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ITEM 1
COVER PAGE
4600 S. Syracuse Street, Suite 650
Denver, CO 80237
Phone: 888-210-6567
August 2025
Part 2A Brochure
is available on
This brochure provides information about the qualifications and business practices of Buck Wealth
Strategies, LLC (“BWS”). If you have any questions about the contents of this brochure, please contact
us at 720-420-4870. 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. Buck Wealth Strategies,
LLC is a Registered Investment Adviser. Registration with the United States Securities and Exchange
Commission or any state securities authority does not imply a certain level of skill or training. Additional
information about Buck Wealth Strategies, LLC
the SEC’s website at
www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as an IARD
number. The IARD number for Buck Wealth Strategies, LLC is 322138.
BUCK WEALTH STRATEGIES, LLC
August 2025 | PAGE 1
Item 2- Material Changes
SUMMARY OF MATERIAL CHANGES
This section of the Brochure will address only those “material changes” that have been
incorporated since our last delivery or posting of this document on the SEC’s public
disclosure website (IAPD) www.adviserinfo.sec.gov.
Item 4: Advisory Business:
The Assets Under Management were updated as of December 31, 2024.
Item 10: Other Financial Industry Activities and Affiliations:
The Brochure was updated to include new business activities and affiliated entities
for Buck Financial Services – Achieve Retirement, LLC (dba Achieve Retirement),
Buck Private Wealth Group LLC, and Buck Financial Partners LLC.
Currently, a free copy of our Brochure may be requested by contacting Jim Dixon, Chief
Compliance Officer of BWS at 888-210-6567 or via email at jdixon@eabuck.com
Our Firm encourages you to read this document in its entirety.
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August 2025 | PAGE 2
ITEM 3
TABLE OF CONTENTS
ITEM 1 COVER PAGE
1
Item 2- Material Changes
2
TABLE OF CONTENTS
ITEM 3
3
ITEM 4 ADVISORY BUSINESS
3
ITEM 5 - FEES AND COMPENSATION
11
ITEM 6 - PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT
15
ITEM 7 - TYPES OF CLIENTS
15
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
16
ITEM 9 - DISCIPLINARY INFORMATION
22
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
23
ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND
PERSONAL TRADING
27
ITEM 12 - BROKERAGE PRACTICES
28
ITEM 13 - REVIEW OF ACCOUNTS
33
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION
34
ITEM 15 – CUSTODY
35
ITEM 16 – INVESTMENT DISCRETION
37
ITEM 17 – VOTING CLIENT SECURITIES
38
ITEM 18 – FINANCIAL INFORMATION
38
ITEM 4
ADVISORY BUSINESS
This Disclosure document is being offered to you by Buck Wealth Strategies, LLC (“BWS”
“E.A. Buck” or “Firm”) about the investment advisory services our Firm provides. It
discloses information about the services that our Firm provides and the way those services
are made available to you, the client.
BUCK WEALTH STRATEGIES, LLC
August 2025 | PAGE 3
Buck Wealth Strategies, LLC was registered as an Investment Advisor with the SEC in July
2022. BWS is owned by Buck Enterprise, Inc. James Dixon is the Chief Compliance Officer
of the Firm.
Our Firm is committed to helping clients build, manage, and preserve their wealth. Our
Firm provides services that help clients to achieve their stated financial goals. BWS will
offer initial complimentary meetings upon our discretion; however, investment advisory
services are initiated only after you and BWS execute a Discretionary Investment
Management Services - Client Agreement (“Agreement”).
INVESTMENT MANAGEMENT AND SUPERVISION SERVICES
BWS manages advisory accounts on a discretionary basis. For discretionary accounts, once
we have determined a profile and investment plan with a client, our Firm will execute the
day-to-day transactions without seeking prior client consent but within the expected
investment guidelines. Account supervision is guided by the client’s written profile and
if
investment plan. BWS will accept accounts with certain trading restrictions
circumstances warrant. Our Firm will primarily allocate client assets among various
equities, Exchanged Traded Funds (“ETFs”), no-load or load-waived mutual funds in
accordance with their stated investment objectives. All of which are considered asset
allocation categories for the client’s investment strategy.
During personal discussions with clients, our Firm will determine the client’s objectives,
time horizons, risk tolerance, and liquidity needs. As appropriate, our Firm will also review
a client’s prior investment history, as well as family composition and background. Based
on client needs, BWS will develop a client’s personal profile and investment plan. We then
create and manage the client’s investments based on that policy and plan. It is the client’s
obligation to notify us immediately if circumstances have changed with respect to their
goals. Once we have determined the types of investments to be included in a client’s
portfolio and have allocated the assets, we provide ongoing investment review and
management services. With our discretionary relationship, BWS will make changes to the
portfolio, as we deem appropriate, to meet client financial objectives. Our Firm will trade
these portfolios based on the combination of our market views and client objectives, using
our investment process. BWS will tailor our advisory services to meet the needs of our
clients and seek to ensure that your portfolio is managed in a manner consistent with
those needs and objectives. Clients have the ability to leave standing instructions with us
to refrain from investing in particular industries or securities or invest in limited amounts
of securities.
Clients may engage us to advise on certain investment products that are not maintained
at our Firm’s recommended custodian, and assets held in employer sponsored retirement
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August 2025 | PAGE 4
plans. Where appropriate, our Firm will provide advice about any type of held-away
account that is part of a client portfolio.
You are advised and are expected to understand that our past performance is not a
guarantee of future results. Certain market and economic risks exist that adversely affect
an account’s performance. This could result in capital losses in your account.
Buck Wealth Strategies has engaged AE Wealth Management, LLC (“AEWM”), an SEC
registered investment advisor, to provide asset management services to our clients.
Registration does not imply a certain level of skill or training.
The Program provides clients with the opportunity to participate in the asset management
services available to BWS through AEWM. Through the Program, AEWM serves as a
Turnkey Asset Management Program (“TAMP”) for Buck Wealth Strategies, and provides
the following services:
• Selection of model managers, portfolio managers, and third-party asset managers
on the platform;
• Research;
• Access to AEWM’s reporting systems, client relationship management systems
and workflow systems;
• Operational support to assist BWS with trading of its client accounts.
FINANCIAL PLANNING
Through the financial planning process, our team strives to engage our clients in
conversations around the family’s goals, objectives, priorities, vision, and legacy – both for
the near term as well as for future generations. With the unique goals and circumstances
of each family in mind, our team will offer financial planning ideas and strategies to
address the client’s holistic financial picture, including estate, income tax, charitable, cash
flow, wealth transfer, and family legacy objectives. Our team partners with our client’s
other advisors (CPAs, Enrolled Agents, Estate Attorneys, Insurance Brokers, etc.) to ensure
a coordinated effort of all parties toward the client’s stated goals. Such services include
various reports on specific goals and objectives or general investment and/or planning
recommendations, guidance to outside assets, and periodic updates.
Our specific services in preparing your plan include:
• Review and clarification of your financial goals.
• Assessment of your overall financial position including cash flow, balance sheet,
investment strategy, risk management, and estate planning.
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August 2025 | PAGE 5
• Creation of a unique plan for each goal you have, including personal and business
real estate, education, retirement or financial independence, charitable giving,
estate planning, business succession, and other personal goals.
• Development of a goal-oriented investment plan, with input from various advisors
to our clients around tax suggestions, asset allocation, expenses, risk, and liquidity
factors for each goal. This includes IRA and qualified plans, taxable, and trust
accounts that require special attention.
• Design of a risk management plan including risk tolerance, risk avoidance,
mitigation, and transfer, including liquidity as well as various insurance and
possible company benefits; and
• Crafting and implementation of, in conjunction with your estate and/or corporate
attorneys as tax advisor, an estate plan to provide for you and/or your heirs in the
event of an incapacity or death.
A written evaluation of each client's initial situation or Financial Plan is provided to the
client.
RETIREMENT PLAN ADVISORY SERVICES
Retirement Plan Advisory Services consists of helping employer plan sponsors (“the
Sponsor”) to establish, monitor and review their company's retirement plan. Our firm
offers (1) Discretionary
Investment Management Services, (2) Non-Discretionary
Investment Management Services and/or (3) Retirement Plan Consulting Services to
employer-sponsored retirement plans and their participants. Depending on the type of
the Plan and the specific arrangement with the Sponsor, we may provide one or more of
these services. Prior to being engaged by the Sponsor, we will provide a copy of this Form
ADV Part 2A along with a copy of our Privacy Policy and the Investment Fiduciary &
Retirement Plan Consulting Agreement ("Agreement") that contains the information
required under Sec. 408(b)(2) of the Employee Retirement Income Security Act ("ERISA")
as applicable.
