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Item 1: Cover Page
Part 2A of Form ADV: Firm Brochure
January 2026
BUCHER WEALTH ADVISORS
1730 S. EL CAMINO REAL, SUITE 250
SAN MATEO, CA 94402
FIRM CONTACT:
BRETT BUCHER
CHIEF COMPLIANCE OFFICER
FIRM WEBSITE ADDRESS:
WWW.BUCHERWA.COM
This brochure provides information about the qualifications and business practices of BWA, LLC dba
Bucher Wealth Advisors. If clients have any questions about the contents of this brochure, please
contact us at (650) 286-9606 or by email at brett@bucherwa.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 information about our firm is also available on the SEC’s
website at www.adviserinfo.sec.gov by searching CRD #
154878.
Please note that the use of the term “registered investment adviser” and description of our firm
and/or our associates as “registered” does not imply a certain level of skill or training. Clients are
encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise
clients for more information on the qualifications of our firm and our employees.
Item 2: Material Changes
Bucher Wealth Advisors is required to notify clients of any information that has changed since the
last annual update of the Firm Brochure (“Brochure”) that may be important to them. Clients can
request a full copy of our Brochure or contact us with any questions that they may have about the
changes.
rd
, 2025, our firm has no material changes to
Since the last annual amendment filed on January 23
disclose.
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Item 3: Table of Contents
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Item 1: Cover Page
Item 2: Material Changes
Item 3: Table of Contents
Item 4: Advisory Business
Item 5: Fees & Compensation
Item 6: Performance-Based Fees & Side-By-Side Management
Item 7: Types of Clients & Account Requirements
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
Item 9: Disciplinary Information
Item 10: Other Financial Industry Activities & Affiliations
Item 11: Code of Ethics, Participation or Interest in
Item 12: Brokerage Practices
Item 13: Review of Accounts or Financial Plans
Item 14: Client Referrals & Other Compensation
Item 15: Custody
Item 16: Investment Discretion
Item 17: Voting Client Securities
Item 18: Financial Information
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Bucher Wealth Advisors
Item 4: Advisory Business
Our firm is dedicated to providing individuals and other types of clients with a wide array of
investment advisory services. Our firm is a limited liability company formed under the laws of the
State of California and has been in business as an investment adviser since 2010. Our firm is wholly
owned by Brett Bucher.
The purpose of this Brochure is to disclose the conflicts of interest associated with the investment
transactions, compensation and any other matters related to investment decisions made by our firm
or its representatives. As a fiduciary, it is our duty to always act in the client’s best interest. This is
accomplished in part by knowing our client. Our firm has established a service-oriented advisory
practice with open lines of communication for many different types of clients to help meet their
financial goals while remaining sensitive to risk tolerance and time horizons. Working with clients to
understand their investment objectives while educating them about our process, facilitates the kind
of working relationship we value.
Types of Advisory Services Offered
Asset Management:
As part of our Asset Management service, a portfolio is created, consisting of individual stocks, bonds,
exchange traded funds (“ETFs”), options, mutual funds and other public and private securities or
investments. The client’s individual investment strategy is tailored to their specific needs and may
include some or all of the previously mentioned securities. Portfolios will be designed to meet a
particular investment goal, determined to be suitable to the client’s circumstances. Once the appropriate
portfolio has been determined, portfolios are continuously and regularly monitored, and if necessary,
rebalanced based upon the client’s individual needs, stated goals and objectives.
When appropriate, our firm may provide advisory services through certain programs sponsored by
other investment managers in the form of separately managed accounts (“SMA or “SMA(s)”). SMA
services may be provided as part of our firm’s Asset Management service. Based on the client's
individual circumstances we determine which selected manager's portfolio management style is
appropriate for that client. Factors considered in making this determination include account size, risk
tolerance, the objectives of each client and the investment philosophy of the selected manager.
Clients should refer to the manager's Firm Brochure or other disclosure document for a full
description of the services offered. Clients are required to sign a separate agreement with the SMA(s)
that we recommend.
Our firm will contact clients from time to time in order to review their financial situation and
objectives; communicate information to SMA(s) as warranted and assist the client in understanding
and evaluating the services provided by the SMA(s). Clients will be expected to notify our firm of any
changes in their financial situation, investment objectives, or account restrictions that could affect
their financial standing.
*Use of Pontera® to manage assets “held away”:
We provide an additional service for accounts
not directly held in our custody and may leverage an Order Management System to implement tax-
efficient asset location and opportunistic rebalancing strategies on behalf of the client with their
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Bucher Wealth Advisors
authorization. These are primarily 401(k) accounts, HSA’s, and other assets we do not custody. We
regularly review the available investment options in these accounts, monitor them, and rebalance
and implement our strategies in the same way we do other accounts, though using different tools as
necessary.
Financial Planning:
Our firm provides a variety of standalone financial planning and consulting services to clients for the
management of financial resources based upon an analysis of current situation, goals, and objectives.
Financial planning services will typically involve preparing a financial plan or rendering a financial
consultation for clients based on the client’s financial goals and objectives. This planning or
consulting may encompass Investment Planning, Retirement Planning, Estate Planning, Charitable
Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study,
Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of
Credit Evaluation, or Business and Personal Financial Planning.
Written financial plans or financial consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the clients.
