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DISCLOSURE BROCHURE
Portfolio Design Services, LLC (CRD 131506), brochure dated October 8, 2026. Text extracted from the firm's SEC Form ADV Part 2 brochure.
View firm on SEC ↗ · Current Form ADV (PDF) ↗
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F O R M A D V P A R T 2 A
D I S C L O S U R E B R O C H U RE
Portfolio Design Services, LLC
Main Office Address:
122 N. 2nd Street
Additional Branch Office:
River Falls, WI 54022
100 Hill Top Road
Tel:
Roanoke, VA 24014
Fax:
715-629-9095
540-400-0054
www.pdsadvisers.com
October 8, 2026
This brochure provides information about the qualifications and business practices of Portfolio
Design Services, LLC. Being registered as an investment adviser does not imply a certain level of
skill or training. If you have any questions about the contents of this brochure, please contact us
at 715-629-9095. The information in this brochure has not been approved or verified by the
A D D I T I O N A L I N F O R M A T I O N A B O U T P O R T F O L I O D E S I G N S E R V I C E S , L L C
United States Securities and Exchange Commission, or by any state securities authority.
( C R D # 1 3 1 5 0 6 ) I S A V A I L A B L E O N T H E S E C ’ S W E B S I T E A T
W W W . A D V I S E R I N F O . S E C . G O V
Item 2: Material Changes
Annual Update
Material Changes since the Last Update
The Material Changes section of this brochure will be updated annually or when material
changes occur since the previous release of the Firm Brochure.
•
Since the last filing on March 2, 2026, the following material changes have occurred:
•
Item 4 Client assets under management have been updated.
•
Item 15 has been updated to reflect custody of third party SLOAs.
•
The brochure has been updated with a new Chief Compliance Officer.
Full Brochure Available
A professional designation as been added to the 2B for Brad Olson.
This Firm Brochure being delivered is the complete brochure for the Firm.
Item 3: Table of Contents
Form ADV – Part 2A – Firm Brochure
Item 1: Cover Page
Item 2: Material Changes .................................................................................................................... ii
Annual Update ................................................................................................................................................................... ii
Material Changes since the Last Update.................................................................................................................. ii
Item 3: Table of Contents ................................................................................................................... iii
Full Brochure Available .................................................................................................................................................. ii
Item 4: Advisory Business .................................................................................................................. 1
Firm Description ............................................................................................................................................................... 1
Types of Advisory Services ........................................................................................................................................... 1
Client Tailored Services and Client Imposed Restrictions ............................................................................... 2
Wrap Fee Programs ......................................................................................................................................................... 3
Item 5: Fees and Compensation ....................................................................................................... 3
Client Assets under Management .............................................................................................................................. 3
Method of Compensation and Fee Schedule .......................................................................................................... 3
Client Payment of Fees ................................................................................................................................................... 4
Additional Client Fees Charged ................................................................................................................................... 4
Prepayment of Client Fees ............................................................................................................................................ 4
Item 6: Performance-Based Fees and Side-by-Side Management ........................................ 5
External Compensation for the Sale of Securities to Clients ........................................................................... 5
Item 7: Types of Clients ....................................................................................................................... 5
Sharing of Capital Gains ................................................................................................................................................. 5
Description .......................................................................................................................................................................... 5
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................ 5
Account Minimums .......................................................................................................................................................... 5
Methods of Analysis ......................................................................................................................................................... 5
Investment Strategy ........................................................................................................................................................ 5
Item 9: Disciplinary Information ..................................................................................................... 7
Security Specific Material Risks .................................................................................................................................. 6
Criminal or Civil Actions ................................................................................................................................................ 7
Administrative Enforcement Proceedings ............................................................................................................. 7
Item 10: Other Financial Industry Activities and Affiliations ............................................... 7
Self- Regulatory Organization Enforcement Proceedings ............................................................................... 7
Broker-Dealer or Representative Registration .................................................................................................... 7
Futures or Commodity Registration ......................................................................................................................... 7
Material Relationships Maintained by this Advisory Business and Conflicts of Interest ................... 7
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ................ 7
Trading ..................................................................................................................................................... 7
Code of Ethics Description ............................................................................................................................................ 7
Investment Recommendations Involving a Material Financial Interest and Conflict of Interest.... 8
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest ... 8
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities
Item 12: Brokerage Practices ........................................................................................................... 9
Transactions and Conflicts of Interest ..................................................................................................................... 8
Factors Used to Select Broker-Dealers for Client Transactions .................................................................... 9
Item 13: Review of Accounts ........................................................................................................... 10
Aggregating Securities Transactions for Client Accounts ............................................................................. 10
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons
Involved ............................................................................................................................................................................. 10
Review of Client Accounts on Non-Periodic Basis ........................................................................................... 10
Item 14: Client Referrals and Other Compensation ................................................................ 10
Content of Client Provided Reports and Frequency ........................................................................................ 10
Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of
Interest ............................................................................................................................................................................... 10
Item 15: Custody .................................................................................................................................. 11
Advisory Firm Payments for Client Referrals .................................................................................................... 10
Item 16: Investment Discretion ..................................................................................................... 12
Account Statements ...................................................................................................................................................... 11
Item 17: Voting Client Securities ................................................................................................... 12
Discretionary Authority for Trading...................................................................................................................... 12
