Overview
- Headquarters
- Bedford, NH
- Total Firm Assets
- $533 million
- Average High-Net-Worth Client Portfolio Size
- $3.0 million
Fee Structure
Primary Fee Schedule (DISCLOSURE BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $500,000 | 1.12% |
| $500,001 | $1,000,000 | 0.92% |
| $1,000,001 | $2,000,000 | 0.52% |
| $2,000,001 | and above | 0.32% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,200 | 1.02% |
| $5 million | $25,000 | 0.50% |
| $10 million | $41,000 | 0.41% |
| $50 million | $169,000 | 0.34% |
| $100 million | $329,000 | 0.33% |
Clients
- High-Net-Worth Share of Firm Assets
- 82.67%
- Number of High-Net-Worth Clients
- 148
- Total Client Accounts
- 1,205
- Discretionary Accounts
- 1,205
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting, Investment Advisor Selection
Regulatory Filings
- SEC CRD Number
- 169894
Additional Brochure: WRAP FEE PROGRAM BROCHURE (2026-05-20)
View Document Text
Item 1.
Cover Page
40 South River Road
Bedford Place, Unit 15
Bedford, NH 03110
603-668-2303
Wrap Fee Program
Brochure
(Form ADV Part 2A
Appendix 1)
May 20, 2026
information about BWM
is available on
This Wrap Fee Program Brochure provides information about the qualifications and business practices of Brophy
Wealth Management, LLC (hereinafter “BWM”). If you have any questions about the contents of this brochure,
please contact Stephen. Brophy at 603-668-2303 or via email sbrophy@brophywealth.com The information in this
brochure has not been approved or verified by the United States Securities and Exchange Commission or by any
state securities authority. Additional
the SEC’s website at
www.advisorinfo.sec.gov. BWM is a registered investment advisor. Registration does not imply any level of skill or
training.
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Item 2.
Material Changes
Annual Update
Form ADV Part 2A Appendix 1 requires registered investment advisers to amend their wrap fee program brochure
when there are material changes. If there are any material changes to an adviser’s brochure, the adviser is required
to notify you and provide you with a description of the material changes. The Material Changes section of this
brochure will be updated annually when material changes occur since the previous release of the Wrap Fee
Program Brochure.
This is the initial version of this Wrap Fee Program Brochure.
BWM’s Chief Compliance Officer, Stephen Brophy, remains available to address any questions regarding this
Wrap Fee Program Brochure.
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Item 3.
Table of Contents
Item 1.
Cover Page ...........................................................................................................................................1
Item 2.
Material Changes ..................................................................................................................................2
Item 3.
Table of Contents ..................................................................................................................................3
Item 4. Services, Fees, and Compensation ......................................................................................................4
Item 5.
Account Requirements and Types of Clients........................................................................................7
Item 6.
Portfolio Manager Selection and Evaluation .........................................................................................7
Item 7.
Client Information Provided to Portfolio Managers ...............................................................................7
Item 8.
Client Contact with Portfolio Managers .................................................................................................8
Item 9.
Additional Information ...........................................................................................................................8
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Item 4. Services, Fees, and Compensation
A. Brophy Wealth Management (“BWM”) is the sponsor of the BWM Wrap Fee Program (the “Program”). In
the Program, BWM provides investment advisory services inclusive of trade execution, custody, and
reporting. The services that BWM provides in the Program are the same as the services described in
BWM’s Form ADV Part 2A. This Wrap Fee Program Brochure is intended to serve as an appendix (or in
addition to) BWM’s Form ADV Part 2A. Certain information has been omitted from this Wrap Fee Program
Brochure to avoid duplication. Please review both brochures to ensure you understand all of BWM’s
services relating to the Program.
Investment Management Services
Clients can engage BWM to design and implement investment planning strategies and recommend one
or more Independent Managers to manage a client’s assets.
Not all client accounts participate in the Program. The Program is generally limited to accounts
maintained at Charles Schwab & Co., Inc. where BWM recommends an Independent Manager. Accounts
held at other custodians do not participate and clients will remain responsible for the payment of any
brokerage and transaction fees. In the Program, BWM is responsible for the payment of any brokerage
and transaction fees incurred by Independent Managers, and Schwab charges those fees directly to
BWM.
The terms and conditions under which the client engages an Independent Manager may be set forth in a
separate written agreement between BWM, the client, and the Independent Manager. BWM also
monitors and reviews the account performance and the client’s investment objectives. BWM receives an
advisory fee that is based upon a percentage of the market value of the assets that is managed by the
Independent Manager.