Implementation of the recommendations will be at the discretion of the client. Our firm provides
clients with a summary of their financial situation, and observations for financial planning
engagements. Financial consultations are not typically accompanied by a written summary of
observations and recommendations, as the process is less formal than the planning service. Assuming
that all the information and documents requested from the client are provided promptly, plans or
consultations are typically completed within 6 months of the client signing a contract with our firm.
Tailoring of Advisory Services
Our firm offers individualized investment advice to our Asset Management clients. General
investment advice will be offered to our Financial Planning clients.
Our firm does not usually allow Asset Management clients to impose restrictions on investing in
certain securities or types of securities due to the level of difficulty this would entail in managing
their account. Exceptions will be made on a case-by-case basis.
Participation in Wrap Fee Programs
We only offer Wrap Asset Management to legacy clients who have already engaged us for this service.
All new clients will be required to execute a “non-wrap” Agreement in order to engage our firm for
investment advisory services.
Regulatory Assets Under Management
Our firm manages $0 on a discretionary basis and $146,886,515 on a non-discretionary basis as of
December 31, 2025.
Item 5: Fees & Compensation
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Bucher Wealth Advisors
Compensation for Our Advisory Services
Asset Management:
The maximum annual fee charged for this service will not exceed 1.25%. Fees to be assessed will be
outlined in the advisory agreement to be signed by the Client. Our firm bills on cash unless otherwise
indicated in writing. Annualized fees are billed on a pro-rata basis quarterly in advance based on the
value of the account(s) on the last day of the previous quarter. Fees are negotiable and will be
deducted from client account(s). In rare cases, our firm will agree to directly invoice.
Our firm may recommend SMAs, these fees are separate from and in addition to our firm’s fees. The
maximum fee for clients utilizing SMAs and our firm’s fees will not exceed 1.75%. Exact fees and fee-
paying arrangements charged by SMA’s will be disclosed in the SMA’s advisory agreement (that is
separate from our firm’s), Firm Brochure, or other disclosure document(s). The SMA’s fees will be
deducted directly from the clients’ account. Our firm does not receive a portion of these fees and the
SMAs’ fees do not have any bearing on the fee our firm charges for our services.
As part of this process, Clients understand the following:
a)
b)
c)
The client’s independent custodian sends statements at least quarterly showing the market
values for each security included in the Assets and all account disbursements, including the
amount of the advisory fees paid to our firm;
Clients will provide authorization permitting our firm to be directly paid by these terms. Our
firm will send an invoice directly to the custodian; and
If our firm sends a copy of our invoice to the client, a legend urging the comparison of
information provided in our statement with those from the qualified custodian will be
included.
For held away assets utilizing the Pontera® platform, Pontera® charges an Annualized fee of 0.25%,
charged quarterly in advance based on the value of the account(s) on the last day of the previous
quarter. The fee in the first quarter of service is pro-rated from the inception date of the account(s)
to the end of the first quarter. Pro-rated adjustments to the prior quarter’s invoice only are applicable
when accounts are added or removed, not when there are inflows or outflows for existing accounts.
In the event the Client cancels a subscription, Client will be billed the pro-rated quarterly payment
for the quarter in which such cancellation occurs. Our firm will not charge clients the 0.25%
Pontera® fee and will cover the additional cost of this service.
Financial Planning & Consulting:
Our firm charges on a flat fee basis for financial planning and consulting services. The total estimated
fee, as well as the ultimate fee charged, is based on the scope and complexity of our engagement with
the client. Flat fees will not exceed $2,500. Our firm requires a retainer of 50% of the ultimate
financial planning or consulting fee at the time of signing. The remainder of the fee will be directly
billed to the client and due within 30 days of a financial plan being delivered or consultation
rendered. Our firm will not require a retainer exceeding $1,200 when services cannot be rendered
within 6 months.
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Bucher Wealth Advisors
Other Types of Fees & Expenses
will
incur transaction fees for trades executed by their chosen custodian,
Asset Management Clients
via individual transaction charges. These transaction fees are separate from our firm’s advisory fees
and will be disclosed by the chosen custodian.
Charles Schwab & Co., Inc. (“Schwab”) does not charge transaction fees for U.S. listed equities
and exchange traded funds.
Fidelity Brokerage Services (“Fidelity”) eliminated transaction fees for U.S. listed equities and
exchange traded funds for clients who opt into electronic delivery of statements or maintain
at least $1 million in assets at Fidelity. Clients who do not meet either criteria will be subject
to transaction fees charged by Fidelity for U.S. listed equities and exchange traded funds.
Currently, both Schwab & Fidelity charge transaction fees for mutual funds.
Clients may also pay holdings charges imposed by the chosen custodian for certain investments,
charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be
disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), distribution
fees, surrender charges, variable annuity fees, IRA and qualified retirement plan fees, mark-ups and
mark-downs, spreads paid to market makers, fees for trades executed away from custodian, wire
transfer fees and other fees and taxes on brokerage accounts and securities transactions. Our firm
does not receive a portion of these fees.
will not
incur transaction costs for trades by their chosen
Existing Wrap Asset Management Clients
custodian; any assessed transaction fees for these clients will be absorbed by our firm.
Termination & Refunds
Either party may terminate the advisory agreement signed with our firm for Asset Management
services in writing at any time. Upon notice of termination our firm will process a pro-rata refund of
the unearned portion of the advisory fees charged in advance.