The Agreement authorizes our Investment Adviser Representatives ("IARs") to deliver one
or more of the following services:
DISCRETIONARY INVESTMENT MANAGEMENT SERVICES
These services are designed to allow the Plan fiduciary to delegate responsibility for
managing, acquiring, and disposing of Plan assets that meet the requirements of the
Employee Retirement Income Security Act of 1974 ("ERISA"). We will perform this
investment management service through our IARs and charge fees as described in this
Form ADV and the Agreement. If the Plan is subject to ERISA, we will perform these
services as an “investment manager” as defined under ERISA Section 3(38) and as a
BUCK WEALTH STRATEGIES, LLC
August 2025 | PAGE 6
“fiduciary” to the Plan as defined under ERISA Section 3(21). Specifically, the Sponsor may
determine that we perform the following services:
Selection, Monitoring & Replacement of Designated Investment Alternatives
(“DIA”)
Our Firm will review with the Sponsor the investment objectives, risk tolerance
and goals of the Plan and provide the Sponsor with an IPS that contains criteria
from which we will select, monitor, and replace the Plan's DIAs. Once approved by
Sponsor, we will review the investment options available to the Plan and will select
the Plan's DIAs in accordance with the criteria set forth in the IPS. On a periodic
basis, our Firm will monitor and evaluate the DIAs and replace any DIA(s) that no
longer meet the IPS criteria.
Selection, Monitoring & Replacement of Qualified Default Investment Alternatives
(“QDIA(s)”)
Based upon the options available to the Plan, we will select, monitor, and replace
the Plan's QDIA(s) in accordance with the IPS.
Management Of Trust Fund
Our Firm will review with the Sponsor the investment objectives, risk tolerance
and goals of the Plan and provide the Sponsor with an IPS that contains criteria
from which we will select, monitor, and replace the Plan's investments. Once
approved by Sponsor, our Firm will review the investment options available to the
Plan and will select the Plan's investments in accordance with the criteria set forth
in the IPS. On a periodic basis, we will monitor and evaluate the investments and
replace any investment(s) that no longer meet the IPS criteria.
NON-DISCRETIONARY FIDUCIARY SERVICES
These services are designed to allow the Sponsor to retain full discretionary authority or
control over the assets of the Plan. We will solely be making recommendations to the
Sponsor. We will perform these Non-Discretionary investment management services
through our IARs and charge fees as described in this Form ADV and the Agreement. If the
Plan is covered by ERISA, we will perform these investment management services to the
Plan as a "fiduciary" defined under ERISA Section 3(21). The Sponsor may engage us to
perform one or more of the following Non-Discretionary investment management
services:
Investment Policy Statement (“IPS”)
Our Firm will review with the Sponsor the investment objectives, risk tolerance
and goals of the Plan. If the Plan does not have an IPS, we will provide
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August 2025 | PAGE 7
recommendations to the Sponsor to assist with establishing an IPS. If the Plan has
an existing IPS, our Firm will review it for consistency with the Plan's objectives. If
the IPS does not represent the objectives of the Plan, we will recommend the
Sponsor make revisions to align the IPS with the Plan's objectives.
Advice regarding designated investment alternatives (“DIAs”)
Based on the Plan's IPS or other guidelines established by the Plan, we will review
the investment options available to the Plan and will make recommendations to
assist Sponsor with selecting DIAs to be offered to Plan participants. Once the
Sponsor selects the DIAs, our Firm will, on a periodic basis and/or upon reasonable
request, provide reports and information to assist Sponsor with monitoring the
DIAs. If a DIA is required to be removed, we will provide recommendations to assist
the Sponsor with replacing the DIA.
Advice Regarding Qualified Default Investment Alternatives (“QDIA”)
Based on the Plan's IPS or other guidelines established by the Plan, our Firm will
review the
investment options available to the Plan and will make
recommendations to assist the Sponsor with selecting or replacing the Plan's
QDIA(s).
Participant Investment Advice
Our Firm will meet with Plan participants, upon reasonable request, to collect
information necessary to identify the Plan participant's investment objectives, risk
tolerance, time horizon, etc. We will provide written recommendations to assist
the Plan participant with creating a portfolio using the Plan's DIAs or Models, if
available. The Plan participant retains sole discretion over the investment of
his/her account.
Advice Regarding Investment of Trust Fund
Based on the Plan's IPS, we will review the investment options available to the Plan
and will make recommendations to assist the Sponsor with selecting investments
that meet the IPS criteria. Once the Sponsor selects the investment(s), our Firm
will, on a periodic basis and/or upon reasonable request, provide reports and
information to assist Sponsor with monitoring the investment(s). If the IPS criteria
require any investment(s) to be replaced, we will provide recommendations to
assist the Sponsor with replacing the investment(s).
RETIREMENT PLAN CONSULTING SERVICES
Retirement Plan Consulting Services are designed to allow our IARs to assist the Sponsor
in meeting his/her fiduciary duties to administer the Plan in the best interests of Plan
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August 2025 | PAGE 8
participants and their beneficiaries. Retirement Plan Consulting Services are performed so
that they would not be considered “investment advice” under ERISA. The Sponsor may
elect for our IARs to assist with any of the following services:
Administrative Support
•
•
•
•
•
•
Assist in reviewing objectives and options available through the Plan
Review Plan committee structure and administrative policies/procedures
Recommend Plan participant education and communication policies under
ERISA 404(c)
Assist with development/maintenance of fiduciary audit file
Deliver fiduciary training and/or education periodically
Recommend procedures for responding to Plan participant requests
Service Provider Support
•
•
•
•
•
•
Assist with a process to select, monitor and replace service providers
Assist with review of Covered Service Providers ("CSP") and fee
benchmarking
Provide reports and/or information designed to assist fiduciaries with
monitoring CSPs
Assist with use of ERISA Spending Accounts or Plan Expense Recapture
Accounts to pay CSPs
Assist with preparation and review of Requests for Proposals and/or
Information
Coordinate and assist with CSP replacement and conversion
Investment Monitoring Support
•
•
•
•
Periodic review of investment policy in the context of Plan objectives
Assist the Plan committee with monitoring investment performance
Assist with monitoring Designated Investment Managers and/or third-
party advice providers
Educate Plan committee members, as needed, regarding replacement of
DIA(s) and/or QDIA(s)
Participant Services
•
•
Facilitate group enrollment meetings and coordinate investment education
Assist Plan participants with financial wellness education, retirement
planning and/or gap analysis
Potential Additional Retirement Services Provided Outside of the Agreement
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August 2025 | PAGE 9
In providing Retirement Plan Services, we and our IARs may establish a client relationship
with one or more Plan participants or beneficiaries. Such client relationships develop in
various ways, including, without limitation:
•
as a result of a decision by the Plan participant or beneficiary to purchase
services from us not involving the use of Plan assets;
•
as part of an individual or family financial plan for which any specific
recommendations concerning the allocation of assets or investment
recommendations relating to assets held outside of the Plan; or
•
through a rollover of an Individual Retirement Account ("IRA Rollover"). If
we are providing Retirement Plan Services to a plan, IARs may, when
requested by a Plan participant or beneficiary, arrange to provide services
to that participant or beneficiary through a separate agreement. If a Plan
participant or beneficiary desires to affect an IRA Rollover from the Plan to
an account advised or managed by us, IAR will have a conflict of interest if
his/her fees are reasonably expected to be higher than those we would
otherwise receive in connection with the Retirement Plan Services. IAR will
disclose relevant information about the applicable fees charged by us prior
to opening an IRA account. Any decision to affect the rollover or about
what to do with the rollover assets remains that of the Plan participant or
beneficiary alone.
DISCLOSURE REGARDING ROLLOVER RECOMMENDATIONS
A client or prospect leaving an employer typically has four options regarding an existing
retirement plan (and may engage in a combination of these options): (i) leave the money
in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s
plan, if one is available and rollovers are permitted, (iii) rollover to an Individual
Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending
upon the client’s age, result in adverse tax consequences). Our Firm may recommend an
investor roll over plan assets to an IRA for which our Firm provides investment
management services. As a result, our Firm and its representatives may earn an asset-
based fee. In contrast, a recommendation that a client or prospective client leave their
plan assets with their previous employer or roll over the assets to a plan sponsored by a
new employer will generally result in no compensation to our Firm. Our Firm therefore
has an economic incentive to encourage a client to roll plan assets into an IRA that our
Firm will manage, which presents a conflict of interest. To mitigate the conflict of interest,
there are various factors that our Firm will consider before recommending a rollover,
including but not limited to: (i) the investment options available in the plan versus the
investment options available in an IRA, (ii) fees and expenses in the plan versus the fees
BUCK WEALTH STRATEGIES, LLC
August 2025 | PAGE 10
and expenses in an IRA, (iii) the services and responsiveness of the plan’s investment
professionals versus those of our Firm, (iv) protection of assets from creditors and legal
judgments, (v) required minimum distributions and age considerations, and (vi) employer
stock tax consequences, if any. All rollover recommendations are also reviewed by our
Firm’s Chief Compliance Officer in a best effort to determine that the recommendation to
a client was reasonable or that the client has determined to make the rollover after being
provided ample information about their options. No client is under any obligation to roll
over plan assets to an IRA advised by our Firm or to engage our Firm to monitor and/or
advise on the account while maintained with the client's employer. Our Firm’s Chief
Compliance Officer remains available to address any questions that a client or prospective
client has regarding this disclosure.