Item 18: Financial Information ...................................................................................................... 12
Proxy Votes ...................................................................................................................................................................... 12
Balance Sheet .................................................................................................................................................................. 12
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments
to Clients ............................................................................................................................................................................ 12
Brochure Supplement (Part 2B of Form ADV) .......................................................................... 14
Bankruptcy Petitions during the Past Ten Years .............................................................................................. 12
®
Bradley Olson, AIF
...................................................................................................................................................... 14
Item 2 - Educational Background and Business Experience ....................................................................... 14
Item 3 - Disciplinary Information ........................................................................................................................... 14
Item 4 - Other Business Activities ........................................................................................................................... 14
Item 5 - Additional Compensation .......................................................................................................................... 14
Brochure Supplement (Part 2B of Form ADV) .......................................................................... 16
Item 6 - Supervision ..................................................................................................................................................... 14
Angela Tille ....................................................................................................................................................................... 16
Item 2 - Educational Background and Business Experience ....................................................................... 16
Item 3 - Disciplinary Information ........................................................................................................................... 16
Item 4 - Other Business Activities ........................................................................................................................... 16
Item 5 - Additional Compensation .......................................................................................................................... 16
Brochure Supplement (Part 2B of Form ADV) .......................................................................... 18
Item 6 - Supervision ..................................................................................................................................................... 16
Bruce Swanson ............................................................................................................................................................... 18
Item 2 - Educational Background and Business Experience ....................................................................... 18
Item 3 - Disciplinary Information ........................................................................................................................... 18
Item 4 - Other Business Activities ........................................................................................................................... 18
Item 5 - Additional Compensation .......................................................................................................................... 18
Brochure Supplement (Part 2B of Form ADV) .......................................................................... 20
Item 6 - Supervision ..................................................................................................................................................... 18
Tonya Swinnea................................................................................................................................................................ 20
Item 2 - Educational Background and Business Experience ....................................................................... 20
Item 3 - Disciplinary Information ........................................................................................................................... 20
Item 4 - Other Business Activities ........................................................................................................................... 20
Item 5 - Additional Compensation .......................................................................................................................... 20
Item 6 - Supervision ..................................................................................................................................................... 20
Item 4: Advisory Business
Firm Description
Types of Advisory Services
Portfolio Design Services, LLC (“PDS”) was founded and became registered as an
investment advisor in 2004. PDS is owned by Bradley Olson, Bruce Swanson and Julie
Swanson. Bruce Swanson is the Chief Compliance Officer.
ASSET MANAGEMENT
PDS offers discretionary asset management services to advisory Clients. PDS will offer
Clients ongoing asset management services through determining individual investment
goals, time horizons, objectives, and risk tolerance. Investment strategies, investment
selection, asset allocation, portfolio monitoring and the overall investment program will be
based on the above factors. The Client will authorize PDS discretionary authority to execute
selected investment program transactions as stated within the Investment Advisory
Agreement.
ERISA PLAN SERVICES
PDS provides service to qualified retirement plans including 401(k) plans, 403(b) plans,
pension and profit-sharing plans, cash balance plans, and deferred compensation plans.
ERISA 3(38) Investment Manager.
PDS will act as a 3(38) advisor.
PDS can also act as an ERISA 3(38) Investment
Manager in which it has discretionary management and control of a given retirement plan’s
assets. PDS would then become solely responsible and liable for the selection, monitoring
and replacement of the plan’s investment options.
1.
•
Fiduciary Services are:
•
PDS has discretionary authority and will make the final decision regarding the initial
selection, retention, removal and addition of investment options in accordance with
the Plan’s investment policies and objectives.
•
Assist the Client with the selection of a broad range of investment options consistent
with ERISA Section 404(c) and the regulations thereunder.
•
Assist the Client in the development of an investment policy statement (“IPS”). The
IPS establishes the investment policies and objectives for the Plan.
Provide discretionary investment advice to the Plan Sponsor with respect to the
selection of a qualified default investment option for participants who are
automatically enrolled in the Plan or who have otherwise failed to make investment
elections. The Client retains the sole responsibility to provide all notices to the Plan
participants required under ERISA Section 404(c) (5).
2.
•
Non-fiduciary Services are:
Assist in the education of Plan participants about general investment information
and the investment options available to them under the Plan. Client understands the
PDS’s assistance in education of the Plan participants shall be consistent with and
within the scope of the Department of Labor’s definition of investment education
(Department of Labor Interpretive Bulletin 96-1). As such, the PDS is not providing
fiduciary advice as defined by ERISA to the Plan participants. PDS will not provide
investment option or
investment advice concerning the prudence of any
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•
combination of investment options for a particular participant or beneficiary under
the Plan.
Assist in the group enrollment meetings designed to increase retirement plan
participation among the employees and investment and financial understanding by
the employees.
PDS may provide these services or, alternatively, may arrange for the Plan’s other
providers to offer these services, as agreed upon between PDS and Client.
3.
PDS has no responsibility to provide services related to the following types of assets
•
(“Excluded Assets”):
•
•
•
•
•
•
not
Employer securities;
Real estate (except for real estate funds or publicly traded REITs);
Stock brokerage accounts or mutual fund windows;
Participant loans;
Non-publicly traded partnership interests;
Other non-publicly traded securities or property (other than collective trusts and
similar vehicles); or
Other hard-to-value or illiquid securities or property.
be included in calculation of Fees paid to the Adviser on the ERISA
Excluded Assets will
Agreement. Specific services will be outlined in detail to each plan in the 408(b)2
disclosure.
Full Financial Plan
FINANCIAL PLANNING AND CONSULTING
Financial planning services include a complete evaluation of a Client’s current and future
financial state and will be provided by using currently known variables to predict
future cash flows, asset values and withdrawal plans. PDS will use current net worth, tax
liabilities, asset allocation, future retirement date and estate plans in developing financial
plans. Typical topics reviewed may include but are not limited to: financial goals, personal
financial consulting, investment analysis, retirement strategy, cash flow analysis, risk
Consultation Services
management, long-term investment and estate preservation.
This service is appropriate for Clients who need assistance with individual topics. This is
not a detailed financial review and will not result in a complete financial plan. Client may
select individual topics above, or other topics as may be deemed appropriate. The
individual topics that will be included in this service will be outlined and agreed upon on
the financial planning and consulting agreement.