Financial Planning & Consulting clients may terminate their agreement at any time before the
delivery of a financial plan by providing written notice. For purposes of calculating refunds, all work
performed by us up to the point of termination shall be calculated at the hourly fee currently in effect.
Clients will receive a pro-rata refund of unearned fees based on the time and effort expended by our
firm.
Commissionable Securities Sales
Our firm and representatives do not sell securities for a commission in advisory accounts.
Item 6: Performance-Based Fees & Side-By-Side Management
Our firm does not charge performance-based fees.
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Item 7: Types of Clients & Account Requirements
Our firm has the following types of clients:
•
•
•
•
Individuals and High Net Worth Individuals;
Trusts, Estates or Charitable Organizations;
Pension and Profit Sharing Plans;
Corporations, Limited Liability Companies and/or Other Business Types
•
Our requirements for opening and maintaining accounts or otherwise engaging us:
Our firm requires a minimum account balance of $1,000,000 for our Asset Management
service. Generally, this minimum account balance requirement is not negotiable and would
be required throughout the course of the client’s relationship with our firm.
Clients who opt into electronic delivery of statements or maintain at least $1 million in assets at
Fidelity will not be charged transaction fees for U.S. listed equities and exchange traded funds.
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
Methods of Analysis
We use the following methods of analysis in formulating our investment advice and/or managing
client assets:
Charting.
In this type of technical analysis, our firm reviews charts of market and security activity
in an attempt to identify when the market is moving up or down and to predict when how long the
trend may last and when that trend might reverse.
Fundamental Analysis.
The analysis of a business's financial statements (usually to analyze the
business's assets, liabilities, and earnings), health, and its competitors and markets. When analyzing
a stock, futures contract, or currency using fundamental analysis there are two basic approaches one
can use: bottom up analysis and top down analysis. The terms are used to distinguish such analysis
from other types of investment analysis, such as quantitative and technical. Fundamental analysis is
performed on historical and present data, but with the goal of making financial forecasts. There are
several possible objectives: (a) to conduct a company stock valuation and predict its probable price
evolution; (b) to make a projection on its business performance; (c) to evaluate its management and
make internal business decisions; (d) and/or to calculate its credit risk.; and (e) to find out the
intrinsic value of the share.
Technical Analysis.
A security analysis methodology for forecasting the direction of prices through
the study of past market data, primarily price and volume. A fundamental principle of technical
analysis is that a market's price reflects all relevant information, so their analysis looks at the history
of a security's trading pattern rather than external drivers such as economic, fundamental and news
events. Therefore, price action tends to repeat itself due to investors collectively tending toward
patterned behavior – hence technical analysis focuses on identifiable trends and conditions.
Technical analysts also widely use market indicators of many sorts, some of which are mathematical
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Bucher Wealth Advisors
transformations of price, often including up and down volume, advance/decline data and other
inputs. These indicators are used to help assess whether an asset is trending, and if it is, the
probability of its direction and of continuation. Technicians also look for relationships between
price/volume indices and market indicators. Technical analysis employs models and trading rules
based on price and volume transformations, such as the relative strength index, moving averages,
regressions, inter-market and intra-market price correlations, business cycles, stock market cycles
or, classically, through recognition of chart patterns. Technical analysis is widely used among traders
and financial professionals and is very often used by active day traders, market makers and pit
traders. The risk associated with this type of analysis is that analysts use subjective judgment to
decide which pattern(s) a particular instrument reflects at a given time and what the interpretation
of that pattern should be.
Cyclical Analysis.
Statistical analysis of specific events occurring at a sufficient number of relatively
predictable intervals that they can be forecasted into the future. Cyclical analysis asserts that cyclical
forces drive price movements in the financial markets. Risks include that cycles may invert or
disappear and there is no expectation that this type of analysis will pinpoint turning points, instead
be used in conjunction with other methods of analysis.
Investment Strategies We Use
We use the following strategies in managing client accounts, provided that such strategies are
appropriate to the needs of the client and consistent with the client's investment objectives, risk
tolerance, and time horizons, among other considerations:
Long Term Purchases.
Our firm may buy securities for your account and hold them for a relatively
long time (more than a year) in anticipation that the security’s value will appreciate over a long
horizon. The risk of this strategy is that our firm could miss out on potential short-term gains that
could have been profitable to your account, or it’s possible that the security’s value may decline
sharply before our firm makes a decision to sell.
Short Term Purchases.
When utilizing this strategy, our firm may also purchase securities with the
idea of selling them within a relatively short time (typically a year or less). Our firm does this in an
attempt to take advantage of conditions that our firm believes will soon result in a price swing in the
securities our firm purchase.
Margin Transactions.
Our firm may purchase stocks, mutual funds, and/or other securities for your
portfolio with money borrowed from your brokerage account. This allows you to purchase more
stock than you would be able to with your available cash, and allows us to purchase stock without
selling other holdings. Margin accounts and transactions are risky and not necessarily appropriate
for every client. The potential risks associated with these transactions are (1) You can lose more
funds than are deposited into the margin account; (2) the forced sale of securities or other assets in
your account; (3) the sale of securities or other assets without contacting you; and (4) you may not
be entitled to choose which securities or other assets in your account(s) are liquidated or sold to
meet a margin call.
Option Writing, Including Covered Options, Uncovered Options or Spreading Strategies.
