Overview
- Headquarters
- Pembroke Pines, FL
- Total Firm Assets
- $114 million
- Average High-Net-Worth Client Portfolio Size
- $2.0 million
Fee Structure
Primary Fee Schedule (ADV BROCHURE PART II)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.00% |
| $1,000,001 | $2,000,000 | 0.75% |
| $2,000,001 | $4,000,000 | 0.50% |
| $4,000,001 | $6,000,000 | 0.25% |
| $6,000,001 | and above | 0.10% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $30,000 | 0.60% |
| $10 million | $36,500 | 0.36% |
| $50 million | $76,500 | 0.15% |
| $100 million | $126,500 | 0.13% |
Clients
- High-Net-Worth Share of Firm Assets
- 60.89%
- Number of High-Net-Worth Clients
- 35
- Total Client Accounts
- 528
- Discretionary Accounts
- 528
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Pension Consulting, Investment Advisor Selection
Regulatory Filings
- SEC CRD Number
- 153074
Additional Brochure: ADV BROCHURE PART II (2026-07-27)
View Document Text
Common Cents Wealth
Management, LLC
Firm Brochure - Form ADV Part 2A
This brochure provides information about the qualifications and business practices of Common Cents Wealth
Management, LLC. If you have any questions about the contents of this brochure, please contact us at (954) 769-
0837 or by email at: info@cc-wealth.com. The information in this brochure has not been approved or verified by the
United States Securities and Exchange Commission or by any state securities authority.
Additional information about Common Cents Wealth Management, LLC is also available on the SEC’s website at
www.adviserinfo.sec.gov. Common Cents Wealth Management, LLC’s CRD number is: 153074.
15800 Pines Blvd #3004
Pembroke Pines, FL 33314
(954) 769-0837
info@cc-wealth.com
Registration as an investment adviser does not imply a certain level of skill or training.
Version Date: 07/27/2026
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Item 2: Material Changes
The material changes in this brochure from the last annual updating amendment of Common Cents
Wealth Management, LLC on 03/19/2026 are described below. Material changes relate to Common
Cents Wealth Management, LLC’s policies, practices or conflicts of interests.
• Common Cents Wealth Management, LLC has successfully transitioned to formal registration
with the Securities and Exchange Commission from its previous registration at the state level.
ii
Item 3: Table of Contents
Item 1: Cover Page
Item 2: Material Changes ....................................................................................................................................... ii
Item 3: Table of Contents ...................................................................................................................................... iii
Item 4: Advisory Business ......................................................................................................................................2
Item 5: Fees and Compensation .............................................................................................................................4
Item 6: Performance-Based Fees and Side-By-Side Management ....................................................................5
Item 7: Types of Clients ..........................................................................................................................................5
Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ...............................................................5
Item 9: Disciplinary Information ...........................................................................................................................8
Item 10: Other Financial Industry Activities and Affiliations ...........................................................................8
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................9
Item 12: Brokerage Practices ..................................................................................................................................9
Item 13: Review of Accounts ................................................................................................................................11
Item 14: Client Referrals and Other Compensation ..........................................................................................11
Item 15: Custody ....................................................................................................................................................12
Item 16: Investment Discretion ............................................................................................................................13
Item 17: Voting Client Securities (Proxy Voting) ..............................................................................................13
Item 18: Financial Information .............................................................................................................................13
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Item 4: Advisory Business
A. Description of the Advisory Firm
Common Cents Wealth Management, LLC (hereinafter “Common Cents”) is a Limited
Liability Company organized in the State of Florida. The firm was formed in August 2008,
and the principal owners are Jeremy C Brinkmeier and Martin D Rosenthal.
B. Types of Advisory Services
Portfolio Management Services
Common Cents offers ongoing portfolio management services based on the individual
goals, objectives, time horizon, and risk tolerance of each client. Common Cents creates
an Investment Policy Statement for each client, which outlines the client’s current
situation (income, tax levels, and risk tolerance levels). Portfolio management services
include, but are not limited to, the following:
•
•
•
Investment strategy •
•
Asset allocation
•
Risk tolerance
Personal investment policy
Asset selection
Regular portfolio monitoring
Common Cents evaluates the current investments of each client with respect to their risk
tolerance levels and time horizon. Common Cents will request discretionary authority
from clients in order to select securities and execute transactions without permission from
the client prior to each transaction. Risk tolerance levels are documented in the Investment
Policy Statement, which is given to each client.