Client Tailored Services and Client Imposed Restrictions
If a conflict of interest exists between the interests of PDS and the interests of the Client,
the Client is under no obligation to act upon any recommendation. Implementation of any
recommendations will be at the discretion of the Client. Other professionals (e.g., lawyers,
accountants, tax preparers, insurance agents, real estate agents, etc.) are engaged directly
by the Client on an as-needed basis and may charge fees of their own. If the Client elects to
act on any of the recommendations, the Client is under no obligation to affect the
transaction through PDS. Financial plans and consultations will be completed and delivered
inside of ninety (90) days contingent upon timely delivery of all required documentation.
The goals and objectives for each Client are documented in our Client files. Investment
strategies are created that reflect the stated goals and objectives. Clients may impose
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Wrap Fee Programs
restrictions on investing in certain securities or types of securities. Agreements may not be
assigned without written Client consent.
Client Assets under Management
PDS does not sponsor any wrap fee programs.
PDS has the following Client assets under management:
Discretionary Amounts:
Non-discretionary Amounts:
Date Calculated:
$
$0
06/30/2026
159,822,368
Item 5: Fees and Compensation
Method of Compensation and Fee Schedule
ASSET MANAGEMENT
PDS charges an annual investment advisory fee based on the total assets under
management as follows: Assets Under Management
Annual Fee
Rates
First $1,000,000
Next $1,000,000
Next $3,000,000
Over $5,000,000
1.50%
1.25%
1.00%
0.75%
This is a tiered advisory fee schedule calculated by applying different rates to different
portions of the portfolio. The annual fee is negotiable. Fees are billed quarterly in advance
based on the amount of assets managed as of the close of business on the last business day
of the previous quarter. Lower fees for comparable services may be available from other
sources. Clients may terminate their account within five (5) business days of signing the
Investment Advisory Agreement with no obligation and without penalty. After the initial
five (5) business days, the agreement may be terminated by PDS with thirty (30) days
written notice to Client and by the Client at any time with written notice to PDS. For
accounts opened or closed mid-billing period, fees will be prorated based on the days
services are provided during the given period. All unpaid earned fees will be due to PDS.
Any unearned fees will be refunded to the Client. Client shall be given thirty (30) days prior
written notice of any increase in fees. Any increase in fees will be acknowledged in writing
by both parties before any increase in said fees occurs.
ERISA PLAN SERVICES
The annual fees are based on the market value of the Included Assets and will not exceed
1.20%. The annual fee is negotiable and may be charged as a percentage of the Included
Assets or as flat fee. Fees may be charged quarterly or monthly in arrears or in advance
based on the assets as calculated by the custodian or record keeper of the Included Assets
(without adjustments for anticipated withdrawals by Plan participants or other anticipated
or scheduled transfers or distribution of assets). If the services to be provided start any
time other than the first day of a quarter or month, the fee will be prorated based on the
number of days remaining in the quarter or month. If this Agreement is terminated prior to
the end of the billing cycle, PDS shall be entitled to a prorated fee based on the number of
days during the fee period services were provided or Client will be due a prorated refund of
fees for days services were not provided in the billing cycle.
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The fee schedule, which includes compensation of PDS for the services is described in detail
in Schedule A of the ERISA Plan Agreement. The Plan is obligated to pay the fees, however
the Plan Sponsor may elect to pay the fees. Client may elect to be billed directly or have fees
deducted from Plan Assets. PDS does not reasonably expect to receive any additional
compensation, directly or indirectly, for its services under this Agreement. If additional
compensation is received, PDS will disclose this compensation, the services rendered, and
the payer of compensation. PDS will offset the compensation against the fees agreed upon
under the Agreement.
FINANCIAL PLANNING AND CONSULTING
PDS charges either a fixed fee or hourly fee for financial planning and consulting services.
Prior to the planning process the Client will be provided an estimated plan fee. Fees for
financial planning and consulting services can be paid either in advance upon the signing of
the Agreement or 50% in advance with balance due upon delivery of the completed plan or
consultation. Services are completed and delivered inside of ninety (90) days contingent on
the timely receipt of all applicable documents from the Client. Client may cancel within five
(5) days of signing Agreement with no obligation. If the Client cancels after five (5)
business days, any unearned fees will be refunded to the Client, or any unpaid earned fees
will be due to PDS based on the hours of work expended by PDS.
FIXED FEES
Financial planning services are offered based on a negotiable fixed fee up to $20,000
dependent upon the complexity of the Client’s specific situation.
HOURLY FEES
Client Payment of Fees
Consulting services are offered based on an hourly fee of $250 per hour.
Fees for asset management services are deducted from a designated Client account to
facilitate billing. The Client must consent in advance to direct debiting of their investment
account.
Fees for ERISA services will either be deducted from Plan assets or paid directly to PDS.
The Client must consent in advance to direct debiting of their investment account.
Additional Client Fees Charged
Fees for financial planning and consulting will be billed to the Client and paid directly to
PDS.
Prepayment of Client Fees
Custodians may charge transaction fees and other related costs on the purchases or sales of
mutual funds, equities, bonds, options and exchange-traded funds. Mutual funds, money
market funds and exchange-traded funds also charge internal management fees, which are
disclosed in the fund’s prospectus. PDS does not receive any compensation from these fees.
All of these fees are in addition to the management fee you pay to PDS. For more details on
the brokerage practices, see Item 12 of this brochure.
Fees for asset management services may be billed quarterly in advance.
Fees for ERISA 3(38) services may be billed in advance.
Fees for financial planning and consulting services are billed in advance.
If the Client cancels after five (5) business days, any unearned fees will be refunded to the
Client, or any unpaid earned fees will be due to PDS.
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External Compensation for the Sale of Securities to Clients
PDS does not receive any external compensation for the sale of securities to Clients, nor do
any of the investment advisor representatives of PDS.