An
option is a financial derivative that represents a contract sold by one party (the option writer) to
another party (the option holder, or option buyer). The contract offers the buyer the right, but not
the obligation, to buy or sell a security or other financial asset at an agreed-upon price (the strike
price) during a certain period of time or on a specific date (exercise date). Options are extremely
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versatile securities. Traders use options to speculate, which is a relatively risky practice, while
hedgers use options to reduce the risk of holding an asset. In terms of speculation, option buyers and
writers have conflicting views regarding the outlook on the performance of a:
Call Option: Call options give the option to buy at certain price, so the buyer would want the
stock to go up. Conversely, the option writer needs to provide the underlying shares in the
event that the stock's market price exceeds the strike due to the contractual obligation. An
option writer who sells a call option believes that the underlying stock's price will drop
relative to the option's strike price during the life of the option, as that is how he will reap
maximum profit. This is exactly the opposite outlook of the option buyer. The buyer believes
that the underlying stock will rise; if this happens, the buyer will be able to acquire the stock
for a lower price and then sell it for a profit. However, if the underlying stock does not close
above the strike price on the expiration date, the option buyer would lose the premium paid
for the call option.
Put Option: Put options give the option to sell at a certain price, so the buyer would want the
stock to go down. The opposite is true for put option writers. For example, a put option buyer
is bearish on the underlying stock and believes its market price will fall below the specified
strike price on or before a specified date. On the other hand, an option writer who sells a put
option believes the underlying stock's price will increase about a specified price on or before
the expiration date. If the underlying stock's price closes above the specified strike price on
the expiration date, the put option writer's maximum profit is achieved. Conversely, a put
option holder would only benefit from a fall in the underlying stock's price below the strike
price. If the underlying stock's price falls below the strike price, the put option writer is
obligated to purchase shares of the underlying stock at the strike price.
The potential risks associated with these transactions are that (1) all options expire. The closer the
option gets to expiration, the quicker the premium in the option deteriorates; and (2) Prices can move
very quickly. Depending on factors such as time until expiration and the relationship of the stock
price to the option’s strike price, small movements in a stock can translate into big movements in the
underlying options.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear. While the stock
market may increase and the account(s) could enjoy a gain, it is also possible that the stock market
may decrease and the account(s) could suffer a loss. It is important that clients understand the risks
associated with investing in the stock market, and that their assets are appropriately diversified in
investments. Clients are encouraged to ask our firm any questions regarding their risk tolerance.
Capital Risk:
Capital risk is one of the most basic, fundamental risks of investing; it is the risk that
you may lose 100% of your money. All investments carry some form of risk and the loss of capital is
generally a risk for any investment instrument.
Economic Risk:
The prevailing economic environment is important to the health of all businesses.
Some companies, however, are more sensitive to changes in the domestic or global economy than
others. These types of companies are often referred to as cyclical businesses. Countries in which a
large portion of businesses are in cyclical industries are thus also very economically sensitive and
carry a higher amount of economic risk. If an investment is issued by a party located in a country that
experiences wide swings from an economic standpoint or in situations where certain elements of an
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Bucher Wealth Advisors
investment instrument are hinged on dealings in such countries, the investment instrument will
generally be subject to a higher level of economic risk.
Equity (Stock) Market Risk:
Common stocks are susceptible to general stock market fluctuations
and, volatile increases and decreases in value as market confidence in and perceptions of their issuers
change. If you held common stock, or common stock equivalents, of any given issuer, you would
generally be exposed to greater risk than if you held preferred stocks and debt obligations of the
issuer.
ETF & Mutual Fund Risk
: When investing in an ETF or mutual fund, you will bear additional
expenses based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including
the potential duplication of management fees. The risk of owning an ETF or mutual fund generally
reflects the risks of owning the underlying securities, the ETF, or mutual fund holds. Clients will also
incur brokerage costs when purchasing ETFs.
Financial Risk:
Financial risk is represented by internal disruptions within an investment or the
issuer of an investment that can lead to unfavorable performance of the investment. Examples of
financial risk can be found in cases like Enron or many of the dot com companies that were caught
up in a period of extraordinary market valuations that were not based on solid financial footings of
the companies.
Fixed Income Securities Risk:
Typically, the values of fixed-income securities change inversely with
prevailing interest rates. Therefore, a fundamental risk of fixed-income securities is interest rate risk,
which is the risk that their value will generally decline as prevailing interest rates rise, which may
cause your account value to likewise decrease, and vice versa. How specific fixed income securities
may react to changes in interest rates will depend on the specific characteristics of each security.
Fixed-income securities are also subject to credit risk, prepayment risk, valuation risk, and liquidity
risk. Credit risk is the chance that a bond issuer will fail to pay interest and principal in a timely
manner, or that negative perceptions of the issuer’s ability to make such payments will cause the
price of a bond to decline.
Inflation Risk
: Inflation risk involves the concern that in the future, your investment or proceeds
from your investment will not be worth what they are today. Throughout time, the prices of resources
and end-user products generally increase and thus, the same general goods and products today will
likely be more expensive in the future. The longer an investment is held, the greater the chance that
the proceeds from that investment will be worth less in the future than what they are today. Said
another way, a dollar tomorrow will likely get you less than what it can today.