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide
investment advice to you regarding your retirement plan account or individual retirement
account, we are also fiduciaries within the meaning of Title I of the Employee Retirement
Income Security Act and/or the Internal Revenue Code, as applicable, which are laws
governing retirement accounts. We have to act in your best interest and not put our
interest ahead of yours. At the same time, the way we make money creates some conflicts
with your interests. BWS is incentivized by encouraging you to bring more assets under
management and thus create more revenue for our firm and/or commissions for our IAR
who are registered representatives of a broker-dealer, licensed to sell insurance products,
or both.
ASSETS
As of December 31, 2024, the firm has $565,377,646 in discretionary assets under
management. The firm has no non-discretionary assets under management.
ITEM 5 - FEES AND COMPENSATION
INVESTMENT MANAGEMENT FEES AND COMPENSATION
BWS charges a fee as compensation for providing Investment Management services on
your account. These services include advisory and consulting services, trade entry,
investment supervision, and other account-maintenance activities. Our recommended
custodian charges transaction costs, custodial fees, redemption fees, retirement plan and
administrative fees or commissions. See Additional Fees and Expenses below for
additional details.
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The fees for portfolio management are based on an annual percentage of assets under
management. Advisory fees are billed monthly in arrears and calculated based on the
average daily balance of the account(s) under management. Advisory relationships that
start after the first of the calendar month will be charged a pro-rated fee from the start
date of the relationship to the end of the calendar month.
Our maximum annual advisory fee is for accounts paying a percentage of assets under
management is 1.50%. The specific advisory fees are set forth in your Investment
Management Agreement. Fees may vary based on the size of the account, complexity of
the portfolio, extent of activity in the account or other reasons agreed upon by us and you
as the client. The market value will be determined as reported by the Custodian. Fees are
assessed on all assets under management. Cash and cash equivalents and any margin debt
balances are included in the calculation of advisory fees, unless otherwise noted and
agreed to in the executed Agreement.
In certain circumstances, our fees and the timing of the fee payments may be negotiated
at our sole discretion.
Our employees and their family-related accounts are charged a reduced fee for our
services.
Unless otherwise instructed by the client, in certain cases, we will aggregate asset
amounts in accounts from your same household together to determine the advisory fee
for all your accounts. For example, if we manage accounts from the individual, our Firm
will include joint accounts for a spouse, minor children and/or Trust accounts. This
consolidation practice is designed to allow you the benefit of an increased asset total,
which could cause your account(s) to be assessed a lower advisory fee.
The independent qualified custodian holding your funds and securities will debit your
account directly for the advisory fee and pay that fee to us. You will provide written
authorization permitting the fees to be paid directly from your account held by the
qualified custodian. Further, the qualified custodian agrees to deliver an account
statement at least quarterly directly to you, indicating all the amounts deducted from the
account including our advisory fees. At our discretion, our Firm will allow advisory fees to
be paid by check as indicated in the Agreement. You are encouraged to review your
account statements for accuracy.
Either BWS or you may terminate the management agreement immediately upon written
notice to the other party. The management fee will be pro-rated to the date of
termination, for the month in which the cancellation notice was given and refunded to
your account. Upon termination, you are responsible for monitoring the securities in your
account, and we will have no further obligation to act or advise with respect to those
assets. In the event of client’s death or disability, BWS will continue management of the
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account until we are notified of client’s death or disability and given alternative
instructions by an authorized party.
FINANCIAL PLANNING FEES
Our Firm offers financial planning services for a separate fee. In this circumstance, our Firm
will negotiate the planning fees with you. Fees may vary based on the extent and
complexity of your individual or family circumstances and the amount of your assets under
our management. Our fee will be agreed in advance of the services being performed. The
fee will be determined based on factors including the complexity of your financial
situation, agreed upon deliverables, and whether you intend to implement any
recommendations through BWS.
Your billing method is agreed to in advance of performing services and is agreed to and
acknowledged in the Financial Planning Agreement executed by you and our Firm. Fifty
percent (50%) of the Financial Planning Fee is collected upon signing the Financial Planning
agreement and the other fifty percent is due upon delivery of the Plan to you. Fees are
paid via check to BWS.
Typically, we complete a plan within a month and will present it to you within 90 days of
the contract date, if you have provided us with all the information needed to prepare the
financial plan.
If you choose to terminate the financial planning agreement by providing us with written
notice. Upon termination, fees will be prorated to the date of termination and any earned
portion of the fee will be billed to you based on the hours that our firm has spent on
creating your financial plan prior to termination. The hourly rate used for this purpose is
$400/hour. The hourly rate would be stated in your executed Financial Planning
Agreement.
We will not require prepayment of more than $1200 in fees per client, six (6) or more
months in advance of providing any services. In no case are our fees based on, or related
to, the performance of your funds or investments.
RETIREMENT PLAN SERVICES
For Retirement Plan Advisory Services compensation, we charge an advisory fee as
negotiated with the Plan Sponsor and as disclosed in the Employer Sponsored Retirement
Plans Consulting Agreement (“Plan Sponsor Agreement”).
Our flat fees range from $2,500 to $50,000. Fees based on a percentage of managed Plan
assets will not exceed 1.00%. Fees are billed monthly or quarterly in arrears and calculated
based on the average daily balance of the Plan’s assets under management. This fee is
generally negotiable at our sole discretion, but terms and the advisory fee are agreed to
in advance and acknowledged by the Plan Sponsor through the Plan Sponsor Agreement
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and/or Plan Provider’s account agreement. Fee billing methods vary depending on the
Plan Provider.
Either our Firm or the Plan Sponsor may terminate the Agreement upon 30 days written
notice to the other party. The Plan Sponsor is responsible to pay for services rendered
until the termination of the Agreement. The management fee will be pro-rated to the date
of termination, for the month in which the cancellation is affected and refunded to your
account.
ADMINISTRATIVE SERVICES
Our Firm utilizes a third party and technology platform to support data reconciliation,
performance reporting, fee calculation and billing, research, client database maintenance,
quarterly performance evaluations, payable reports, web site administration, models,
trading platforms, and other functions related to the administrative tasks of managing
client accounts. Due to this arrangement, the third-party vendor will have access to client
information but will not serve as an investment advisor to our clients. BWS and this third
party are non-affiliated companies. This third party charges our Firm an annual fee for
each account administered by the third party. The annual fee is paid from the portion of
the management fee retained by us.
ADDITIONAL FEES AND EXPENSES
In addition to the advisory fees paid to our Firm, clients also incur certain charges imposed
by other third parties, such as broker-dealers, custodians, trust companies, banks, and
other financial institutions (collectively “Financial Institutions”). These additional charges
include custodial fees, charges imposed by a mutual fund or ETF in a client’s account, as
disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses),
deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic
fund fees, and other fees and taxes on brokerage accounts and securities transactions.
Our brokerage practices are described at length in Item 12, below.
NON-TRANSACTION FEE (NTF) MUTUAL FUNDS
When selecting investments for our clients’ portfolios we might choose mutual funds on
your account custodian’s Non-Transaction Fee (“NTF”) list. This means that your account
custodian will not charge a transaction fee or commission associated with the purchase or
sale of the mutual fund.
The mutual fund companies that choose to participate in your custodian’s NTF fund
program pay a fee to be included in the NTF program. The fee that a mutual fund company
pays to participate in the program is ultimately borne by the owners of the mutual fund
including clients of our Firm. When we decide whether to choose a fund from your
custodian’s NTF list or not, we consider our expected holding period of the fund, the
BUCK WEALTH STRATEGIES, LLC
August 2025 | PAGE 14
position size, and the expense ratio of the fund versus alternative funds. Depending on
our analysis and future events, NTF funds might not always be in your best interest.
Compensation from Advisors Excel
Insurance commissions received from insurance carriers, and other benefits received by
Advisors Excel are significant sources of compensation and are paid separately from
advisory fees on assets in a client’s managed securities account. Commissions are
generally paid up-front, at the time of sale, unlike asset-based advisory fees which are paid
periodically over the course your relationship with Buck Wealth Strategies. This amount
and form of insurance compensation creates a conflict of interest in that our investment
adviser representatives who are dually licensed as insurance agents, are incentivized to
recommend insurance products based on the compensation received rather than on a
client’s needs. Consequently, the advice rendered to you could be biased. You are under
no obligation to implement any insurance or annuity transaction through your investment
adviser representative.
ITEM 6 - PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT
Our Firm does not engage in performance-based fees. No supervised person is
compensated by performance-based fees. Performance-based fees may create an
incentive for the advisor to recommend an investment that may carry a higher degree of
risk.