Item 6: Performance-Based Fees and Side-by-Side Management
Sharing of Capital Gains
Fees are not based on a share of the capital gains or capital appreciation of managed
securities.
Item 7: Types of Clients
Description
Account Minimums
PDS generally provides investment advice to individuals, high net worth individuals, trusts
or estates. Client relationships vary in scope and length of service.
PDS requires a minimum of $100,000 to open an account. At the discretion of PDS, the
minimum account size may be lowered or waived.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Security analysis methods may include fundamental analysis, technical analysis and cyclical
analysis. Investing in securities involves risk of loss that Clients should be prepared to bear.
Past performance is not a guarantee of future returns.
Fundamental analysis concentrates on factors that determine a company’s value and
expected future earnings. This strategy would normally encourage equity purchases in
stocks that are undervalued or priced below their perceived value. The risk assumed is that
the market will fail to reach expectations of perceived value.
Technical analysis attempts to predict a future stock price or direction based on market
trends. The assumption is that the market follows discernible patterns and if these patterns
can be identified then a prediction can be made. The risk is that markets do not always
follow patterns and relying solely on this method may not take into account new patterns
that emerge over time.
Investment Strategy
Cyclical analysis assumes that the markets react in cyclical patterns which, once identified,
can be leveraged to provide performance. The risks with this strategy are twofold: 1) the
markets do not always repeat cyclical patterns; and 2) if too many investors begin to
implement this strategy, then it changes the very cycles these investors are trying to
exploit.
PDS’s asset management approach incorporates your financial needs and investment
objectives, time horizon, and risk tolerance to yield an effective investment strategy. Your
portfolio is then tailored to these unique investment parameters using equities (“stocks”)
and fixed income/debt (“bond”) instruments, and a mix of investment company products
(“mutual funds”) and Exchange Traded Funds (“ETFs”), and other assets to design your
unique investment strategy.
The investment strategy for a specific Client is based upon the objectives stated by the
Client during consultations. The Client may change these objectives at any time by
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Security Specific Material Risks
providing written notice to PDS. Each Client executes a Client profile form or similar form
that documents their objectives and their desired investment strategy.
All investment programs have certain risks that are borne by the investor. Our investment
approach constantly keeps the risk of loss in mind. Investors face the following investment
• Market Risk
risks and should discuss these risks with PDS:
•
: The prices of securities in which Clients invest may decline in response to
certain events taking place around the world, including those directly involving the
companies whose securities are owned by a fund; conditions affecting the general
economy; overall market changes; local, regional or global political, social or economic
instability; and currency, interest rate and commodity price fluctuations. Investors
should have a long-term perspective and be able to tolerate potentially sharp declines
Interest-rate Risk
in market value.
•
: Fluctuations in interest rates may cause investment prices to
fluctuate. For example, when interest rates rise, yields on existing bonds become less
Inflation Risk
attractive, causing their market values to decline.
: When any type of inflation is present, a dollar today will buy more than a
• Currency Risk
dollar next year, because purchasing power is eroding at the rate of inflation.
: Overseas investments are subject to fluctuations in the value of the dollar
against the currency of the investment’s originating country. This is also referred to as
• Reinvestment Risk
exchange rate risk.
• Management Risk:
: This is the risk that future proceeds from investments may have to
be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily
relates to fixed income securities.
• Equity Risk:
The advisor’s investment approach may fail to produce the intended
results. If the advisor’s assumptions regarding the performance of a specific asset class
or fund are not realized in the expected time frame, the overall performance of the
Client’s portfolio may suffer.
• Fixed Income Risk:
Equity securities tend to be more volatile than other investment choices.
The value of an individual mutual fund or ETF can be more volatile than the market as a
whole. This volatility affects the value of the Client’s overall portfolio. Small- and mid-
cap companies are subject to additional risks. Smaller companies may experience
greater volatility, higher failure rates, more limited markets, product lines, financial
resources, and less management experience than larger companies. Smaller companies
may also have a lower trading volume, which may disproportionately affect their
market price, tending to make them fall more in response to selling pressure than is the
case with larger companies.
•
The issuer of a fixed income security may not be able to make
interest and principal payments when due. Generally, the lower the credit rating of a
security, the greater the risk that the issuer will default on its obligation. If a rating
agency gives a debt security a lower rating, the value of the debt security will decline
because investors will demand a higher rate of return. As nominal interest rates rise,
the value of fixed income securities held by a fund is likely to decrease. A nominal
Investment Companies Risk:
interest rate is the sum of a real interest rate and an expected inflation rate.
When a Client invests in open end mutual funds or ETFs, the
Client indirectly bears their proportionate share of any fees and expenses payable
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directly by those funds. Therefore, the Client will incur higher expenses, which may be
duplicative. In addition, the Client’s overall portfolio may be affected by losses of an
underlying fund and the level of risk arising from the investment practices of an
underlying fund (such as the use of derivatives). ETFs are also subject to the following
risks: (i) an ETF’s shares may trade at a market price that is above or below their net
asset value or (ii) trading of an ETF’s shares may be halted if the listing exchange’s
officials deem such action appropriate, the shares are de-listed from the exchange, or
the activation of market-wide “circuit breakers” (which are tied to large decreases in
stock prices) halts stock trading generally. Adviser has no control over the risks taken
by the underlying funds in which Client invests.
Item 9: Disciplinary Information
Criminal or Civil Actions
Administrative Enforcement Proceedings
PDS and its management have not been involved in any criminal or civil action.
Self- Regulatory Organization Enforcement Proceedings
PDS and its management have not been involved in administrative enforcement
proceedings.
PDS and its management have not been involved in any self-regulatory organizational
enforcement proceedings that are material to a Client’s or prospective Client’s evaluation of
PDS or the integrity of its management.