Interest Rate Risk:
Certain investments involve the payment of a fixed or variable rate of interest to
the investment holder. Once an investor has acquired or has acquired the rights to an investment that
pays a particular rate (fixed or variable) of interest, changes in overall interest rates in the market
will affect the value of the interest-paying investment(s) they hold. In general, changes in prevailing
interest rates in the market will have an inverse relationship to the value of existing, interest paying
investments. In other words, as interest rates move up, the value of an instrument paying a particular
rate (fixed or variable) of interest will go down. The reverse is generally true as well.
Legal/Regulatory Risk:
Certain investments or the issuers of investments may be affected by
changes in state or federal laws or in the prevailing regulatory framework under which the
investment instrument or its issuer is regulated. Changes in the regulatory environment or tax laws
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can affect the performance of certain investments or issuers of those investments and thus, can have
a negative impact on the overall performance of such investments.
Liquidity Risk:
Certain assets may not be readily converted into cash or may have a very limited
market in which they trade. This can create a substantial delay in the receipt of proceeds from an
investment. Liquidity risk can also result in unfavorable pricing when exiting (i.e. not being able to
quickly get out of an investment before the price drops significantly) a particular investment and
therefore, can have a negative impact on investment returns.
Manager Risk:
There is always the possibility that poor security selection will cause your
investments to underperform relative to benchmarks or other funds with a similar investment
objective.
Market Risk:
The value of your portfolio may decrease if the value of an individual company or
multiple companies in the portfolio decreases or if our belief about a company’s intrinsic worth is
incorrect. Further, regardless of how well individual companies perform, the value of your portfolio
could also decrease if there are deteriorating economic or market conditions. It is important to
understand that the value of your investment may fall, sometimes sharply, in response to changes in
the market, and you could lose money. Investment risks include price risk as may be observed by a
drop in a security’s price due to company specific events (e.g. earnings disappointment or downgrade
in the rating of a bond) or general market risk (e.g. such as a “bear” market when stock values fall in
general). For fixed-income securities, a period of rising interest rates could erode the value of a bond
since bond values generally fall as bond yields go up. Past performance is not a guarantee of future
returns.
Alternative Investments:
Hedge funds, commodity pools, Real Estate Investment Trusts (“REITs”),
Business Development Companies (“BDCs”), and other alternative investments involve a high degree
of risk and can be illiquid due to restrictions on transfer and lack of a secondary trading market. They
can be highly leveraged, speculative and volatile, and an investor could lose all or a substantial
amount of an investment. Alternative investments may lack transparency as to share price, valuation
and portfolio holdings. Complex tax structures often result in delayed tax reporting. Compared to
mutual funds, hedge funds and commodity pools are subject to less regulation and often charge
higher fees and may require “capital calls” which would require additional investment. Alternative
investment managers typically exercise broad investment discretion and may apply similar
strategies across multiple investment vehicles, resulting in less diversification.
Options Risk
: Options on securities may be subject to greater fluctuations in value than an
investment in the underlying securities. Additionally, options have an expiration date, which makes
them “decay” in value over the amount of time they are held and can expire worthless. Purchasing
and writing put and call options are highly specialized activities and entail greater than ordinary
investment risks.
Past Performance:
Charting and technical analysis are often used interchangeably. Technical
analysis generally attempts to forecast an investment’s future potential by analyzing its past
performance and other related statistics. In particular, technical analysis often times involves an
evaluation of historical pricing and volume of a particular security for the purpose of forecasting
where future price and volume figures may go. As with any investment analysis method, technical
analysis runs the risk of not knowing the future and thus, investors should realize that even the most
diligent and thorough technical analysis cannot predict or guarantee the future performance of any
particular investment instrument or issuer thereof.
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Strategy Risk:
There is no guarantee that the investment strategies discussed herein will work under
all market conditions and each investor should evaluate his/her ability to maintain any investment
he/she is considering in light of his/her own investment time horizon. Investments are subject to
risk, including possible loss of principal.
Description of Material, Significant or Unusual Risks
Our firm generally invests client cash balances in money market funds, FDIC Insured Certificates of
Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, our
firm tries to achieve the highest return on client cash balances through relatively low-risk
conservative investments. In most cases, at least a partial cash balance will be maintained in a money
market account so that our firm may debit advisory fees for our services related to our Asset
Management service, as applicable.
Item 9: Disciplinary Information
There are no legal or disciplinary events that are material to the evaluation of our advisory business
or the integrity of our management.
Item 10: Other Financial Industry Activities & Affiliations
Representatives of our firm are insurance agents/brokers. They offer insurance products and receive
customary fees as a result of insurance sales. A conflict of interest exists as these insurance sales
create an incentive to recommend products based on the compensation adviser and/or our
supervised persons may earn. To mitigate this potential conflict, our firm will act in the client’s best
interest.
Item 11: Code of Ethics, Participation or Interest in
Client Transactions & Personal Trading
As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material
facts and to act solely in the best interest of each of our clients at all times. Our fiduciary duty is the
underlying principle for our firm’s Code of Ethics, which includes procedures for personal securities
transaction and insider trading. Our firm requires all representatives to conduct business with the
highest level of ethical standards and to comply with all federal and state securities laws at all times.
Upon employment with our firm, and at least annually thereafter, all representatives of our firm will
acknowledge receipt, understanding and compliance with our firm’s Code of Ethics. Our firm and
representatives must conduct business in an honest, ethical, and fair manner and avoid all circumstances
that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure
is provided to give all clients a summary of our Code of Ethics. If a client or a potential client wishes to
review our Code of Ethics in its entirety, a copy will be provided promptly upon request.