Our investment professionals simultaneously manage multiple types of client accounts
according to the same, similar, or different investment strategy (e.g., side-by-side
management).
The simultaneous management of these different types of client accounts, with different
fee structures, creates certain conflicts of interest, as the fees for the management of
some client types are higher than for others and gives us incentive to prioritize those
accounts. Nevertheless, when managing the assets of these accounts, we have a duty to
treat all accounts fairly and equitably over time.
ITEM 7 - TYPES OF CLIENTS
Our Firm works with the following types of clients: individuals, high net-worth individuals,
trusts, and employer sponsored retirement plans.
We impose a minimum account value of $25,000 to initiate our Firm’s advisory and money
management services. This minimum account value can be waived at our sole discretion.
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ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
BWS takes a macro-environmental approach to tactical asset allocation with sector
rotation and uses a relative growth/value framework in determining sub-asset classes.
This top-down method allows BWS to assess the investing landscape and provide
recommendations as to when and where it may be advantageous to modify exposures
within the asset classes, market segments, and sectors.
To develop a complete picture of a client’s investment objectives, our investment adviser
representatives work one-on-one with the advisory client through the initial and on-going
planning process to create an investment plan which fits the client’s risk tolerance and
investment objectives. Based on this information, we obtain a broad understanding of the
client’s investment objectives, goals, and the amount of risk the client will tolerate. To
further fine tune our understanding of a client’s risk tolerance, our Firm does utilize third-
party financial planning tools to include life and long-term care insurance, as well as social
security payments, into the overall financial plan.
Such third-party financial planning tools assist our financial planners in two critical tasks:
(1) measuring the risk preferences of investors, and (2) applying these preference
measurements to portfolio selection. These tools summarize an investor’s mean-variance
risk aversion on a 99-point scale. In connection with this output, the third-party financial
planning tools “quantifies” the client’s indicated investment risk tolerance through the
illustration of expected return (plus/minus) and investment volatility (investment
variance) which uses past data to calculate expected variance. Our Firm works with third-
party financial planning tools to customize client portfolios using a combination of existing
holdings and recommended allocation strategies to provide the client with the desired risk
score identified with the third-party financial planning tools. Once a risk score is identified,
our Firm prepares a strategy, which is also scored by third-party financial planning tools.
Generally, clients are recommended a mixture of strategies with various allocations,
including strategies which focus on fixed income, growth, balanced, moderate, or
aggressive investments, which correlate to the client’s risk score. We seek to go beyond a
traditional asset allocation strategy by incorporating investments on each end of the risk
spectrum.
BWS’s growth strategies consist of investments spanning a broad range of asset classes
that are selected for their long-term risk/return characteristics as well as their correlation
to the overall markets and appropriateness for each client’s portfolio. The resulting
blended allocation is used as the foundation for the client's growth portfolio. Portfolio
rebalancing is discretionary and will be based on individual portfolio considerations. There
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is no guarantee as to the number of times a portfolio is rebalanced each year. Other asset
classes and opportunistic investments are added to the growth portfolio to create a
customized allocation that is appropriate for client’s investment objectives, time horizon,
and risk tolerance. Examples of investments which may be included as part of BWS’s
growth strategies include individual equities and exchange traded funds (ETFs).
Fixed income investments such as bonds, notes, and certificates of deposit are intended
to provide diversification, generate income, and to preserve and protect assets. Generally,
the stabilizing influence of fixed income comes at the cost of lower returns relative to
growth investments. BWS’s fixed income portfolios generally consist of high quality
domestically issued bonds, both taxable and tax-free. Examples of investments which may
be included as part of BWS’s fixed income strategies include individual government,
municipal, and corporate bonds, certificates of deposits, exchange traded funds (ETFs),
and money markets.
While there may be some similarities in the portfolios created by BWS, we understand that
every client has their own unique planning needs. We have the ability and flexibility to
create portfolios to help our clients achieve their goals. We may utilize the following forms
of analysis:
▪ Fundamental Analysis: We attempt to measure the intrinsic value of a security by
looking at economic and financial factors (including the overall economy, industry
conditions, and the financial condition and management of the company itself) to
determine if the company is underpriced (indicating it may be a good time to buy)
or overpriced (indicating it may be time to sell). Fundamental analysis does not
attempt to anticipate market movements. This presents a potential risk, as the
price of a security can move up or down along with the overall market regardless
of the economic and financial factors considered in evaluating the stock.
▪ Quantitative Analysis: We use mathematical ratios and other performance
appraisal methods in attempt to obtain more accurate measurements of a model
manager’s investment acumen, idea generation, consistency of purpose and
overall ability to outperform their stated benchmark throughout a full market
cycle. Additionally, we perform periodic measurements to assess the authenticity
of returns. A risk in using quantitative analysis is that the models used may be
based on assumptions that prove to be incorrect.
▪ Technical Analysis: We analyze statistics generated by market activity, such as past
prices and volume. Technical analysts do not attempt to measure a security's
intrinsic value but instead use charts and other tools to identify patterns that can
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suggest future activity. Technical analysts believe that the historical performance
of stocks and markets are indications of future performance. Technical analysis is
even more subjective than fundamental analysis in that it relies on proper
interpretation of a given security's price and trading volume data. A decision might
be made based on a historical move in a certain direction that was accompanied
by heavy volume; however, that heavy volume may only be heavy relative to past
volume for the security in question but not compared to the future trading volume.
Therefore, there is the risk of a trading decision being made incorrectly since
future trading volume is unknown. Technical analysis is also done through
observation of various market sentiment readings, many of which are quantitative.
Market sentiment gauges the relative degree of bullishness and bearishness in a
given security, and a contrarian investor utilizes such sentiment advantageously.
When most traders are bullish, then there are very few traders left in a position to
buy the security in question, so it becomes advantageous to sell it ahead of the
crowd. When most traders are bearish, then there are very few traders left in a
position to sell the security in question, so it becomes advantageous to buy it
ahead of the crowd. The risk in utilization of such sentiment technical measures is
that a very bullish reading can always become more bullish, resulting in lost
opportunity if the money manager chooses to act upon the bullish signal by selling
out of a position. The reverse is also true in that a bearish reading of sentiment
can always become more bearish, which may result in a premature purchase of a
security.
▪ Asset Allocation: Rather than focusing primarily on securities selection, we
attempt to identify an appropriate ratio of securities, fixed income, and cash
suitable to the client’s investment goals and risk tolerance. A risk of asset allocation
is that the client may not participate in sharp increases in a particular security,
industry, or market sector. Another risk is that the ratio of securities, fixed income,
and cash will change over time due to stock and market movements and, if not
corrected, will no longer be appropriate for the client’s goals.
MUTUAL FUND SHARE CLASS
in our client
Generally, our Firm does not recommend mutual funds holdings
portfolios/investment strategies, however, some clients may hold mutual funds in their
accounts for various reasons including tax strategies or legacy assets. If we need to render
advice on mutual fund holdings, our Firm will purchase institutional share classes, when
available, of those mutual funds. The institutional share class generally has the lowest
expense ratio. The expense ratio is the annual fee that all mutual funds or ETFs charge
their shareholders. It expresses the percentage of assets deducted each fiscal year for a
fund’s expenses, including 12b-1 fees, management fees, administrative fees, operating
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costs, and all other asset-based costs incurred by the fund. Some fund families offer
different classes of the same fund, and one share class may have a lower expense ratio
than another share class. These expenses come from client assets which could impact the
client’s account performance. Mutual fund expense ratios are in addition to our fee, and
we do not receive any portion of these charges. If an institutional share class is not
available for the mutual fund selected, the adviser will purchase the least expensive share
class available for the mutual fund. As share classes with lower expense ratios become
available, we may use them in the client’s portfolio, and/or convert the existing mutual
fund position to the lower cost share class. Clients who transfer mutual funds into their
accounts with our Firm would bear the expense of any contingent or deferred sales loads
incurred upon selling the product. If a mutual fund has a frequent trading policy, the policy
can limit a client’s transactions in shares of the fund (e.g., for rebalancing, liquidations,
deposits, or tax harvesting). All mutual fund expenses and fees are disclosed in the
respective mutual fund prospectus.
RISK OF LOSS
Every investment portfolio is exposed to risk of loss caused by general economic and
market conditions, such as interest rates, availability of credit, inflation rates, economic
conditions, changes in laws and national and international political circumstances.
Investing in securities involves certain investment risks. Securities may fluctuate in value
or lose value. Clients should be prepared to bear the potential risk of loss. BWS will assist
Clients in determining an appropriate strategy based on their tolerance for risk.
Each Client engagement will entail a review of the Client’s investment goals, financial
situation, time horizon, tolerance for risk and other factors to develop an appropriate
strategy for managing a client’s account. Client participation in this process, including full
and accurate disclosure of requested information, is essential for the analysis of a client’s
account(s). BWS shall rely on the financial and other information provided by the Client or
their designees without the duty or obligation to validate the accuracy and completeness
of the provided information. It is the responsibility of the Client to inform BWS of any
changes in financial condition, goals or other factors that may affect this analysis.
