financial Industry Regulatory
Authority and the Securities Investor Protection Corporation. In their capacity as registered
representatives, these persons will receive commission-based compensation in connection with the
purchase and sale of securities, including 12b-1 fees for the sale of investment company products.
Compensation earned by these persons in their capacities as registered representatives is separate
and in addition to our advisory fees. This practice presents a conflict of interest because persons
providing investment advice on behalf of our firm who are registered representatives have an incentive
to effect securities transactions for the purpose of generating commissions rather than solely based on
your needs. You are under no obligation, contractually or otherwise, to purchase securities products
through any person affiliated with our firm.
Licensed Insurance Agents
Persons providing investment advice on behalf of our firm may be licensed as insurance agents. These
persons will earn commission-based compensation for selling insurance products, including insurance
products they sell to you. Insurance commissions earned by these persons are separate from our
advisory fees. This practice presents a conflict of interest because persons providing investment
advice on behalf of our firm who are insurance agents have an incentive to recommend insurance
products to you for the purpose of generating commissions rather than solely based on your needs.
You are under no obligation, contractually or otherwise, to purchase insurance products through any
person affiliated with our firm.
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, non-public 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.
Participation or Interest in Client Transactions
Neither our firm nor any persons associated with our firm has any material financial interest in client
transactions beyond the provision of investment advisory services as disclosed in 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.
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Block Trading
Our firm or persons associated with our firm may buy or sell securities for you at the same time we or
persons associated with our firm buy or sell such securities for our own account. We may also combine
our orders to purchase securities with your orders to purchase securities ("block trading"). Refer to
the Brokerage Practices section in this brochure for information on our block trading practices.
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 block trading with your accounts; however, they will
not be given preferential treatment.
Review of Accounts
Paul Bullock, CEO, or your investment advisor representative, will monitor your accounts on an
ongoing basis and will conduct account reviews at least annually or upon client request to ensure that
the planning advice and/or asset allocation recommendations made to you are consistent with
your stated investment needs and objectives.
We will provide you with additional or regular written reports in conjunction with account reviews.
Reports we provide to you will contain relevant account and/or market-related information such as an
inventory of account holdings and account performance, etc. You will receive trade confirmations and
monthly or quarterly statements from your account custodian(s).
Client Referrals and Other Compensation
We receive an economic benefit from Schwab in the form of the support products and services it
makes available to us and other independent investment advisors that have their clients maintain
accounts at Schwab. These products and services, how they benefit us, and the related conflicts of
interest are described above. The availability to us of Schwab’s products and services is not based on
us giving particular investment advice, such as buying particular securities for our clients.
Persons providing investment advice on behalf of our firm are licensed insurance agents. For
information on the conflicts of interest this presents, and how we address these conflicts, refer to
the Licensed Insurance Agents section.
We do not receive any compensation from any third party in connection with providing investment
advice to you.
We directly compensate non-employee (outside) consultants, individuals, and/or entities (solicitors) for
client referrals. In order to receive a cash referral fee from us, solicitors must comply with the
requirements of the jurisdictions in which they operate. If you were referred to us by a solicitor, you
should have received a copy of this brochure along with the solicitor's disclosure statement at the time
of the referral. The solicitor that referred you to us receives either a fee paid on a per-lead basis, or
a monthly, flat referral fee. You will not pay additional fees because of this referral arrangement.
Solicitors have a financial incentive to recommend us to you for advisory services. This creates a
conflict of interest; however, you are not obligated to retain us for advisory services. Comparable
services and/or lower fees may be available through other firms.
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Solicitors that refer business to more than one investment adviser may have a financial incentive to
recommend advisers with more favorable compensation arrangements. We request that our solicitors
disclose to you whether multiple referral relationships exist and that comparable services may be
available from other advisers for lower fees and/or where the Solicitor's compensation is less
favorable.
Financial Information
Our firm does not have any financial condition or impairment that would prevent us from meeting our
contractual commitments to you. We do not take physical custody of client funds or securities, or serve
as trustee or signatory for client accounts, and we do not require the prepayment of more than $500 in
fees six or more months in advance. Therefore, we are not required to include a financial statement
with this brochure.
Additionally, our firm has never filed a bankruptcy petition.
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