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Bucher Wealth Advisors
Our firm recognizes that the personal investment transactions of our representatives demands the
application of a Code of Ethics with high standards and requires that all such transactions be carried out
in a way that does not endanger the interest of any client. At the same time, our firm also believes that if
investment goals are similar for clients and for our representatives, it is logical, and even desirable, that
there be common ownership of some securities.
1
In order to prevent conflicts of interest, our firm has established procedures for transactions effected by
. In order to monitor compliance with our personal
our representatives for their personal accounts
trading policy, our firm has pre-clearance requirements and a quarterly securities transaction reporting
system for all of our representatives.
Neither our firm nor a related person recommends, buys or sells for client accounts, securities in
which our firm or a related person has a material financial interest without prior disclosure to the
client.
Related persons of our firm may buy or sell securities and other investments that are also
recommended to clients. In order to minimize this conflict of interest, our related persons will place
client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which
is available upon request.
Likewise, related persons of our firm buy or sell securities for themselves at or about the same time they
buy or sell the same securities for client accounts. In order to minimize this conflict of interest, our
related persons will place client interests ahead of their own interests and adhere to our firm’s Code of
Ethics, a copy of which is available upon request. Further, our related persons will refrain from buying
or selling securities that will be bought or sold in client accounts unless done so after the client execution
or concurrently as a part of a block trade.
Item 12: Brokerage Practices
Custodian & Brokers Used
Item 15
Our firm does not maintain custody of client assets (although our firm may be deemed to have
Custody
custody of client assets if give the authority to withdraw assets from client accounts. See
, below). Client assets must be maintained in an account at a “qualified custodian,” generally
a broker-dealer or bank. Our firm recommends that clients use the Schwab Advisor Services division
of Charles Schwab & Co. Inc. (“Schwab”), a FINRA-registered broker-dealer, member SIPC, as the
qualified custodian. Our firm is independently owned and operated, and not affiliated with Schwab.
Schwab will hold client assets in a brokerage account and buy and sell securities when instructed.
While our firm recommends that clients use Schwab as custodian/broker, clients will decide whether
to do so and open an account with Schwab by entering into an account agreement directly with them.
Our firm does not open the account. Even though the account is maintained at Schwab, our firm can
still use other brokers to execute trades, as described in the next paragraph.
1
For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse,
his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our
associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect
beneficial interest in.
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Bucher Wealth Advisors
In addition, our firm recommends that clients use National Financial Services LLC and Fidelity
Brokerage Services LLC (collectively, and together with all affiliates, "Fidelity") through which Fidelity
provides our firm with "institutional platform services." Our firm is independently operated and owned
and is not affiliated with Fidelity. The institutional platform services include, among others, brokerage,
custody, and other related services. Fidelity's institutional platform services that assist us in managing
and administering clients' accounts include software and other technology that (i) provide access to
client account data (such as trade confirmations and account statements); (ii) facilitate trade execution
and allocate aggregated trade orders for multiple client accounts; (iii) provide research, pricing and
other market data; (iv) facilitate payment of fees from its clients' accounts; and (v) assist with back-office
functions, recordkeeping and client reporting.
Collectively, herein, “Schwab” & “Fidelity” are referred to as “Qualified Custodian.”
How Brokers/Custodians Are Selected
•
Our firm seeks to recommend a custodian/broker who will hold client assets and execute
transactions on terms that are overall most advantageous when compared to other available
providers and their services. A wide range of factors are considered, including, but not limited to:
•
•
•
•
•
•
•
•
combination of transaction execution services along with asset custody services (generally
without a separate fee for custody)
capability to execute, clear and settle trades (buy and sell securities for client accounts)
capabilities to facilitate transfers and payments to and from accounts (wire transfers, check
requests, bill payment, etc.)
breadth of investment products made available (stocks, bonds, mutual funds, exchange
traded funds (ETFs), etc.)
availability of investment research and tools that assist in making investment decisions
quality of services
competitiveness of the price of those services (commission rates, margin interest rates, other
fees, etc.) and willingness to negotiate them
reputation, financial strength and stability of the provider
prior service to our firm and our other clients
Products & Services Available from Qualified Custodian
availability of other products and services that benefit our firm, as discussed below (see
“
”)
Custody & Brokerage Costs
Qualified Custodian generally does not charge a separate for custody services but is compensated by
charging commissions or other fees to clients on trades that are executed or that settle into the
Schwab account. Schwab charges a flat dollar amount as a “prime broker” or “trade away” fee for each
trade that our firm has executed by a different broker-dealer but where the securities bought or the
funds from the securities sold are deposited (settled) into a Schwab account. These fees are in
addition to the commissions or other compensation paid to the executing broker-dealer. Because of
this, in order to minimize client trading costs, our firm has Schwab execute most trades for the
accounts.
Products & Services Available from Schwab
Schwab Advisor Services is Schwab’s business serving independent investment advisory firms like
our firm. They provide our firm and clients with access to its institutional brokerage – trading,
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Bucher Wealth Advisors
custody, reporting and related services – many of which are not typically available to Schwab retail
customers. Schwab also makes available various support services. Some of those services help
manage or administer our client accounts while others help manage and grow our business. Schwab’s
support services are generally available on an unsolicited basis (our firm does not have to request
them) and at no charge to our firm. The availability of Schwab’s products and services is not based
on the provision of particular investment advice, such as purchasing particular securities for clients.