When recommending an Independent Manager for a client, BWM reviews information about the
Independent Manager such as its disclosure brochure and/or material supplied by the Independent
Manager for a description of the Independent Manager’s investment strategies, past performance and
risk results to the extent available. Factors that BWM considers in recommending an Independent
Manager include the client’s investment objectives, management style, performance, reputation, financial
strength, reporting, pricing, and research.
In addition to this brochure, the client also receives the written disclosure brochure of each Independent
Manager. Certain Independent Managers may impose more restrictive account requirements and
varying billing practices than BWM.
BWM also may provide advice about any type of investment held in a client's portfolios not directly
supervised or managed by BWM. In these events, BWM does not monitor or supervise these other assets
and clients are encouraged to review these holdings with BWM.
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In other very limited circumstances, BWM directly manages the client’s assets on an ongoing basis.
BWM tailors its advisory services to accommodate the needs of its individual clients and continuously
seeks to ensure that its clients’ portfolios are managed in a manner consistent with their specific
investment profiles. BWM consults with clients on an initial and ongoing basis to determine their specific
risk tolerance, time horizon, liquidity constraints and other factors relevant to the management of their
portfolios. Clients are advised to promptly notify BWM if there are changes in their financial situation or
if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable
restrictions or mandates on the management of their accounts if BWM determines, in its sole discretion,
the conditions would not materially impact the performance of a management strategy or prove overly
burdensome to the firm’s management efforts.
BWM may provide its clients with a broad range of comprehensive financial consulting services. These
services may include advice on investments, insurance, retirement, education, tax, estate planning, and
cash flow needs of the client. These services may be included as part of BWM’s Investment Management
Services described above.
Investment Management Fees
BWM provides investment management services for an annual fee based upon a percentage of the market
value of the assets managed by BWM. Below is a schedule of the fees generally charged by BWM.
Assets under
Management
On the first $500,000
On the next $500,000
On the next $1,000,000
On amounts thereafter
Advisory Fee
Rate
1.12 %
0.92%
0.52%
0.32%
The total portfolio value may include Assets Under Management from other members of a client’s
household, family, company 401k, or other individuals or institutions that they are connected with that
has/had a mutual association with Brophy Wealth Management, LLC. The Firm’s management fee is
prorated and charged quarterly, in advance (or arrears), as derived from the market value of the assets
managed by BWM on the last day of the previous billing period.
If assets are deposited into or withdrawn from an account after the inception of a billing period, the fee
payable with respect to such assets is typically adjusted to reflect the interim change in portfolio value.
For the initial term of an engagement, the fee is calculated on a pro rata basis. In the event the Agreement
is terminated, the fee for the final billing period is prorated through the effective date of the termination
and the outstanding balance is charged or refunded to the client, as appropriate. The Independent
Managers engaged to manage client assets generally charge investment advisory fees that are separate
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from the Firm’s management fee and such Independent Managers and other turnkey asset management
platforms may employ billing practices that differ from those of BWM.
BWM, in its sole discretion, may negotiate to charge a lesser management fee based upon certain criteria
(i.e., anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to
be managed, related accounts, account composition, pre-existing client, account retention, pro bono
activities, etc.).
Fee Debit
BWM’s Agreement and the separate agreement with any Financial Institutions may authorize BWM or
the Independent Manager to debit the client’s account for the amount of BWM’s fee and to directly remit
that fee to BWM or the Independent Manager. Any Financial Institutions recommended by BWM have
agreed to send a statement to the client, at least quarterly, indicating all amounts disbursed from the
account, including the amount of management fees paid directly to BWM.
Account Additions and Withdrawals
Clients may make additions to and withdrawals from their account at any time, subject to BWM’s right to
terminate an account. Additions may be in cash or securities provided that the Firm reserves the right to
liquidate any transferred securities or decline to accept particular securities into a client’s account. Clients
may withdraw account assets on notice to BWM, subject to the usual and customary securities settlement
procedures. However, BWM designs its portfolios as long-term investments, and the withdrawal of assets
may impair the achievement of a client’s investment objectives. BWM may consult with its clients about
the options and implications of transferring securities. Clients are advised that when transferred securities
are liquidated, they may be subject to transaction fees, fees assessed at the mutual fund level (i.e.,
contingent deferred sales charge) and/or tax ramifications.