Item 10: Other Financial Industry Activities and Affiliations
Broker-Dealer or Representative Registration
Futures or Commodity Registration
PDS is not registered as a broker-dealer and no affiliated representatives of PDS are
registered representatives of a broker-dealer.
Material Relationships Maintained by this Advisory Business and Conflicts of Interest
Neither PDS nor its affiliated representatives are registered or have an application pending
to register as a futures commission merchant, commodity pool operator, or a commodity
trading advisor.
PDS doesn’t maintain any material relationships and the supervised persons are not
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest
involved in any other business activities.
PDS doesn’t select or recommend other investment advisors.
Item 11: Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
Code of Ethics Description
include employees and/or
The affiliated persons (affiliated persons
independent
contractors) of PDS have committed to a Code of Ethics (“Code”). The purpose of our Code
is to set forth standards of conduct expected of PDS affiliated persons and addresses
conflicts that may arise. The Code defines acceptable behavior for affiliated persons of PDS.
The Code reflects PDS and its supervised persons’ responsibility to act in the best interest
of their Client.
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One area which the Code addresses is when affiliated persons buy or sell securities for
their personal accounts and how to mitigate any conflict of interest with our Clients. We do
not allow any affiliated persons to use non-public material information for their personal
profit or to use internal research for their personal benefit in conflict with the benefit to
our Clients.
PDS’s policy prohibits any person from acting upon or otherwise misusing non-public or
inside information. No advisory representative or other affiliated person, officer or director
of PDS may recommend any transaction in a security or its derivative to advisory Clients or
engage in personal securities transactions for a security or its derivatives if the advisory
representative possesses material, non-public information regarding the security.
PDS’s Code is based on the guiding principle that the interests of the Client are our top
priority. PDS’s officers, directors, advisors, and other affiliated persons have a fiduciary
duty to our Clients and must diligently perform that duty to maintain the complete trust
and confidence of our Clients. When a conflict arises, it is our obligation to put the Client’s
interests over the interests of either affiliated persons or the company.
The Code applies to “access” persons. “Access” persons are affiliated persons who have
access to non-public information regarding any Clients' purchase or sale of securities, or
non-public information regarding the portfolio holdings of any reportable fund, who are
involved in making securities recommendations to Clients, or who have access to such
recommendations that are non-public.
PDS will provide a copy of the Code of Ethics to any Client or prospective Client upon
Investment Recommendations Involving a Material Financial Interest and Conflict of
request.
Interest
PDS and its affiliated persons do not recommend to Clients securities in which we have a
material financial interest.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
Interest
PDS and its affiliated persons may buy or sell securities that are also held by Clients. In
order to mitigate conflicts of interest such as trading ahead of Client transactions, affiliated
persons are required to disclose all reportable securities transactions as well as provide
PDS with copies of their brokerage statements.
The Chief Compliance Officer of PDS is Bruce Swanson. He reviews all trades of the
affiliated persons each quarter. The personal trading reviews ensure that the personal
trading of affiliated persons does not front run or disadvantage trading for Clients.
Client Securities Recommendations or Trades and Concurrent Advisory Firm
Securities Transactions and Conflicts of Interest
PDS does not have a material financial interest in any securities being recommended.
However, affiliated persons may buy or sell securities at the same time they buy or sell
securities for Clients. In order to mitigate conflicts of interest such as front running,
affiliated persons are required to disclose all reportable securities transactions as well as
provide PDS with copies of their brokerage statements.
The Chief Compliance Officer of PDS is Bruce Swanson. He reviews all trades of the
affiliated persons each quarter. The personal trading reviews ensure that the personal
trading of affiliated persons does not front run or disadvantage trading for Clients.
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Item 12: Brokerage Practices
Factors Used to Select Broker-Dealers for Client Transactions
PDS will recommend the use of a particular broker-dealer based on their duty to seek best
execution for the Client, meaning they have an obligation to obtain the most favorable
terms for a Client under the circumstances. The determination of what may constitute best
execution and price in the execution of a securities transaction by a broker involves a
number of considerations and is subjective. Factors affecting brokerage selection include
the overall direct net economic result to the portfolios, the efficiency with which the
transaction is affected, the ability to affect the transaction where a large block is involved,
the operational facilities of the broker-dealer, the value of an ongoing relationship with
such broker and the financial strength and stability of the broker. PDS will select
appropriate brokers based on a number of factors including but not limited to their
relatively low transaction fees and reporting ability. PDS relies on its broker to provide its
execution services at the best prices available. Lower fees for comparable services may be
available from other sources. Clients pay for any and all custodial fees in addition to the
advisory fee charged by PDS. PDS does not receive any portion of the trading fees.
PDS will recommend the use of Charles Schwab & Co., Inc. or AXOS Clearing, LLC. Our
recommendation for you to custody your assets with one of these financial institutions has
no direct correlation to the services we receive and the investment advice we offer you,
although we do receive economic benefits through our relationship with from these
institutions that are typically not available to retail clients.
These benefits include the following products and services (provided without cost or at a
discount): receipt of duplicate client statements and confirmations; research related
products and tools; consulting services; access to a dedicated trading desk; access to batch
trading (which provides the ability to aggregate securities transactions for execution and
then allocate the appropriate shares to accounts); the ability to have advisory fees
deducted directly from accounts; access to an electronic communications network for
order entry and account information; access to mutual funds with no transaction fees and
to certain institutional money managers.
PDS is not a subsidiary of, or an affiliated entity of, Schwab or AXOS. PDS is solely
responsible for investment advice rendered, and advisory services are provided separately
• Research and Other Soft Dollar Benefits
and independently of these financial institutions.
