Overview
- Headquarters
- Great Falls, VA
- Average Client Assets
- $3.1 million
- Minimum Account Size
- $1,000,000
- SEC CRD Number
- 328429
Fee Structure
Primary Fee Schedule (DISCLOSURE BROCHURE FOR DECISIONMAP WEALTH MANAGEMENT, LLC)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.10% |
| $1,000,001 | $3,000,000 | 0.80% |
| $3,000,001 | $5,000,000 | 0.70% |
| $5,000,001 | $10,000,000 | 0.60% |
| $10,000,001 | and above | 0.25% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $11,000 | 1.10% |
| $5 million | $41,000 | 0.82% |
| $10 million | $71,000 | 0.71% |
| $50 million | $171,000 | 0.34% |
| $100 million | $296,000 | 0.30% |
Clients
- HNW Share of Firm Assets
- 96.55%
- Total Client Accounts
- 799
- Discretionary Accounts
- 644
- Non-Discretionary Accounts
- 155
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Investment Advisor Selection
Regulatory Filings
Primary Brochure: DISCLOSURE BROCHURE FOR DECISIONMAP WEALTH MANAGEMENT, LLC (2026-03-11)
View Document Text
March 11, 2026
Disclosure Brochure
a Registered Investment Adviser
746 Walker Road, Suite 16
Great Falls, VA 22066
(703) 520-1160
www.decisionmap.com
This brochure provides information about the qualifications and business practices of DecisionMap Wealth
Management, LLC (hereinafter “DMWM” or the “Firm”). If you have any questions about the contents of
this brochure, please contact the Firm at the telephone number listed above. The information in this brochure
has not been approved or verified by the United States Securities and Exchange Commission (SEC) or by any
state securities authority. Additional information about the Firm is available on the SEC’s website at
www.adviserinfo.sec.gov. The Firm is a registered investment adviser. Registration does not imply any
level of skill or training.
Disclosure Brochure
DecisionMap Wealth Management, LLC
Item 2. Material Changes
In this Item, DMWM is required to discuss any material changes that have been made to the brochure since
the last annual amendment . DMWM has updated its advisory fee schedule for Wealth Management
Services. The revised fee schedule applies to new households entering into advisory agreements as of
March 2026. Further details regarding advisory fees, billing practices, and the revised fee schedule are
described in Item 5: Fees and Compensation of this brochure.
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Item 3. Table of Contents
Item 2. Material Changes ................................................................................................................................................................ 2
Item 3. Table of Contents ................................................................................................................................................................ 3
Item 4. Advisory Business .............................................................................................................................................................. 4
Item 5. Fees and Compensation ...................................................................................................................................................... 8
Item 6. Performance-Based Fees and Side-by-Side Management .................................................................................................. 12
Item 7. Types of Clients ................................................................................................................................................................ 12
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ........................................................................................... 12
Item 9. Disciplinary Information ................................................................................................................................................... 17
Item 10. Other Financial Industry Activities and Affiliations ........................................................................................................ 17
Item 11. Code of Ethics................................................................................................................................................................. 19
Item 12. Brokerage Practices ......................................................................................................................................................... 19
Item 13. Review of Accounts ........................................................................................................................................................ 23
Item 14. Client Referrals and Other Compensation ....................................................................................................................... 24
Item 15. Custody ........................................................................................................................................................................... 24
Item 16. Investment Discretion ..................................................................................................................................................... 25
Item 17. Voting Client Securities .................................................................................................................................................. 25
Item 18. Financial Information ...................................................................................................................................................... 25
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Item 4. Advisory Business
DMWM offers a variety of advisory services, which include financial planning, consulting, and investment
management services. Prior to DMWM rendering any of the foregoing advisory services, clients are
required to enter into one or more written agreements with DMWM setting forth the relevant terms and
conditions of the advisory relationship (the “Advisory Agreement”).
DMWM is registered with the U.S. Securities and Exchange Commission as an investment adviser. Our
firm is majority owned by Paul Bennett and Mark Weber. As of December 31, 2025, we provide continuous
management services for $306,311,225 in client assets on a discretionary basis, and $57,122,332 in client
assets on a non-discretionary basis.
While this brochure generally describes the business of DMWM, certain sections also discuss the activities
of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying
a similar status or performing similar functions), employees or other persons who provide investment advice
on DMWM’s behalf and are subject to the Firm’s supervision or control.
Financial Planning and Consulting Services
DMWM offers clients a broad range of financial planning and consulting services, which include any or all
of the following functions:
Business Planning
Insurance Planning
•
•
Tax and Cash Flow Analysis
Retirement Planning
•
•
Trust and Estate Planning
Education Planning
•
•
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While each of these services is available on a stand-alone basis, certain of them can also be rendered in
conjunction with investment portfolio management as part of a comprehensive wealth management
engagement (described in more detail below).
In performing these services, DMWM is not required to verify any information received from the client or
from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely
on such information. DMWM recommends certain clients engage the Firm for additional related services,
its Supervised Persons in their individual capacities as insurance agents and/or other professionals to
implement its recommendations. Clients are advised that a conflict of interest exists for the Firm to
recommend that clients engage DMWM or its affiliates to provide (or continue to provide) additional
services for compensation, including investment management services. Clients retain absolute discretion
over all decisions regarding implementation and are under no obligation to act upon any of the
recommendations made by DMWM under a financial planning or consulting engagement. Clients are
advised that it remains their responsibility to promptly notify the Firm of any change in their financial
situation or investment objectives for the purpose of reviewing, evaluating, or revising DMWM’s
recommendations and/or services.