We rely on the assumption that the underlying companies within our security allocations
accurately report their financial performance and provide accurate and unbiased data. We
also must assume that the underlying firms and industries are accurately reviewed by the
rating agencies and other publicly available sources of information about these securities.
While we are alert to indications that data may be incorrect, there is always a risk that our
analysis may be compromised by inaccurate or misleading information provided by third
parties.
Investors should be aware that accounts are subject to risks, including but not limited to:
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▪ MARKET RISK - Even a long-term investment approach cannot guarantee a profit.
Economic, political, and issuer-specific events will cause the value of securities to
rise or fall. Because the value of investment portfolios will fluctuate, there is the
risk that you will lose money, and your investment may be worth more or less upon
liquidation.
▪ FOREIGN SECURITIES AND CURRENCY RISK - Investments in international and
emerging-market securities
include exposure to risks such as currency
fluctuations, foreign taxes and regulations, and the potential for illiquid markets
and political instability.
▪ CAPITALIZATION RISK – Almost all investments carry some degree of capitalization
risk, as most investments do not guarantee a full return of your capital. An investor
may lose part or all of their initial investment in a security or other asset due to
market fluctuations and the timing of the performance of the underlying business.
Capitalization risk represents the exposure to loss of your original investment if
you sell an asset at a lower price than what you purchased it for. In addition to
market fluctuations, a company’s performance may be influenced by numerous
factors including, but not limited to, the size of the company. Small-cap and mid-
cap companies may be hindered by more limited resources or less diverse products
or services. Their stocks have historically been more volatile than the stocks of
larger, more established companies.
▪
INTEREST RATE RISK – Shifts in interest rates may adversely impact the value of an
investment.
▪ CREDIT RISK - Credit risk is the risk that the issuer of a security may be unable to
make interest payments, fail to repay principal when due, or both. A downgrade
to an issuer’s credit rating or a perceived change in an issuer’s financial strength
may affect a security’s value and thus impact the value of your investment.
▪ LIQUIDITY RISK: Liquidity risk is the risk that there may be limited buyers for a
security when an investor wants to sell. Typically, this results in a discounted sale
price in order to attract a buyer.
▪ DEFAULT RISK - A default occurs when an issuer fails to make payment on a
principal or interest payment.
▪ EVENT RISK - Event risk is difficult to predict because it may involve natural
disasters such as earthquakes or hurricanes, as well as changes in circumstance
from regulators or political bodies.
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▪ POLITICAL RISK - Political risk is the risk associated with the laws of the country, or
to events that may occur there. Political events such as a government’s change in
policy could restrict the flow of capital.
▪ DURATION RISK - Duration is a way to measure a bond's price sensitivity to changes
in interest rates. The duration of a bond is determined by its maturity date, coupon
rate, and call feature. Duration is a method to compare how different bonds will
react to interest rate changes. If a bond has a duration of five (5) years it means
that the value of that security will decline by approximately five percent (5%) for
every one percent (1%) increase in interest rates.
▪ REINVESTMENT RISK: Reinvestment risk is the risk that future interest and
principal payments may be reinvested at lower yields due to declining interest
rates.
▪ TAX RISK: For municipal bonds, depending on the client’s state of residence, the
interest earned on certain bonds may not be tax-exempt at the state level. Also,
changes in federal tax policy may impact the tax treatment of interest and capital
gains of an investment.
▪ REGULATORY RISK: Market participants are subject to rules and regulations
imposed by one or more regulators. Changes to these rules and regulations could
have an adverse effect on the value of an investment.
▪ CONCENTRATION RISK: The risk of amplified losses that may occur from having a
large portion of your holdings in a particular investment, asset class or market
segment relative to your overall portfolio.
▪ SECURITIES LENDING RISK - Securities lending involves the risk that the fund loses
money because the borrower fails to return the securities in a timely manner or at
all. The fund could also lose money if the value of the collateral provided for loaned
securities, or the value of the investments made with the cash collateral, falls.
These events could also trigger adverse tax consequences for the fund.
▪ EXCHANGE-TRADED FUNDS – In addition to all the above risks to underlying
investments, ETFs may also face market-trading risks, such as the potential lack of
an active market for shares, losses from trading in the secondary markets, and
disruption in the creation/redemption process of the ETF. Any of these factors may
lead to the fund’s shares trading at either a premium or a discount to its “net asset
value.”
▪ CYBERSECURITY RISK - In addition to the Material Investment Risks listed above,
investing involves various operational and “cybersecurity” risks. These risks include
both intentional and unintentional events at our firm or one of its third-party
counterparties or service providers, that may result in a loss or corruption of data,
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August 2025 | PAGE 21
result in the unauthorized release or other misuse of confidential information, and
generally compromise our Firm’s ability to conduct its business. A cybersecurity
breach may also result in a third-party obtaining unauthorized access to our
clients’ information, including social security numbers, home addresses, account
numbers, account balances, and account holdings. Our Firm has established
business continuity plans and risk management systems designed to reduce the
risks associated with cybersecurity breaches. However, there are inherent
limitations in these plans and systems, including that certain risks may not have
been identified, in large part because different or unknown threats may emerge in
the future. As such, there is no guarantee that such efforts will succeed, especially
because our Firm does not directly control the cybersecurity systems of our third-
party service providers. There is also a risk that cybersecurity breaches may not be
detected.
ALTERNATIVE
INVESTMENTS
Investments classified as "alternative investments" may include a broad range of
underlying assets in addition to the Material Investment Risks listed above.
Alternative Investment include, but are not limited to, the following examples:
cryptocurrency, hedge funds, private equity, private credit, interval funds, venture
capital, and registered, publicly traded securities. Alternative investments are
speculative, not suitable for all clients and intended for only experienced and
sophisticated investors who are willing to bear the high risk of the investment,
which can include: loss of all or a substantial portion of the investment due to
leveraging, short-selling, or other speculative investment practices; lack of liquidity
in that there may be no secondary market for the fund and none expected to
develop; volatility of returns; potential for restrictions on transferring interest in
the fund; potential lack of diversification and resulting higher risk due to
concentration of trading authority with a single advisor; absence of information
regarding valuations and pricing; potential for delays in tax reporting; less
regulation and typically higher fees than other investment options such as mutual
funds. The SEC requires investors to be accredited to invest in these more
speculative alternative investments. Investing in a fund that concentrates its
investments in a few holdings may involve heightened risk and result in greater
price volatility.
ITEM 9 - DISCIPLINARY INFORMATION
We are required to disclose any legal or disciplinary events that are material to a client, or
prospective client's, evaluation of our advisory business or the integrity of our
management. Our Firm has not been subject to any legal or disciplinary events to disclose.
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ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
BROKER/DEALER
BWS is not a broker/dealer, but some of our Investment Adviser Representatives (“IAR”)
are registered representatives of Madison Avenue Securities, LLC. (“Madison Avenue”), a
full-service broker-dealer, member FINRA/SIPC, which compensates them for effecting
securities transactions. When placing securities transactions through Madison Avenue in
their capacity as registered representatives, they may earn sales commissions. Because
the IARs are dually registered with Madison Avenue and BWS, Madison Avenue has certain
supervisory and administrative duties pursuant to the requirements of FINRA Conduct
Rule 3040. Madison Avenue and BWS are not affiliated companies. IARs of BWS spend a
portion of their time in connection with broker/dealer activities.
is selected as the broker- dealer, Madison Avenue, and
As a broker-dealer, Madison Avenue engages in a broad range of activities normally
associated with securities brokerage firms. Pursuant to the investment advice given by
BWS or its IARs, investments in securities may be recommended for clients. If Madison
Avenue
its registered
representatives, including IARs of BWS, may receive commissions for executing securities
transactions.
You are advised that if Madison Avenue is selected as the broker-dealer, the transaction
charges may be higher or lower than the charges you may pay if the transactions were
executed at other broker/dealers. You are under no obligation to purchase securities
through IARs of BWS or Madison Avenue.
Moreover, you should note that under the rules and regulations of FINRA, Madison
Avenue has an obligation to maintain certain client records and perform other functions
regarding certain aspects of the investment management activities of its registered
representatives. These obligations require Madison Avenue to coordinate with and have
the cooperation of its registered representatives that operate as, or are otherwise
associated with, investment advisers other than Madison Avenue. Accordingly, Madison
Avenue may limit the use of certain custodial and brokerage arrangements available to
clients of BWS and Madison Avenue may collect, as paying agent of BWS, the investment
management fee remitted to BWS by the account custodian. Madison Avenue may charge
an administrative Fee to the Firm. This charge will not increase the advisory fee you have
agreed to pay BWS.