Common Cents seeks to provide that investment decisions are made in accordance with
the fiduciary duties owed to its accounts and without consideration of Common Cents'
economic, investment or other financial interests. To meet its fiduciary obligations,
Common Cents attempts to avoid, among other things, investment or trading practices
that systematically advantage or disadvantage certain client portfolios, and accordingly,
Common Cents' policy is to seek fair and equitable allocation of investment
opportunities/transactions among its clients to avoid favoring one client over another
over time. It is Common Cents' policy to allocate investment opportunities and
transactions it identifies as being appropriate and prudent among its clients on a fair and
equitable basis over time.
Services Limited to Specific Types of Investments
Common Cents generally limits its investment advice to mutual funds, fixed income
securities, insurance products including annuities and ETFs, although Common Cents
primarily recommends diversified portfolios made up of ETFs and indexed mutual funds.
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Common Cents may use other securities as well to help diversify a portfolio when
applicable.
Written Acknowledgement of Fiduciary Status
When we provide investment advice to you regarding your retirement plan account or
individual retirement account, we are 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. The way we make money
creates some conflicts with your interests, so we operate under a special rule that requires
us to act in your best interest and not put our interest ahead of yours. Under this special
rule’s provisions, we must:
● Meet a professional standard of care when making investment recommendations
(give prudent advice).
● Never put our financial interests ahead of yours when making recommendations
(give loyal advice).
● Avoid misleading statements about conflicts of interest, fees, and investments.
● Follow policies and procedures designed to ensure that we give advice that is in
your best interest.
● Charge no more than is reasonable for our services.
● Give you basic information about conflicts of interest.
C. Client Tailored Services and Client Imposed Restrictions
Common Cents offers the same suite of services to all of its clients. However, specific client
investment strategies and their implementation are dependent upon the client Investment
Policy Statement which outlines each client’s current situation (income, tax levels, and
risk tolerance levels). Clients may impose restrictions in investing in certain securities or
types of securities in accordance with their values or beliefs. However, if the restrictions
prevent Common Cents from properly servicing the client account, or if the restrictions
would require Common Cents to deviate from its standard suite of services, Common
Cents reserves the right to end the relationship.
D. Wrap Fee Programs
Common Cents does not participate in wrap fee programs. A wrap fee program is an
investment program where the investor pays one stated fee that includes management
fees and transaction costs.
E. Assets Under Management
Common Cents has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$113,726,879
$0
December 2025
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Item 5: Fees and Compensation
Although we generally adhere to the published fee schedule, in certain limited and special
circumstances, the advisory fee may be negotiable. Lower fees for comparable services may
be available from other sources.
A. Fee Schedule
Portfolio Management Fees
Annual Fees
Total Assets Under
Management
$0 - $999,999
1.00%
$1,000,000 - $1,999,999
0.75%
$2,000,000 - $3,999,999
0.50%
$4,000,000 - $5,999,999
0.25%
$6,000,000 - AND UP
0.10%
Common Cents uses the value of the account as of the last business day of the billing
period, after taking into account deposits and withdrawals, for purposes of determining
the market value of the assets upon which the advisory fee is based.
Clients may terminate the Investment Advisory Contract upon written notice.
B. Payment of Fees
Payment of Portfolio Management Fees
Asset-based portfolio management fees are withdrawn directly from the client's accounts
with client's written authorization on a monthly basis. Fees are paid in arrears.
C. Client Responsibility for Third Party Fees
Clients are responsible for the payment of all third-party fees (i.e. custodian fees,
brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and
distinct from the fees and expenses charged by Common Cents. Please see Item 12 of this
brochure regarding broker-dealer/custodian.
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D. Prepayment of Fees
Common Cents collects its fees in arrears. It does not collect fees in advance.
E. Outside Compensation for the Sale of Securities to Clients
1. Conflicts of Interest
Common Cents does not receive compensation or commissions for the sale of any
investment products, thereby eliminating a direct conflict of interest in this area.
Should any conflicts of interest arise in the future, Common Cents will disclose them
to the client prior to any transaction or recommendation.
2. Clients Have the Option to Purchase Recommended Products from
Other Brokers
Clients always have the option to purchase Common Cents recommended products
through other brokers or agents that are not affiliated with Common Cents.
Item 6: Performance-Based Fees and Side-By-Side Management
Common Cents does not accept performance-based fees or other fees based on a share of capital
gains on or capital appreciation of the assets of a client.
Item 7: Types of Clients
Common Cents generally provides advisory services to the following types of clients:
❖
❖
❖
Individuals
High-Net-Worth Individuals
Small Businesses
There is no account minimum for any of Common Cents' services.
Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss
A. Methods of Analysis and Investment Strategies
Methods of Analysis
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Common Cents Wealth Management's investment philosophy aligns with a passive
approach by primarily recommending diversified portfolios made up of Exchange Traded
Funds (ETFs) and indexed mutual funds. This strategy is underpinned by their use of
Modern Portfolio Theory, which aims to maximize expected return for a given level of
risk by carefully selecting asset proportions. By focusing on index-based products and
managing risk according to this theory, the firm emphasizes a long-term trading strategy
designed to capture market rates of return and risk, which is a hallmark of passive
investing.
Modern portfolio theory assumes that investors are risk averse, meaning that given two
portfolios that offer the same expected return, investors will prefer the less risky one.
Thus, an investor will take on increased risk only if compensated by higher expected
returns. Conversely, an investor who wants higher expected returns must accept more
risk. The exact trade-off will be the same for all investors, but different investors will
evaluate the trade-off differently based on individual risk aversion characteristics. The
implication is that a rational investor will not invest in a portfolio if a second portfolio
exists with a more favorable risk-expected return profile – i.e., if for that level of risk an
alternative portfolio exists which has better expected returns.
Investment Strategies
Long term trading is designed to capture market rates of both return and risk. Due to its
nature, the long-term investment strategy can expose clients to various types of risk that
will typically surface at various intervals during the time the client owns the investments.
These risks include but are not limited to inflation (purchasing power) risk, interest rate
risk, economic risk, market risk, and political/regulatory risk.
Investing in securities involves a risk of loss that you, as a client, should be prepared
to bear.
B. Risks of Specific Securities Utilized
Clients should be aware that there is a material risk of loss using any investment strategy.
The investment types listed below are not guaranteed or insured by the FDIC or any other
government agency.
Mutual Funds: Investing in mutual funds is subject to market risk, which includes the
potential for loss of principal. All mutual funds incur operating expenses and
management fees that consequently reduce investment returns. Funds are broadly
categorized by their underlying holdings, primarily consisting of fixed income securities
(typically associated with lower risk) or equity securities (typically associated with higher
risk).
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Fixed income investments generally pay a return on a fixed schedule, though the amount
of the payments can vary. This type of investment can include corporate and government
debt securities, leveraged loans, high yield, and investment grade debt and structured
products, such as mortgage and other asset-backed securities, although individual bonds
may be the best-known type of fixed income security.
In general, the fixed income market is volatile and fixed income securities carry interest
rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is
usually more pronounced for longer-term securities.) Fixed income securities also carry
inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and
counterparties. The risk of default on treasury inflation protected/inflation linked bonds
is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry
a potential risk of losing share price value, albeit rather minimal.
Exchange Traded Funds (ETFs): An Exchange Traded Fund (ETF) is a security that holds
a basket of assets, such as stocks or bonds, providing investors with immediate
diversification. Unlike traditional mutual funds, ETFs trade on a stock exchange
throughout the day, allowing their prices to fluctuate with market supply and demand.
● Risk of Principal Loss: As with stocks, investing in ETFs carries the risk of losing capital,
potentially up to 100% loss.
● Market and Specific Risks: ETFs are subject to the volatility and risks of their underlying
securities, which can include:
● Foreign/Emerging Market Risk: Investments in foreign securities are exposed to
currency exchange, economic, and political risks, which are more significant in
emerging markets.
● Sector/Region Risk: ETFs targeting a narrow area are generally subject to greater
market volatility and the specific risks of that sector or region.
● Complex Strategy Risk: Those using leverage, derivatives, or complex investment
strategies involve additional risks.
● Trading and Price Discrepancy Risk:
● An ETF's trading price may be different from its net asset value (NAV), meaning it
can trade at a premium or discount.
● The degree of liquidity varies, and losses can be magnified if there is no liquid
market when you attempt to sell shares.
● Fund Operation Risks: Concerns include complexity, conflicts of interest, and the risk of
inadequate regulatory compliance. ETFs can also be subject to shutdown risks.
Costs Involved with ETFs
● Fund Expenses: All ETFs have operating expenses and management fees. For index-tracking
ETFs, these fees, expenses, and tracking errors mean the fund's return will usually differ
from the index it tracks.
● Trading Costs: Regular trading of ETFs adds costs to your portfolio, which may counteract
the benefit of the fund's low internal fees
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Past performance is not indicative of future results. Investing in securities involves a
risk of loss that you, as a client, should be prepared to bear.
Item 9: Disciplinary Information
A. Criminal or Civil Actions
There are no criminal or civil actions to report.
B. Administrative Proceedings
There are no administrative proceedings to report.
C. Self-regulatory Organization (SRO) Proceedings
There are no self-regulatory organization proceedings to report.