The Securities and Exchange Commission defines soft dollar practices as
arrangement under which products or services other than execution services are
obtained by PDS from or through a broker-dealer in exchange for directing Client
transactions to the broker-dealer. Although PDS has no formal soft dollar
arrangements, PDS may receive products, research and/or other services from
custodians or broker-dealers connected to Client transactions or “soft dollar
benefits”. As permitted by Section 28(e) of the Securities Exchange Act of 1934, PDS
receives economic benefits as a result of commissions generated from securities
transactions by the custodian or broker-dealer from the accounts of PDS. PDS
receives a benefit because we do not have to produce or pay for the research
products, or services.
A conflict of interest exists because PDS receives soft dollars which could result in
higher commissions charged to Clients. This conflict is mitigated by the fact that PDS
has a fiduciary responsibility to act in the best interest of its Clients and the services
received are beneficial to all Clients.
- 9 -
• Brokerage for Client Referrals
• Directed Brokerage
PDS does not receive Client referrals from any custodian in exchange for using that
custodian.
Aggregating Securities Transactions for Client Accounts
Clients who direct brokerage outside our recommendation may be unable to achieve
the most favorable execution of Client transactions as Client directed brokerage may
cost Clients more money. For example, in a directed brokerage account, you may pay
higher brokerage commissions because we may not be able to aggregate orders to
reduce transaction costs, or you may receive less favorable prices.
PDS is authorized in its discretion to aggregate purchases and sales and other transactions
made for the account with purchases and sales and transactions in the same securities for
other Clients of PDS. All Clients participating in the aggregated order shall receive an
average share price with all other transaction costs shared on a pro-rated basis. If
aggregation is not allowed or infeasible and individual transactions occur (e.g., withdrawal
or liquidation requests, odd-lot trades, etc.) an account may potentially be assessed higher
costs or less favorable prices than those where aggregation has occurred.
Item 13: Review of Accounts
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory
Persons Involved
Account reviews are performed quarterly by an Investment Advisor Representative of PDS.
Account reviews are performed more frequently when market conditions dictate. Reviews
of Client accounts include, but are not limited to, a review of Client documented risk
tolerance, adherence to account objectives, investment time horizon, suitability criteria and
reviewing target allocations of each asset class to identify if there is an opportunity for
rebalancing.
Review of Client Accounts on Non-Periodic Basis
Financial plans and consultations are updated as requested by the Client and pursuant to a
new or amended agreement.
Content of Client Provided Reports and Frequency
Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws,
new investment information, and changes in a Client's own situation.
Clients receive written account statements no less than quarterly for managed accounts.
Account statements are issued by the Client’s custodian. Client receives confirmations of
each transaction in account from custodian and an additional statement during any month
in which a transaction occurs.
Item 14: Client Referrals and Other Compensation
Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts
of Interest
Advisory Firm Payments for Client Referrals
PDS does not receive any economic benefits from external sources.
PDS may enter into agreements with individuals and organizations, which may be affiliated
or unaffiliated with PDS, that refer Clients to PDS in exchange for compensation. All such
agreements will be in writing and comply with the requirements of Federal or State
regulation. If a Client is introduced to PDS by a referring party, PDS may pay that referring
- 10 -
party a fee. While the specific terms of each agreement may differ, generally, the
compensation will be based upon PDS’s engagement of new Clients and is calculated using
a varying percentage of the fees paid to PDS by such Clients. Any such fee shall be paid
solely from PDS’s investment management fee and will not result in any additional charge
to the Client.
Each prospective Client who is referred to PDS under such an arrangement will receive a
copy of this brochure and a separate written disclosure document disclosing the nature of
the relationship between the referring party and PDS and the amount of compensation that
will be paid by PDS to the referring party. The referring party is required to obtain the
Client’s signature acknowledging receipt of PDS’s disclosure brochure and the written
disclosure statement.
Item 15: Custody
Account Statements
All assets are held at qualified custodians, which means the custodians provide account
statements directly to Clients at their address of record at least quarterly. Clients are urged
to carefully compare the account statements received directly from their custodians to any
documentation or reports prepared by PDS.
PDS is deemed to have custody of Client assets solely as a result of (i) the deduction of
advisory fees directly from Client accounts by the qualified custodian at PDS’s direction and
(ii) Third-Party Standing Letters of Authorization (“SLOAs”).
PDS and the applicable qualified custodian satisfy the following seven (7) conditions to
qualify for the exception from the surprise examination requirement:
1.
The Client provides an instruction to the qualified custodian, in writing, that includes
the Client’s signature, the third party’s name, and either the third party’s address or
the third party’s account number at a custodian to which the transfer should be
directed.
2.
The Client authorizes PDS, in writing, either on the qualified custodian’s form or
separately, to direct transfers to the third party either on a specified schedule or
from time to time.
3.
The Client’s qualified custodian performs appropriate verification of the instruction,
such as a signature review or other method to verify the Client’s authorization and
provides a transfer of funds notice to the Client promptly after each transfer.
4.
The Client has the ability to terminate or change the instruction to the Client’s
qualified custodian.
5.
PDS has no authority or ability to designate or change the identity of the third party,
the address, or any other information about the third party contained in the Client’s
instruction.
6.
PDS maintains records showing that the third party is not a related party nor located
at the same address as PDS.
7.
The Client’s qualified custodian sends the Client, in writing, an initial notice
confirming the instruction and an annual notice reconfirming the instruction.
- 11 -
Item 16: Investment Discretion
Discretionary Authority for Trading
PDS requires discretionary authority to manage securities accounts on behalf of Clients.
PDS has the authority to determine, without obtaining specific Client consent, the securities
to be bought or sold, and the amount of the securities to be bought or sold. Client will
authorize PDS discretionary authority to execute selected investment program transactions
as stated within the Investment Advisory Agreement.
PDS allows Clients to place certain restrictions, as outlined in the Client’s Investment
Advisory Agreement or similar document. These restrictions must be provided to PDS in
writing.