IARs of BWS, in their capacity as registered representatives of Madison Avenue, or as
agents appointed with various life, disability or other insurance companies, receive
commissions, 12(b)-1 fees, fee trails, or other compensation from the respective product
sponsors and/or as a result of effecting securities transactions for clients. However, clients
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August 2025 | PAGE 23
should note that they have the right to decide whether or not to purchase any investment
products through BWS’s representatives.
OTHER AFFILIATIONS
Buck Enterprises, Inc., is the sole shareholder of BWS, E.A. Buck Insurance, Inc., Buck
Financial Services, Inc., Buck Private Wealth Group LLC Buck Enterprises, Inc. is also the
controlling owner and manager of Buck Financial Partners LLC. Buck Financial Services
Inc. is the sole shareholder of LTCPRO, LLC and E.A. Buck Accounting & Tax Services, and
Buck Financial Services – Achieve Retirement, LLC. Buck Financial Services is also the
majority shareholder of Buck Financial Services – Outer Banks LLC and Buck Financial
Services – New Mexico LLC.
E.A. Buck Financial Services
Buck Financial Services, Inc., E.A. Buck Financial Services is a tradename used in marketing
advisory and planning services offered to clients.
Buck Financial Services, Inc.
Buck Financial Services, Inc. is a subsidiary of Buck Enterprises Inc., which conducts many
back-office business operations on behalf of BWS, including office administration,
marketing, human resources, contractor management and accounting.
Buck Financial Services – Achieve Retirement, LLC
Buck Financial Services – Achieve Retirement, LLC (dba Achieve Retirement) provides
retirement plan services and consulting to employers and is headquartered located in
Denver, CO.
Buck Private Wealth Group LLC
Buck Private Wealth Group LLC provides investment advising services to high-net-worth
individuals, and households.
Buck Financial Services – New Mexico LLC
Buck Financial Services – New Mexico LLC (BFS-NM) provides financial services in offices
located in the State of New Mexico.
Buck Financial Services – Outer Banks LLC
Buck Financial Services – Outer Banks LLC (BFS-OB) provides financial services in offices
located in the State of North Carolina.
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August 2025 | PAGE 24
E.A. Buck Accounting & Tax Services.
E.A. Buck Accounting & Tax Services provides tax services as well as payroll and
bookkeeping services for individuals and businesses. BWS will refer clients to E.A. Buck
Accounting & Tax Services and E.A. Buck Accounting & Tax Services to BWS.
LTCPRO, LLC
LTCPRO, LLC offers Federal Retirement Benefit Workshops to Federal Agencies for their
employees. Federal employees receive financial planning services and engage in a
separate agreement for services offered by LTCPRO, LLC. Prospective clients should note
that they have the right to decide whether or not to engage in services with LTCPRO, LLC.
All arrangements doing business with a government client or investor must comply with
the Advisers Act as well as any applicable state/local laws or regulations regarding the use
investment adviser
of placement agents. Associated employees of LTCPRO are
representatives of AE Wealth Management, LLC. These individuals are separately
registered with AE Wealth Management as investment adviser representatives and able
to receive separate, yet customary, compensation resulting from implementing advisory
services on behalf of investment management clients they service through LTCPRO. Our
Firm and AE Wealth have implemented policies and procedures regarding political
contributions and doing business with government entities in accordance with applicable
laws and regulations, including Rule 206(4)-5 under the Advisers Act. All employees are
required to receive written preclearance for any political contributions through our
centralized compliance department to ensure compliance with applicable political
contribution restrictions. Furthermore, we do not normally allow political contributions to
be made by our Firm. Our employees may occasionally refer clients to our affiliates and
may be compensated by such affiliates, consistent with the requirements of applicable law
and regulation.
Buck Financial Partners LLC
Buck Financial Partners LLC provides opportunities for individuals who make significant
contributions to the successful growth of Buck Enterprises to participate in the growth in
valuation of the enterprise.
E.A. Buck Insurance Inc.
Buck Enterprises is the sole shareholder of E.A. Buck Insurance Inc. a licensed insurance
producer domiciled in the State of Hawaii and operating in multiple states. As such, certain
advisors of BWS will be compensated for selling insurance products to clients to whom
our investment management services are offered. A portion of our advisor’s time is spent
on these activities.
BWS does not own, nor is it affiliated with any insurer. When a BWS IAR or employee
makes a recommendation to a client about the purchase, redemption or exchange of an
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insurance policy, Clients are not obligated in any way to execute the recommendations
made through E.A. Buck Insurance Inc or any insurance agent affiliated with BWS or any
insurance agency that its advisors may be licensed.
Further, insurance product recommendations may not be subject to the same fiduciary
standard as investment advisers are subject. Certain advisors of BWS may be compensated
when the sale of an insurance product through E.A. Buck Insurance Inc is made.
Insurance Activities Outside of BWS
Additionally, BWS personnel may engage in outside business activities. As such, these
individuals can receive separate, yet customary commission compensation resulting from
implementing product transactions on behalf of investment management Clients.
Furthermore, commissions may vary by product, and each product may have different
commission rates, encouraging the financial professional to recommend products that
may pay higher commissions over the products that make the most sense for you.
Insurance products may also have different payment schedules depending on the
product's nature, and the timing of the payments may differ from that of the advisory
options offered by BWS. This timing difference has the potential to create a conflict of
interest since some financial professionals may have the incentive to recommend a
product that pays commissions now, over an advisory product that pays commissions over
a longer period. As an example, all other variables held equal, a 5% commission paid by an
insurance company upon sale of a $100,000 annuity product, may be more attractive to a
financial professional than a one percent (1%) advisory fee charged on a $100,000 account
paid over a period of five (5) years, despite the overall pre-tax compensation paid to the
financial professional being equal.
You should be aware there are other insurance products offered by other insurance agents
other than those recommended by our financial professionals. You are under no obligation
to implement any insurance or annuity transaction through a BWS employee.
Clients are not under any obligation to engage these individuals when considering the
implementation of these outside recommendations. The implementation of any or all
recommendations is solely at the discretion of the Client.
Other Activities Outside of BWS
Neither our firm nor any of its management persons are registered or have an application
pending to register as a broker-dealer.
Clients should be aware that the ability to receive additional compensation by our Firm
and its management persons or employees creates conflicts of interest that impair the
objectivity of the Firm and these individuals when making advisory recommendations.
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Our Firm endeavors at all times to put the interest of its clients first as part of our fiduciary
duty as a registered investment adviser; we take the following steps, among others to
address this conflict:
• we disclose to clients the existence of all material conflicts of interest, including
the potential for the Firm and our employees to earn compensation from advisory
clients in addition to the Firm's advisory fees.
• we disclose to clients that they have the right to decide to purchase recommended
investment products from our employees.
• we collect, maintain and document accurate, complete, and relevant client
background information, including the client’s financial goals, objectives, and
liquidity needs.
•
the Firm conducts regular reviews of each client advisory account to verify that all
recommendations made to a client are in the best interest of the client’s needs
and circumstances.
• we require that our employees seek prior approval of any outside employment
activity so that we may ensure that any conflicts of interests in such activities are
properly addressed.
• we periodically monitor these outside employment activities to verify that any
conflicts of interest continue to be properly addressed by the Firm; and
• we educate our employees regarding the responsibilities of a fiduciary, including
the need to have a reasonable and independent basis for the investment advice
provided to clients.
ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND
PERSONAL TRADING
Our Firm and persons associated with us are allowed to invest for their own accounts, or
to have a financial investment in the same securities or other investments that we
recommend or acquire for your account and may engage in transactions that are the same
as or different than transactions recommended to or made for your account. This creates
a conflict of interest. We recognize the fiduciary responsibility to act in your best interest
and have established polices to mitigate conflicts of interest.
We have developed and implemented a Code of Ethics that sets forth standards of conduct
expected of our advisory personnel to mitigate this conflict of interest. The Code of Ethics
addresses, among other things, personal trading, gifts, and the prohibition against the use
of inside information.
The Code of Ethics is designed to protect our clients to detect and deter misconduct,
educate personnel regarding the Firm’s expectations and laws governing their conduct,
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remind personnel that they are in a position of trust and must act with complete propriety
at all times, protect the reputation of BWS, safeguard against the violation of the securities
laws, and establish procedures for personnel to follow so that we may determine whether
their personnel are complying with the Firm’s ethical principles.
We have established the following restrictions in order to ensure our Firm’s fiduciary
responsibilities:
▪ No supervised employee of BWS shall prefer his or her own interest to that of the
advisory client. Trades for supervised employees are traded alongside client
accounts.
▪ We maintain a list of all securities holdings of anyone associated with this advisory
practice with access to advisory recommendations. These holdings are reviewed
on a regular basis by an appropriate officer/individual of BWS.
▪ We emphasize the unrestricted right of the client to decline implementation of any
advice rendered, except in situations where we are granted discretionary authority
of the client’s account.
▪ We require that all supervised employees act in accordance with all applicable
Federal and State regulations governing registered investment management
practices.
▪ Any supervised employee not in observance of the above may be subject to
termination.