Item 10: Other Financial Industry Activities and Affiliations
A. Registration as Broker/Dealer or Broker/Dealer Representative
Neither Common Cents nor its representatives are registered as, or have pending
applications to become, a broker/dealer or a representative of a broker/dealer.
B. Registration as a Futures Commission Merchant, Commodity
Pool Operator, or a Commodity Trading Advisor
Neither Common Cents nor its representatives are registered as or have pending
applications to become either a Futures Commission Merchant, Commodity Pool
Operator, or Commodity Trading Advisor or an associated person of the foregoing
entities.
C. Registration Relationships Material to this Advisory Business
and Possible Conflicts of Interests
Neither Common Cents nor its representatives have any material relationships to this
advisory business that would present a possible conflict of interest.
D. Selection of Other Advisers or Managers and How This Adviser
is Compensated for Those Selections
Common Cents does not utilize nor select third-party investment advisers.
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Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
A. Code of Ethics
Common Cents has a formal, written Code of Ethics covering key areas of compliance and
conduct. These areas include:
● Prohibited trading activities (e.g., Insider Trading, Prohibited Purchases and Sales,
Personal Securities Transactions)
● Conflicts of Interest, Gifts and Entertainment, and Confidentiality
● Firm procedures for Compliance, Reporting Violations, Recordkeeping, and Annual
Review
● Compliance Officer Duties, Training, and Sanctions
The firm's full Code of Ethics is available free of charge to any current or prospective
client upon request.
B. Recommendations Involving Material Financial Interests
Common Cents does not recommend that clients buy or sell any security in which a
related person to Common Cents or Common Cents has a material financial interest.
C. Investing Personal Money in the Same Securities as Clients
As fiduciaries, Common Cents and its representatives may invest in the same ETFs,
mutual funds, and/or stocks that are recommended to clients. This is done to ensure our
interests are aligned with yours, as we invest alongside our clients, and not to improperly
influence a security's price or trading volume.
D. Trading Securities At/Around the Same Time as Clients’ Securities
Please see Item 11.C above.
Item 12: Brokerage Practices
A. Factors Used to Select Custodians and/or Broker/Dealers
Common Cents maintains an exclusive relationship with Schwab Institutional, a division
of Charles Schwab & Co., Inc., for the custody and brokerage of client assets. This policy
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is in place to achieve operational efficiencies and keep overall costs low for our clients. As
a result, clients must open and maintain their accounts with this custodian to utilize our
advisory services; those who wish to use a different custodian would need to seek services
from another investment advisor or transact directly with another financial institution.
1. Research and Other Soft-Dollar Benefits
Common Cents does not have a formal soft dollar program where client fees are explicitly
used to pay for third-party services. However, in connection with client securities
transactions, we may receive research, products, and other services (often called "soft
dollar benefits") from our custodian, Schwab Institutional. This practice is consistent with
the safe harbor provision contained in Section 28(e) of the Securities Exchange Act of 1934,
as amended.
Conflict of Interest Disclosure
● Firm Benefit and Incentive: We benefit by receiving these services (such as research,
technology, and practice management tools) at no direct cost. This creates a potential conflict
of interest, as it provides an incentive for us to recommend and continue using Schwab
Institutional for client accounts.
● Client Information: Schwab, the custodian, is compensated by account holders through
asset-based fees and other transaction-related charges. We do not attempt to allocate the
value of the soft dollar benefits to clients in proportion to their trading activity, and there is
no guarantee that any individual client will directly benefit from the services received.
2. Brokerage for Client Referrals
Common Cents receives no referrals from a broker-dealer or third party in exchange
for using that broker-dealer or third party.
3. Clients Directing Which Broker/Dealer/Custodian to Use
Common Cents will require clients to use a specific broker-dealer to execute
transactions. Not all advisers require clients to use a particular broker-dealer.
B. Aggregating (Block) Trading for Multiple Client Accounts
Common Cents may combine (aggregate or 'block') orders for the same securities across
multiple client accounts. This practice is to seek more favorable prices, lower brokerage
costs, and more efficient execution for all participating clients. We are committed to a fair
and equitable allocation of the securities to all clients and will periodically review trades
to ensure no single account is systematically disadvantaged by this policy.
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Item 13: Review of Accounts
A. Frequency and Nature of Periodic Reviews and Who Makes
Those Reviews
All client accounts receiving ongoing advisory services are reviewed at least quarterly by
Common Cents. This review is focused on the client's respective investment policies and risk
tolerance levels.
B. Factors That Will Trigger a Non-Periodic Review of Client Accounts
Reviews may be triggered by changes in a client's financial situation (such as retirement,
termination of employment, physical move, or inheritance).