Here is a more detailed description of Schwab’s support services:
Services that Benefit Clients
Qualified Custodian’s institutional brokerage services include access to a broad range of investment
products, execution of securities transactions, and custody of client assets. The investment products
available through Qualified Custodian include some to which our firm might not otherwise have
access or that would require a significantly higher minimum initial investment by firm clients.
Qualified Custodian’s services described in this paragraph generally benefit clients and their
accounts.
Services that May Not Directly Benefit Clients
•
Qualified Custodian also makes available other products and services that benefit our firm but may
not directly benefit clients or their accounts. These products and services assist in managing and
administering our client accounts. They include investment research, both Qualified Custodian’s and
that of third parties. This research may be used to service all or some substantial number of client
accounts, including accounts not maintained at Qualified Custodian. In addition to investment
research, Qualified Custodian also makes available software and other technology that:
•
•
•
•
provides access to client account data (such as duplicate trade confirmations and account
statements);
facilitates trade execution and allocate aggregated trade orders for multiple client accounts;
provides pricing and other market data;
facilitates payment of our fees from our clients’ accounts; and
assists with back-office functions, recordkeeping and client reporting.
Services that Generally Benefit Only Our Firm
•
•
•
•
Qualified Custodian also offers other services intended to help manage and further develop our
business enterprise. These services include:
educational conferences and events
technology, compliance, legal, and business consulting;
publications and conferences on practice management and business succession; and
access to employee benefits providers, human capital consultants and insurance providers.
Qualified Custodian may provide some of these services itself. In other cases, Qualified Custodian will
arrange for third-party vendors to provide the services to our firm. Qualified Custodian may also
discount or waive fees for some of these services or pay all or a part of a third party’s fees. Qualified
Custodian may also provide our firm with other benefits, such as occasional business entertainment
for our personnel. Irrespective of direct or indirect benefits to our client through Qualified Custodian,
our firm strives to enhance the client experience, help clients reach their goals and put client interests
before that of our firm or associated persons.
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Bucher Wealth Advisors
Our Interest in Schwab and Fidelity’s Services.
The availability of these services from Qualified Custodian benefits our firm because our firm does
not have to produce or purchase them. Our firm does not have to pay for these services, and they are
not contingent upon committing any specific amount of business to Qualified Custodian in trading
commissions or assets in custody.
In light of our recommendation with Qualified Custodian, a conflict of interest exists as our firm may
have incentive to require that clients maintain their accounts with Qualified Custodian based on our
interest in receiving Qualified Custodian’s services that benefit our firm rather than based on client
interest in receiving the best value in custody services and the most favorable execution of
transactions. As part of our fiduciary duty to our clients, our firm will endeavor at all times to put the
interests of our clients first. Clients should be aware, however, that the receipt of economic benefits
by our firm or our related persons creates a potential conflict of interest and may indirectly influence
our firm’s choice of Qualified Custodian as a custodial recommendation. Our firm examined this
potential conflict of interest when our firm chose to recommend Qualified Custodian and have
determined that the recommendation is in the best interest of our firm’s clients and satisfies our
fiduciary obligations, including our duty to seek best execution.
In seeking best execution, the determinative factor is not the lowest possible cost, but whether the
transaction represents the best qualitative execution, taking into consideration the full range of a
broker-dealer’s services, including the value of research provided, execution capability, commission
rates, and responsiveness. Although our firm will seek competitive rates, to the benefit of all clients,
our firm may not necessarily obtain the lowest possible commission rates for specific client account
transactions. Our firm believes that the selection of Qualified Custodian as a custodian and broker is
the best interest of our clients. It is primarily supported by the scope, quality and price of Qualified
Custodian’s services, and not Qualified Custodian’s services that only benefit our firm.
Soft Dollars
Our firm does not receive soft dollars in excess of what is allowed by Section 28(e) of the Securities
Exchange Act of 1934. The safe harbor research products and services obtained by our firm will
generally be used to service all of our clients but not necessarily all at any one particular time.
Client Brokerage Commissions
Qualified Custodian does not make client brokerage commissions generated by client transactions
available for our firm’s use.
Client Transactions in Return for Soft Dollars
Our firm does not direct client transactions to a particular broker-dealer in return for soft dollar
benefits.
Brokerage for Client Referrals
Our firm does not receive brokerage for client referrals.
Directed Brokerage
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Bucher Wealth Advisors
In certain instances, clients may seek to limit or restrict our discretionary authority in making the
determination of the brokers with whom orders for the purchase or sale of securities are placed for
execution, and the commission rates at which such securities transactions are effected. Clients may
seek to limit our authority in this area by directing those transactions (or some specified percentage
of transactions) be executed through specified brokers in return for portfolio evaluation or other
services deemed by the client to be of value. Any such client direction must be in writing (often
through our advisory agreement) and may contain a representation from the client that the
arrangement is permissible under its governing laws and documents, if this is relevant.
Our firm provides appropriate disclosure in writing to clients who direct trades to particular brokers,
that with respect to their directed trades, they will be treated as if they have retained the investment
discretion that our firm otherwise would have in selecting brokers to effect transactions and in
negotiating commissions and that such direction may adversely affect our ability to obtain best price
and execution. In addition, our firm will inform clients in writing that the trade orders may not be
aggregated with other clients’ orders and that direction of brokerage may hinder best execution.