Item 17: Voting Client Securities
Proxy Votes
PDS does not vote proxies on securities. Clients are expected to vote their own proxies. The
Client will receive their proxies directly from the custodian of their account or from a
transfer agent. When assistance on voting proxies is requested, PDS will provide
recommendations to the Client. If the Client requires assistance or has questions, they can
reach out to the investment advisor representatives of the firm at the contact information
on the cover page of this document.
Item 18: Financial Information
Balance Sheet
A balance sheet is not required to be provided to Clients because PDS does not serve as a
custodian for Client funds or securities and PDS does not require prepayment of fees of
more than $1200 per Client and six months or more in advance.
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet
Commitments to Clients
Bankruptcy Petitions during the Past Ten Years
PDS has no condition that is reasonably likely to impair our ability to meet contractual
commitments to our Clients.
PDS has not had any bankruptcy petitions in the last ten years.
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S U P E R V I S E D P E R S O N B R O C H U RE
Item 1 Cover Page
F O R M A D V P A R T 2 B
®
Bradley C. Olson, AIF
Portfolio Design Services, LLC
Office Address:
122 N. 2nd Street
Tel:
River Falls, WI 54022
Fax:
715-629-9095
Email:
540-400-0054
brad@pdsadvisers.com
www.pdsadvisers.com
March 2, 2026
This brochure supplement provides information about Bradley Olson and supplements the
Portfolio Design Services, LLC brochure. You should have received a copy of that brochure. Please
contact Bradley Olson if you did not receive the brochure or if you have any questions about the
A D D I T I O N A L I N F O R M A T I O N A B O U T B R A D L E Y O L S O N ( C R D # 5 3 4 2 5 5 0)
contents of this supplement.
I S A V A I L A B L E O N T H E S E C ’ S W E B S I T E A T W W W . A D V I S E R I N F O . S E C . G O V .
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Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Bradley Olson, AIF®
•
Item 2 - Educational Background and Business Experience
Year of birth: 1972
•
Educational Background:
Mankato State University; Bachelor of Science – Business Administration; 1996
•
Business Experience:
•
•
•
•
•
•
Portfolio Design Services, LLC; Managing Member/Research Manager; 07/2021 –
Present
Portfolio Design Services, LLC; Investment Advisor Representative; 05/2007 –
07/2021
University of Wisconsin – River Falls; Custodial Service Supervisor; 08/2005 –
10/2008
Taylor Corporation – Heinrich Envelope; Production Supervisor; 01/2004 – 09/2005
Taylor Corporation – Hortense B. Hewitt & Treasure Masters; General Manager;
06/2001 – 12/2003
Taylor Corporation – CH Printing; Plant Manager; 11/1999 – 05/2001
Taylor Corporation – Carlson Craft; Department Supervisor; 09/1995 – 11/1999
Professional Certifications
®
®
(AIF
): Accredited Investment Fiduciary designation is
®
Bradley Olson has earned certifications and credentials that are required to be explained in
further detail.
Accredited Investment Fiduciary
awarded from the Center for Fiduciary Studies, LLC. AIF
certification requirements:
®
exam with 75% correct answers.
•
•
•
•
•
•
Item 3 - Disciplinary Information
Complete training curriculum.
Pass the 60 questions AIF
Sign and agree to abide by a Code of Ethics.
Complete six hours of continuing professional education, four of which are fi360
Training CE.
Maintain current contact information in fi360’s designee database.
Submit yearly renewal application with annual dues.
None to report.
Criminal or Civil Action:
Administrative Proceeding:
Self-Regulatory Proceeding:
Item 4 - Other Business Activities
None to report.
None to report.
Item 5 - Additional Compensation
Mr. Olson is not involved in any other business activities.
Item 6 - Supervision
Mr. Olson does not receive any economic benefit, sales awards, prizes or bonuses that are
based on the number or amount of sales, client referrals, or from opening new accounts.
Bruce Swanson is the Chief Compliance Officer of PDS. Bruce Swanson reviews Mr. Olson’s
work through Client account reviews and quarterly personal transaction reports, as well as
face-to-face and phone interactions. Bruce Swanson can be reached at 715-629-9095 or
bruce@pdsadvisers.com
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S U P E R V I S E D P E R S O N B R O C H U RE
Item 1 Cover Page
F O R M A D V P A R T 2 B
Angela K. Tille
Portfolio Design Services, LLC
Office Address:
122 N. 2nd Street
Tel:
River Falls, WI 54022
Fax:
715-629-9095
Email:
540-400-0054
angela@pdsadvisers.com
www.pdsadvisers.com
October 8, 2026
This brochure supplement provides information about Angela Tille and supplements the Portfolio
Design Services, LLC brochure. You should have received a copy of that brochure. Please contact
Angela Tille if you did not receive the brochure or if you have any questions about the contents of
A D D I T I O N A L I N F O R M A T I O N A B O U T A N G E L A T I L L E ( C R D # 7 2 9 3 0 0 7) I S
this supplement.
A V A I L A B L E O N T H E S E C ’ S W E B S I T E A T W W W . A D V I S E R I N F O . S E C . G O V .
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Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Angela Tille
•
Item 2 - Educational Background and Business Experience
Year of birth: 1978
•
Educational Background:
University of Northern Iowa; Bachelor of Arts – Business Administration; 2000
•
Business Experience:
•
•
•
•
Item 3 - Disciplinary Information
Portfolio Design Services, LLC; Investment Advisor Representative; 01/2024 –
Present
Portfolio Design Services, LLC; Chief Compliance Officer; 01/2024 – 08/2026
Portfolio Design Services, LLC; Associate/Investment Advisor Representative;
09/2020 – 01/2024
Portfolio Design Services, LLC; Associate; 12/2019 – 09/2020
Tille Family; At-Home Mother; 12/2006 – 12/2019
None to report.