C. Content and Frequency of Regular Reports Provided to Clients
Each client of Common Cents' advisory services provided on an ongoing basis will receive a
monthly account statement from the custodian, which details the client's assets held, asset
value, and the advisory fee. The fee calculation, though performed by third-party software, is
included on the custodian's monthly statement. Common Cents will also provide a separate
written statement at least monthly, posting invoices for fees and performance reporting.
Item 14: Client Referrals and Other Compensation
A. Economic Benefits Provided by Third Parties for Advice
Rendered to Clients (Includes Sales Awards or Other Prizes)
Common Cents does not receive any economic benefit, directly or indirectly from any
third party for advice rendered to Common Cents' clients.
With respect to Schwab, Common Cents gains access to Schwab’s institutional trading
and custody services, which are typically not available to Schwab retail investors. These
services are generally provided to independent investment advisers at no charge,
provided that at least $10 million of the adviser’s clients’ assets are maintained in accounts
at Schwab Advisor Services.
Schwab’s services include:
● Brokerage services related to the execution of securities transactions.
● Custody.
● Research (advice, analyses, and reports).
● Access to mutual funds and other investments usually reserved for institutional
investors or those with significantly higher minimum initial investments.
11
For Common Cents client accounts held in Schwab's custody, Schwab typically does not
charge separately for custody services. Instead, Schwab is compensated by account
holders through commissions or other transaction-related or asset-based fees for securities
trades executed through Schwab or settled into Schwab accounts.
Schwab also offers other products and services that benefit Common Cents but may not
directly benefit its clients’ accounts. These include:
● Educational Events: National, regional, or Common Cents-specific educational events
organized and/or sponsored by Schwab Advisor Services.
● Business Entertainment: Occasional business entertainment of Common Cents
personnel by Schwab Advisor Services, such as meals, invitations to sporting events,
and other forms of entertainment, sometimes accompanying educational opportunities.
● Account Management and Administration Tools: Software and other technology (and
related training) that provide access to client account data (e.g., trade confirmations,
account statements), facilitate trade execution (and allocation of aggregated trade
orders), provide research, pricing information, and other market data, facilitate payment
of Common Cents' fees, and assist with back-office training, support, recordkeeping,
and client reporting. These services generally support all or a substantial number of
Common Cents' accounts.
● Business Development Services: Services intended to help Common Cents manage and
develop its business, including professional compliance, legal and business consulting,
publications and conferences on practice management, information technology, business
succession, regulatory compliance, employee benefits providers, human capital
consultants, insurance, and marketing.
● Third-Party Vendor Support: Schwab may make available, arrange, and/or pay
vendors for these types of services rendered to Common Cents by independent third
parties. Schwab Advisor Services may discount or waive fees for some of these services
or pay all or a portion of the fees of a third-party provider.
Common Cents is independently owned and operated and is not affiliated with Schwab.
B. Compensation to Non – Advisory Personnel for Client Referrals
Common Cents does not directly or indirectly compensate any person who is not advisory
personnel for client referrals.
Item 15: Custody
When advisory fees are deducted directly from client accounts at client's custodian, Common
Cents will be deemed to have limited custody of client's assets and must have written
authorization from the client to do so. Clients will receive all account statements and billing
invoices that are required in each jurisdiction, and they should carefully review those statements
for accuracy.
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Item 16: Investment Discretion
Common Cents provides discretionary and non-discretionary investment advisory services to
clients. The advisory contract established with each client sets forth the discretionary authority
for trading. Where investment discretion has been granted, Common Cents generally manages
the client’s account and makes investment decisions without consultation with the client as to
when the securities are to be bought or sold for the account, the total amount of the securities to
be bought/sold, what securities to buy or sell, or the price per share.
Item 17: Voting Client Securities (Proxy Voting)
Common Cents will not ask for, nor accept voting authority for client securities. Clients will
receive proxies directly from the issuer of the security or the custodian. Clients should direct all
proxy questions to the issuer of the security.
Item 18: Financial Information
A. Balance Sheet
Common Cents neither requires nor solicits prepayment of more than $1,200 in fees per
client, six months or more in advance, and therefore is not required to include a balance
sheet with this brochure.
B. Financial Conditions Reasonably Likely to Impair Ability to
Meet Contractual Commitments to Clients
Neither Common Cents nor its management has any financial condition that is likely to
reasonably impair Common Cents' ability to meet contractual commitments to clients.
C. Bankruptcy Petitions in Previous Ten Years
Common Cents has not been the subject of a bankruptcy petition.
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