None of our associated persons may affect for himself/herself or for accounts in which
he/she holds a beneficial interest, any transactions in a security which is being actively
recommended to any of our clients, unless in accordance with the Firm’s procedures.
You may request a complete copy of our Code by contacting us at the address, telephone,
or email on the cover page of this Part 2; ATTN: James Dixon, Chief Compliance Officer.
ITEM 12 - BROKERAGE PRACTICES
THE CUSTODIAN AND BROKERS WE USE
Clients must maintain assets in an account at a “qualified custodian,” generally a broker-
dealer or bank. We generally recommend that clients utilize the custody and brokerage
services of Fidelity Brokerage Services LLC ("Fidelity") or Charles Schwab & Co., Inc.
Advisor Services (“Schwab”) (together referred to as “Custodian”) for investment
management accounts. The Custodian will hold client assets in a brokerage account and
buy and sell securities when we instruct them to do so.
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While we recommend that clients use the recommended Custodian, clients must decide
whether to do so and open accounts with the Custodian by entering into account
agreements directly with the Custodian. The accounts will always be held in the name of
the client and never in our Firm’s name. Even though clients maintain accounts at
Custodian, we can still use other brokers to execute trades for client accounts (see Client
Brokerage and Custody Costs, below).
HOW WE SELECT BROKERS/CUSTODIANS
We seek 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. We consider a wide range of factors, including:
1.
Combination of transaction execution services and asset custody services
(generally, without a separate fee for custody)
Capability to buy and sell securities for client accounts
2.
3.
Capability to facilitate transfers and payments to and from accounts (wire transfers,
check requests, bill payment, etc.)
4.
Breadth of available investment products (stocks, bonds, mutual funds, exchange
traded funds, etc.)
5.
Availability of investment research and tools that assist us in making investment
decisions
6.
Quality of services
7.
Competitiveness of the price of those services (commission rates, other fees, etc.)
and willingness to negotiate the prices
Reputation, financial strength, and stability
8.
9.
Prior service to our Firm and our other clients
10.
Availability of other products and services that benefit us, as discussed below (see
Products and Services Available to Us from Custodian)
CLIENT BROKERAGE AND CUSTODY COSTS
For client accounts that the Custodian maintains, the Custodian generally does not charge
separately for custody services. However, the Custodian receives compensation by
charging ticket charges or other fees on trades that it executes or that settle into clients’
Custodian accounts. In addition to commissions, the Custodian charges a flat dollar
amount as a “prime broker” or “trade away” fee for each trade that we have executed by
a different custodian but where the securities bought or the funds from the securities sold
are deposited (settled) into a client’s Custodian account. These fees are in addition to the
ticket charges or other compensation the client pays the executing custodian. To minimize
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these trading costs, we have the Custodian execute most trades for client accounts. We
have determined that having the Custodian execute most trades is consistent with our
duty to seek “best execution” of client trades. Best execution means the most favorable
terms for a transaction based on all relevant factors, including those listed above (see How
We Select Brokers/Custodians).
PRODUCTS AND SERVICES AVAILABLE TO US FROM CUSTODIAN
The Custodian provides our Firm and our clients with access to institutional brokerage,
trading, custody, reporting, and related services, many of which are not typically available
to the Custodian retail customers. The Custodian also makes available various support
services which help us manage or administer our clients’ accounts and help us manage
and grow our business. The Custodian’s support services generally are available on an
unsolicited basis (we do not have to request them) and at no charge to us. These are
considered soft dollar benefits because there is an incentive to do business with the
Custodian. This creates a conflict of interest. We recognize the fiduciary responsibility to
place clients’ interests first and have established policies in this regard to mitigate any
conflicts of interest. The following is a more detailed description of the Custodian’s
support services.
SERVICES THAT BENEFIT OUR CLIENTS
The 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 the Custodian include some to which we might
not otherwise have access or that would require a significantly higher minimum initial
investment by our clients. The Custodian’s services described in this paragraph generally
benefit our clients and their accounts.
SERVICES THAT MAY NOT DIRECTLY BENEFIT OUR CLIENTS
The Custodian also makes available to us other products and services that benefit us but
may not directly benefit our clients or their accounts. These products and services assist
us in managing and administering our clients’ accounts. They include investment research,
both the Custodian’s own and that of third parties. We may use this research to service all
or a substantial number of our clients’ accounts, including accounts not maintained at
Custodian. In addition to investment research, the Custodian also makes available
software and other technology that:
1.
Provides access to client account data (positions, trades, statements, cost
basis, etc.).
2.
Facilitates trade execution and allocates aggregated trade orders for multiple
client accounts.
3.
Provides pricing and other market data.
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Facilitates payment of our fees from our clients’ accounts.
4.
5.
Assists with back-office functions, recordkeeping, and client reporting.
SERVICES THAT GENERALLY BENEFIT ONLY US
The Custodian also offers other services intended to help us manage and further develop
our business enterprise. These services include:
1.
Educational conferences and events
2.
Consulting on technology, compliance, legal, and business needs
3.
Publications or conferences on practice management & business succession
4.
Access to employee benefits providers, human capital consultants, and
insurance providers
Schwab may provide some of these services itself. In other cases, it will arrange for third-
party vendors to provide the services to us. Schwab may also discount or waive its fees for
some of these services or pay all or part of a third party’s fees. Schwab may also provide
us with other benefits, such as occasional business entertainment for our personnel.
Schwab did provide monetary support, specifically toward our Orion subscription and our
Compliance Consulting services needed to run Buck Wealth Strategies, LLC. Without this
arrangement, our Firm might be compelled to purchase the same or similar services at its
own expense. Schwab provides these additional services and support to our Firm in its
sole discretion and at its own expense, and our Firm does not pay any fees to Schwab for
this. The benefits received by our Firm or our personnel through participation in the
program do not depend on the amount of brokerage transactions directed to the
Custodian. As part of our fiduciary duties to clients, we endeavor at all times to put the
interests of our clients first. You should be aware, however, that the receipt of economic
benefits by our Firm or our related persons in and of itself creates a potential conflict of
interest and may indirectly influence our choice of the Custodian for custody and
brokerage services. The Custodian may discount or waive fees it would otherwise charge
for some of these services or pay all or a part of the fees of a third-party providing these
services to us.
OUR INTEREST IN CUSTODIAN’S SERVICES
The availability of these services from the Custodian benefits us because we do not have
to produce or purchase them. These services are not contingent upon us committing any
specific amount of business to the Custodian. We believe that our selection of Custodian
as custodian and broker is in the best interest of our clients. Some of the products,
services and other benefits provided by the Custodian benefit our Firm and may not
benefit our client accounts.
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interest. Our
Services that we receive from a Custodian create a conflict of
recommendation or requirement that clients place assets in the Custodian's custody may
be based in part on benefits the Custodian provides to us, or our agreement to maintain
certain Assets Under Management at Custodian, and not solely on the nature, cost or
quality of custody and execution services provided by the Custodian.
BROKERAGE FOR CLIENT REFERRALS
Our Firm does not receive client referrals from any custodian or third party in exchange
for using that custodian or third party.
AGGREGATION AND ALLOCATION OF TRANSACTIONS
BWS may aggregate transactions if we believe that aggregation is consistent with the duty
to seek best execution for our clients and is consistent with the disclosures made to clients
and terms defined in the client investment management agreement. No advisory client
will be favored over any other client, and each account that participates in an aggregated
order will participate at the average share price (per custodian) for all transactions in that
security on a given business day. Our Firm does not aggregate trades of our personnel with
those of client accounts.
If we do not receive a complete fill for an aggregated order, we will allocate the order on
a pro-rata basis. If we determine that a pro-rata allocation is not appropriate under the
particular circumstances, we will base the allocation on other relevant factors, which may
include:
• When only a small percentage of the order is executed, with respect to purchase
allocations, allocations may be given to accounts high in cash.
• With respect to sale allocations, allocations may be given to accounts low in cash.
• We may allocate shares to the account with the smallest order, or to the smallest
position, or to an account that is out of line with respect to security or sector
weightings, relative to other portfolios with similar mandates.
• We may allocate to one account when that account has limitations in its
investment guidelines prohibiting it from purchasing other securities that we
expect to produce similar investment results and that can be purchased by other
accounts in the block.
•
If an account reaches an investment guideline limit and cannot participate in an
allocation, we may reallocate shares to other accounts. For example, this may be
due to unforeseen changes in an account’s assets after an order is placed.
•
If a pro-rata allocation of a potential execution would result in a de minimis
allocation in one or more accounts, we may exclude the account(s) from the
allocation and disgorge any profits. Generally, de minimis allocations do not exceed
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5% of the total allocation. Additionally, we may execute the transactions on a pro
rata basis.
• We will document the reasons for any deviation from a pro-rata allocation.