Criminal or Civil Action:
Administrative Proceeding:
Self-Regulatory Proceeding:
Item 4 - Other Business Activities
None to report.
None to report.
Item 5 - Additional Compensation
Ms. Tille is not involved in any other business activities.
Item 6 - Supervision
Ms. Tille does not receive any economic benefit, sales awards, prizes or bonuses that are
based on the number or amount of sales, client referrals, or from opening new accounts.
Bruce Swanson is the Chief Compliance Officer of PDS. Bruce Swanson reviews Ms. Tille’s
work through Client account reviews and quarterly personal transaction reports, as well as
face-to-face and phone interactions. Bruce Swanson can be reached at 715-629-9095 or
bruce@pdsadvisers.com.
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S U P E R V I S E D P E R S O N B R O C H U RE
Item 1 Cover Page
F O R M A D V P A R T 2 B
Bruce D. Swanson
Portfolio Design Services, LLC
Office Address:
100 Hill Top Road
Tel:
Roanoke, VA 24014
Fax:
540-400-0053
Email:
540-400-0054
bruce@pdsadvisers.com
www.pdsadvisers.com
March 2, 2026
This brochure supplement provides information about Bruce Swanson and supplements the
Portfolio Design Services, LLC brochure. You should have received a copy of that brochure. Please
contact Bruce Swanson if you did not receive the brochure or if you have any questions about the
A D D I T I O N A L I N F O R M A T I O N A B O U T B R U C E S W A N S O N ( C R D # 1 1 1 3 4 4 6)
contents of this supplement.
I S A V A I L A B L E O N T H E S E C ’ S W E B S I T E A T W W W . A D V I S E R I N F O . S E C . G O V .
- 17 -
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Bruce Swanson
•
Item 2 - Educational Background and Business Experience
Year of birth: 1950
•
Educational Background:
North Dakota State University; Bachelor of Science – Mechanical Agriculture; 1971
Business Experience:
•
•
•
•
•
Item 3 - Disciplinary Information
Portfolio Design Services, LLC; Member; 01/2024 – Present
Portfolio Design Services, LLC; Member/Chief Compliance Officer; 07/2021 –
01/2024
Portfolio Design Services, LLC; Managing Member/Chief Compliance Officer;
05/2004 – 07/2021
Valmark Securities, Inc.; Registered Representative; 11/2002 – 06/2004
Valmark Securities, Inc.; Investment Advisor Representative; 11/2002 – 06/2004
None to report.
Criminal or Civil Action:
Administrative Proceeding:
Self-Regulatory Proceeding:
Item 4 - Other Business Activities
None to report.
None to report.
Item 5 - Additional Compensation
Mr. Swanson is not involved in any other business activities.
Item 6 - Supervision
Mr. Swanson does not receive any economic benefit, sales awards, prizes or bonuses that
are based on the number or amount of sales, client referrals, or from opening new
accounts.
Mr. Swanson is the Chief Compliance Officer of PDS. He is responsible for all supervision,
formulation and monitoring of investment advice offered to Clients. He will adhere to the
policies and procedures as described in PDS’s Compliance Manual. He can be reached at
715-629-9095 or
bruce@pdsadvisers.com.
- 18 -
S U P E R V I S E D P E R S O N B R O C H U RE
Item 1 Cover Page
F O R M A D V P A R T 2 B
Tonya A. Swinnea
Portfolio Design Services, LLC
Office Address:
122 N. 2nd Street
Tel:
River Falls, WI 54022
Fax:
715-629-9095
Email:
540-400-0054
tonya@pdsadvisers.com
www.pdsadvisers.com
October 8, 2026
This brochure supplement provides information about Tonya Swinnea and supplements the
Portfolio Design Services, LLC brochure. You should have received a copy of that brochure. Please
contact Tonya Swinnea if you did not receive the brochure or if you have any questions about the
A D D I T I O N A L I N F O R M A T I O N A B O U T T O N Y A S W I N N E A ( C R D # 1 1 3 7 5 7 3)
contents of this supplement.
I S A V A I L A B L E O N T H E S E C ’ S W E B S I T E A T W W W . A D V I S E R I N F O . S E C . G O V .
- 19 -
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Tonya Swinnea
•
Item 2 - Educational Background and Business Experience
Year of birth: 1961
•
Educational Background:
Ms. Swinnea attended the University of Phoenix where she completed course work
and earned credits towards an associate degree but did not graduate.
•
Business Experience:
•
•
•
•
Item 3 - Disciplinary Information
Portfolio Design Services, LLC; Investment Advisor Representative; 03/2016 –
Present
Desert Flower Creations; Owner – Jewelry Designer; 08/1997 – Present
Portfolio Design Services, LLC; Operations Assistant; 03/2014 – 03/2016
Merrill Lynch, Pierce, Fenner & Smith Incorporated; Senior Registered Client
Associate; 09/1994 – 10/2010
Prudential Securities Incorporated; Assistant Branch Manager; 02/1990 – 09/1994
None to report.
Criminal or Civil Action:
Administrative Proceeding:
Self-Regulatory Proceeding:
Item 4 - Other Business Activities
None to report.
None to report.
Item 5 - Additional Compensation
Ms. Swinnea is owner of Desert Flower Creations but she is not involved in any other
fulltime business activities.
Item 6 - Supervision
Ms. Swinnea does not receive any economic benefit, sales awards, prizes or bonuses that
are based on the number or amount of sales, client referrals, or from opening new
accounts.
Bruce Swanson is the Chief Compliance Officer of PDS. Bruce Swanson reviews Ms.
Swinnea’s work through Client account reviews and quarterly personal transaction reports,
as well as face-to-face and phone interactions. Bruce Swanson can be reached at 715-629-
9095 or
bruce@pdsadvisers.com.
- 20 -