B. Participation in the Program may cost more or less than purchasing such services separately. Also, the
Program fee charged by BWM for participation in the Program may be higher or lower than those charged
by other sponsors for comparable wrap fee programs.
Depending on the percentage wrap-fee charged by BWM, the amount of portfolio activity in the client's
account, and the value of custodial and other services provided, the wrap fee may or may not exceed the
aggregate cost of such services if they were to be provided separately or if BWM were to negotiate
transaction fees and seek best price and execution of transactions for the client's account. Clients are
solely responsible for determining which offering that they select or negotiate to enter, and BWM is under
no obligation to monitor or review whether a client would be better off in a different offering.
C. The Program’s wrap fee does not include certain charges and administrative fees, including, but not
limited to, fees charged by Independent Managers, transaction charges (excluding mark-ups and mark-
downs) resulting from trades effected through or with a broker-dealer other than Schwab, transfer taxes,
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odd lot differentials, interest charges, and any charges, taxes or other fees mandated by any federal,
state or other applicable law or otherwise agreed to with regard to client accounts. Client accounts may
invest in mutual funds (including money market funds) and ETFs that have various internal fees and
expenses (i.e. management fees), which are paid by these funds but ultimately borne by clients as a fund
shareholder. These internal fees and expenses, and the previously discussed fees and expenses, are in
addition to the fees charged by BWM. Fees charged by Independent Managers generally range from 25
bps to 95 bps (0.25% - 0.95%), per annum. Clients remain responsible for the payment of Independent
Managers, and these fees are separate, and in addition, to the fees charged by BWM.
D. BWM related persons who recommend the Program to clients do not receive compensation because of
a client’s participation in the wrap fee program.
Item 5.
Account Requirements and Types of Clients
BWM provides its services to individuals, pension and profit-sharing plans, trusts, estates, charitable
organizations, corporations and business entities. Client relationships vary in scope and length of service.
BWM does not impose a minimum portfolio size or minimum annual fee. Certain Independent Managers
may, however, impose more restrictive account requirements and varying billing practices than BWM. In
such instances, BWM may alter its corresponding account requirements and/or billing practices to
accommodate those of the Independent Managers.
Item 6.
Portfolio Manager Selection and Evaluation
A. BWM generally recommends the use of Independent Managers. In these situations, BWM continues to
do ongoing due diligence of such managers, but such recommendations rely to a great extent on the
Independent Managers’ ability to successfully implement their investment strategies. In addition, BWM
generally may not have the ability to supervise the Independent Managers on a day-to-day basis.
B. BWM acts as the portfolio manager for the Program. Inasmuch as the execution costs for transactions
effected in the client account will be paid by BWM, a conflict of interest arises because BWM bears
certain transaction costs for participating accounts and BWM has an incentive to limit trading activity in
those accounts. In addition, the amount of compensation received by BWM as a result of the client’s
participation in the Program may be more than what BWM would receive if the client paid separately for
investment advice, brokerage and other services.
As the Program sponsor, the Registrant is responsible for the primary management of the Program,
including the selection and termination of all Independent Managers. Once selected, Independent
Managers will be responsible for day-to-day management and selection of securities for the account.
Item 7.
Client Information Provided to Portfolio Managers
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BWM serves as the Program’s portfolio manager. BWM shall provide investment advisory services
specific to the needs of each client. Prior to providing investment advisory services, an investment
adviser representative will discuss with each client their particular investment objective(s). BWM shall
allocate each client’s investment assets consistent with their designated investment objective(s).
Clients may impose restrictions, in writing, on BWM services.
To the extent the Program uses Independent Manager(s), BWM shall provide the Independent
Manager(s) with each client’s particular investment objective(s). Any changes to the client’s financial
situation or investment objectives reported by the client to BWM shall be communicated to the
Independent Manager(s) within a reasonable period of time.
Item 8.
Client Contact with Portfolio Managers
The client shall have, without restriction, reasonable access to the Program’s portfolio manager.
Item 9.
Additional Information
Instead of reiterating the information in the Brochure that is found in Items 9 (Disciplinary Information), 10
(Other Financial Industry Activities and Affiliations) 11 (Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading), 13 (Review of Accounts), 14 (Client Referrals and Other
Compensation), and 18 (Financial Information), that information is incorporated by reference. Clients and
prospective clients should review those sections of the Brochure carefully.
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