TRADE ERRORS
We have implemented procedures designed to prevent trade errors; however, trade errors
in client accounts cannot always be avoided. BWS will correct trade errors only when such
a correction is in the best interest of the client consistent with our fiduciary duty to the
client. In cases where the client causes a trade error, the client will be responsible for any
loss resulting from the correction. Depending on the specific circumstances of the trade
error, the client may not be able to receive any gains generated as a result of the error
correction. In all situations where the client does not cause the trade error, the client will
be made whole, and we will absorb any loss resulting from the trade error if the error was
caused by the firm. If the error is caused by the custodian, the custodian will be
responsible for covering all trade error costs. We will never benefit from or profit from
trade errors.
DIRECTED BROKERAGE
We do not routinely require that you direct us to execute transactions through a specified
broker dealer. Additionally, we typically do not permit you to direct brokerage. We place
trades for your account subject to our duty to seek best execution and other fiduciary
duties.
ITEM 13 - REVIEW OF ACCOUNTS
ACCOUNT REVIEWS AND REVIEWERS – INVESTMENT SUPERVISORY SERVICES
Our Investment Adviser Representatives will monitor client accounts at least annually and
perform reviews with each client on a regular basis. All accounts are reviewed for
consistency with client investment strategy, asset allocation, risk tolerance, and
performance relative to the appropriate benchmark. More frequent reviews may be
triggered by changes in an account holder’s personal, tax, or financial status. Geopolitical
and macroeconomic specific events may also trigger reviews. You are urged to notify us of
any changes in your personal circumstances.
STATEMENTS AND REPORTS
Reports from our Firm are generated for clients on an annual basis or as requested. These
reports show the rate of return on accounts under the management of BWS.
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The Custodian for the individual client’s account will also provide clients with an account
statement at least quarterly. You are urged to compare the reports provided by BWS
against the account statements you receive directly from your account custodian.
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION
REFERRAL PAYMENTS
BWS does not have any compensation arrangements with any entities from which BWS
receives compensation in exchange for client referrals.
OTHER FORMS OF COMPENSATION
BWS IARs may receive bonuses based on their overall assets under management during a
specific period of time. These bonuses could include cash payments and/or qualification
for an invitation to networking and business trips. These benefits do not result from
achieving sales quotas related to specific product lines. However, these incentives present
a conflict of interest, which BWS addresses by providing disclosures, following procedures,
and applying the firm’s fiduciary obligation to each client.
BWS IARs, acting in their separate capacities as insurance agents, may also receive
commissions from insurance companies/carriers for selling their insurance products. The
commissions vary from carrier to carrier, and the receipt of these commissions creates a
conflict or incentive to sell or offer insurance products as compared with investment
advisory services or securities recommendations. The insurance agent can also receive
other incentive awards or bonus payments from an insurance company/carrier/insurance
marketing organization for selling a targeted number of a specific carrier’s annuity or
insurance products. Because insurance agents are subject to a separate regulatory regime
from the rules and regulations that apply to IARs, BWS does not supervise or conduct
oversight of the insurance activity.
training events hosted by product
From time to time, our Firm may receive expense reimbursement for travel and/or
marketing expenses from distributors of investment and/or insurance products. Travel
expense reimbursements are typically a result of attendance at due diligence and/or
sponsors. Marketing-expense
investment
reimbursements are typically the result of informal expense sharing arrangements in
which product sponsors may underwrite costs incurred for marketing such as advertising,
publishing, and seminar expenses. Although receipt of these travel and marketing expense
reimbursements are not predicated upon specific sales quotas, the product sponsor
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reimbursements are typically made by those sponsors for whom sales have been made or
it is anticipated sales will be made.
Our Firm may be asked to recommend a financial professional, such as an attorney,
accountant, or mortgage broker. In such cases, our Firm does not receive any direct
compensation in return for any referrals made to individuals or firms in our professional
network. Clients must independently evaluate these firms or individuals before engaging
in business with them and clients have the right to choose any financial professional to
conduct business. Individuals and firms in our financial professional network may refer
clients to our Firm. Again, our Firm does not pay any direct compensation in return for any
referrals made to our Firm. Our Firm does recognize the fiduciary responsibility to place
your interests first and have established policies in this regard to mitigate any conflicts of
interest.
ITEM 15 – CUSTODY
Custody has been defined by regulators as having access to or control over client funds
and/or securities. BWS does not have physical custody of funds or securities, as it applies
to investment advisors. However, BWS, through its affiliated accounting practice, does
have indirect access to bill pay information for their accounting clients, which may or may
not be advisory clients.
Per SEC regulations, BWS is deemed to have custody because, for certain clients, the
affiliated entity:
•
Has entered into an arrangement with the client, per the client’s request,
in which our affiliated firm is able to withdraw funds from the client’s account
(including bill pay services or other withdrawals made pursuant to standing letters
of client authorization); and/or
Have client-authorized access to an account, with the ability to withdraw
•
or transfer funds from the account.
The SEC requires that firms who have custody for the reasons listed above are subject to
an annual surprise audit to be conducted by an independent CPA firm which is registered
with and subject to regular inspection by the Public Company Accounting Oversight Board
(PCAOB). BWS have complied with the requirements concerning such surprise audits and
will continue to do so in the future.
BWS is also deemed to have constructive custody over those client accounts where our
Firm is able to deduct our fees directly from the account. As long as BWS comply with
certain regulatory requirements, this constructive custody does not mandate that the Firm
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undergo a surprise audit for those accounts. Our clients receive account statements
directly from the qualified custodian at least quarterly. Our Firm may send clients
quarterly reports that the Firm does produce using our portfolio accounting system. BWS
strongly urge our clients to compare such reports with the statements received from the
qualified custodian. Furthermore, when BWS calculates our investment management fees
and instructs the custodian to remit these fees to us directly from clients’ accounts, the
custodian does not verify our calculation of fees. BWS performs quarterly testing to ensure
that our fees are charged in accordance with the client’s Agreement.
STANDING LETTERS OF AUTHORIZATION – THIRD PARTIES
While our firm does not maintain physical custody of client assets (which are maintained
by a qualified custodian, as discussed above), BWS is deemed to have custody of certain
client assets if given the authority to withdraw assets from client accounts, as further
described below under “Standing Instructions”. All our clients receive account statements
directly from their qualified custodian(s) at least quarterly upon opening of an account.
BWS urges 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.
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 instruction (“SLOA”) is deemed to
have custody. As such, our Firm has adopted the following safeguards in conjunction with
our custodians:
• 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.
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• 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.
DEDUCTION OF ADVISORY FEES
BWS is deemed to have custody of client funds and securities whenever BWS is given the
authority to have fees deducted directly from client accounts. It should be noted that
authorization to trade in client accounts is not deemed by regulators to be custody.
Account statements are delivered directly from the qualified custodian to each client, or
the client’s independent representative, at least quarterly. You should carefully review
those statements and are urged to compare the statements against reports received from
BWS. When you have questions about your account statements, you should contact BWS
or the qualified custodian preparing the statement.
Additionally, BWS has a related person, as defined by the Investment Advisers Act, as
amended, who has a payroll service to entities. The related party pays the company payroll
via the entities’ bank account.
Since deemed to have custody BWS is required to hire an independent outside auditor to
make a surprise audit each year of the accounts on which we have been deemed to have
custody. In both of the above cases of “custody”, BWS does not have physical custody of
the client’s assets, and the assets are not registered in the firm’s name.
ITEM 16 – INVESTMENT DISCRETION
For discretionary accounts, prior to engaging BWS to provide investment management
services, you will enter a written Agreement with us granting the Firm the authority to
supervise and direct, on an on-going basis, investments in accordance with the client’s
investment objective and guidelines. In addition, you will need to execute additional
documents required by the Custodian to authorize and enable BWS, in its sole discretion,
without prior consultation with or ratification by you, to purchase, sell, or exchange
securities in and for your accounts. BWS is authorized, in our discretion and without prior
consultation with you to: (1) buy, sell, exchange, and trade any stocks, bonds or other
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securities or assets and (2) determine the number of securities to be bought or sold, and
(3) place orders with the custodian. Any limitations to such discretionary authority will be
communicated to our Firm in writing by you, the client.
ITEM 17 – VOTING CLIENT SECURITIES
BWS will not vote proxies on your behalf. You are welcome to vote proxies or designate an
independent third-party at your own discretion. You designate proxy voting authority in
the custodial account documents. You must ensure that proxy materials are sent directly
to you or your assigned third party. BWS does not act with respect to any securities or
other investments that become the subject of any legal proceedings, including
bankruptcies. Clients can contact our office with questions about a particular proxy
solicitation by phone at 888-210-6567.
ITEM 18 – FINANCIAL INFORMATION
BWS does not require or solicit prepayment of more than $1,200 in fees per client, six
months or more in advance. Therefore, BWS is not required to include a balance sheet for
our most recent fiscal year. BWS is not subject to a financial condition that is reasonably
likely to impair our ability to meet contractual commitments to clients. Finally, BWS has
not been the subject of a bankruptcy petition at any time.
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