Special Considerations for ERISA Clients
A retirement or ERISA plan client may direct all or part of portfolio transactions for its account
through a specific broker or dealer in order to obtain goods or services on behalf of the plan. Such
direction is permitted provided that the goods and services provided are reasonable expenses of the
plan incurred in the ordinary course of its business for which it otherwise would be obligated and
empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services
purchased are not for the exclusive benefit of the plan. Consequently, our firm will request that plan
sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will
be for the exclusive benefit of the plan.
Client-Directed Brokerage
Our firm generally does not allow client-directed brokerage outside our recommendations. The
potential risks of directing brokerage outside of our firm’s recommendation is that our firm may be
unable to achieve the most favorable execution of client transactions. Client directed brokerage may
cost clients more money.
Item 13: Review of Accounts or Financial Plans
Our management personnel or financial advisors review accounts on at least a quarterly basis for our
Asset Management clients. The nature of these reviews is to learn whether client accounts are in line
with their investment objectives, appropriately positioned based on market conditions, and
investment policies, if applicable. Our firm does not provide written reports to clients, unless asked
to do so. Verbal reports to clients take place on at least an annual basis when our Asset Management,
clients are contacted.
Our firm may review client accounts more frequently than described above. Among the factors which
may trigger an off-cycle review are major market or economic events, the client’s life events, requests
by the client, etc.
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Bucher Wealth Advisors
Financial Planning clients do not receive reviews of their written plans unless they take action to
schedule a financial consultation with us. Our firm does not provide ongoing services to financial
planning clients, but are willing to meet with such clients upon their request to discuss updates to
their plans, changes in their circumstances, etc. Financial Planning clients do not receive written or
verbal updated reports regarding their financial plans unless they separately engage our firm for a
post-financial plan meeting or update to their initial written financial plan.
Item 14: Client Referrals & Other Compensation
Schwab & Fidelity
Except for the arrangements outlined in Item 12 of Form ADV Part 2A, our firm has no additional
arrangements to disclose.
Referral Fees
Our firm does not pay referral fees (non-commission based) to independent solicitors (non-
registered representatives) for the referral of their clients to our firm in accordance with the
Investment Advisers Act of 1940.
Item 15: Custody
Deduction of Advisory Fees:
While our firm does not maintain physical custody of client assets (which are maintained by a
qualified custodian, as discussed above), we are deemed to have custody of certain client assets if
given the authority to withdraw assets from client accounts, as further described below under “Third
Party Money Movement.” All of our clients receive account statements directly from their qualified
custodian(s) at least quarterly upon opening of an account. We urge our clients to carefully review
these statements. Additionally, if our firm decides to send its own account statements to clients, such
statements will include a legend that recommends the client compare the account statements
received from the qualified custodian with those received from our firm. Clients are encouraged to
raise any questions with us about the custody, safety or security of their assets and our custodial
recommendations.
Third Party Money Movement:
On February 21, 2017, the SEC issued a no-action letter (“Letter”) with respect to Rule 206(4)-2
(“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided
guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client
funds to a third party under a standing letter of authorization (“SLOA”) is deemed to have custody.
As such, our firm has adopted the following safeguards in conjunction with our custodian:
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Bucher Wealth Advisors
•
•
•
•
•
•
•
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.
The client authorizes the investment adviser, 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.
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.
The client has the ability to terminate or change the instruction to the client’s qualified
custodian.
The investment adviser 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.
The investment adviser maintains records showing that the third party is not a related party
of the investment adviser or located at the same address as the investment adviser.
The client’s qualified custodian sends the client, in writing, an initial notice confirming the
instruction and an annual notice reconfirming the instruction.
Pontera®:
Our firm has entered into an agreement with Pontera®, a platform allowing our firm to manage
accounts held away from our recommend custodian without obtaining client login information and
as such avoiding custody. Information about the fees associated with this platform is disclosed in
Item 5 of this Brochure.
Item 16: Investment Discretion
Our firm does not accept discretionary authority to manage securities accounts on behalf of clients.
Item 17: Voting Client Securities
We do not and will not accept the proxy authority to vote client securities. Clients will receive
proxies or other solicitations directly from their custodian or a transfer agent. In the event that
proxies are sent to our firm, we will forward them on to you and ask the party who sent them to
mail them directly to you in the future. Clients may call, write or email us to discuss questions they
may have about particular proxy votes or other solicitations.
However, third party money managers selected or recommended by our firm may vote proxies for
clients. Therefore, except in the event a third party money manager votes proxies, clients maintain
exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers of
securities beneficially owned by the client shall be voted, and (2) making all elections relative to
any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to
the client’s investment assets. Therefore (except for proxies that may be voted by a third party
money manager), our firm and/or you shall instruct your qualified custodian to forward to you
copies of all proxies and shareholder communications relating to your investment assets.
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Bucher Wealth Advisors
Item 18: Financial Information
•
Our firm is not required to provide financial information in this Brochure because:
•
•
•
Our firm does not require the prepayment of more than $1,200 in fees when services cannot
be rendered within 6 months.
Our firm does not take custody of client funds or securities.
Our firm does not have a financial condition or commitment that impairs our ability to meet
contractual and fiduciary obligations to clients.
Our firm has never been the subject of a bankruptcy proceeding.
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Bucher Wealth Advisors