Investment and Wealth Management Services
DMWM provides clients with wealth management services which include a broad range of financial
planning and consulting services as well as discretionary management of investment portfolios.
DMWM primarily allocates client assets among various individual debt and equity securities, mutual funds,
exchange-traded funds (“ETFs”), privately placed securities (including debt, equity and/or interests in
pooled investment vehicles) and third-party money managers (“third-party managers”) in accordance with
their stated investment objectives.
Where appropriate, the Firm also provides advice about any type of legacy position or other investment
held in client portfolios, but clients should not assume that these assets are being continuously monitored
or otherwise advised on by the Firm unless specifically agreed upon. Clients can engage DMWM to manage
and/or advise on certain investment products that are not maintained at their primary custodian, such as
variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and
qualified tuition plans (i.e., 529 plans). In these situations, DMWM directs or recommends the allocation
of client assets among the various investment options available with the product. These assets are generally
maintained at the underwriting insurance company, or the custodian designated by the product’s provider.
DMWM tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a
continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives.
DMWM consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time
horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients
are advised to promptly notify DMWM if there are changes in their financial situation or if they wish to
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place any limitations on the management of their portfolios. Clients can impose reasonable restrictions or
mandates on the management of their accounts if DMWM determines, in its sole discretion, the conditions
would not materially impact the performance of a management strategy or prove overly burdensome to the
Firm’s management efforts.
Use of Third-Party Managers
As mentioned above, DMWM selects certain third-party managers to actively manage a portion of its
clients’ assets. The specific terms and conditions under which a client engages a third-party manager are
set forth in a separate written agreement with the designated third-party manager. That agreement can be
between the Firm and the third-party manager (often called a subadvisor) or the client and the third-party
manager (sometimes called a separate account manager). In addition to this brochure, clients
will typically also receive the written disclosure documents of the respective third-party managers engaged
to manage their assets.
DMWM evaluates a variety of information about third-party managers, which includes the third-party
managers’ public disclosure documents, materials supplied by the third-party managers themselves and
other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the
third-party managers’ investment strategies, past performance, and risk results in relation to its clients’
individual portfolio allocations and risk exposure. DMWM also takes into consideration each third-party
manager’s management style, returns, reputation, financial strength, reporting, pricing, and research
capabilities, among other factors.
DMWM continues to provide services relative to the discretionary selection of the third-party managers. On
an ongoing basis, the Firm monitors the performance of those accounts being managed by third-party
managers. DMWM seeks to ensure the third-party managers’ strategies and target allocations remain
aligned with its clients’ investment objectives and overall best interests. For more information about the
third-party managers, see the Dynasty TAMP disclosures, below.
Use of Dynasty TAMP
DMWM has entered into a contractual relationship with Dynasty Financial Partners, LLC (“Dynasty”),
which provides the Firm with operational and back-office support including access to a network of service
providers. Through the Dynasty network of service providers, DMWM can receive preferred pricing on
trading technology, reporting, custody, brokerage, compliance, and other related services.
In addition, Dynasty’s subsidiary, Dynasty Wealth Management, LLC (“DWM”), an SEC registered
investment adviser, provides access to a range of investment services including: separately managed
accounts (“SMA”), mutual fund and ETF asset allocation strategies, and unified managed accounts (“UMA”
and together with the SMAs is the same as the third-party managers) managed by external third party
managers (collectively, the “Investment Programs”). DMWM can separately engage the services of
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Dynasty and/or its subsidiaries to access the Investment Programs. Under the SMA and UMA programs,
DMWM will maintain the ability to select the specific, underlying third-party managers that will, in turn,
have day-to-day discretionary trading authority over the requisite client assets.
Dynasty charges a “Program Fee,” for which, unless otherwise disclosed, the client will be charged, separate
from and in addition to such client’s annual investment management fee, as described in Item 5 below. This
arrangement presents a conflict of interest because DMWM can use the Investment Programs with higher
Program Fees that will not affect the DMWM’s annual investment management fee. This conflict is
mitigated because DMWM does not receive any portion of the Program Fees paid directly to Dynasty or
the service providers made available through its platform and therefore DMWM is free to choose the
Investment Program that best suits the clients’ needs.
Dynasty and DMWM offer an investment management platform (the “Platform” or the “TAMP") that is
available to the advisers in the Dynasty Network, such as DMWM. Through the Platform, DMWM and
Dynasty collectively provide certain technology, administrative, operations and advisory support services
that allow advisers to manage their own portfolios and access third-party managers. DMWM can allocate all
or a portion of client assets among the different third-party managers via the Platform. DMWM can also
use the model and/or overlay management feature of the TAMP by creating its own asset allocation model
and underlying investments that comprise the model. Through the model management feature, the Firm can
outsource the implementation of trade orders and periodic rebalancing of the model when needed.
DMWM will maintain the direct contractual relationship with each client and obtain, through such
agreements, the authority to engage the third-party managers, DWM and/or Dynasty, as applicable, for
services rendered through the Platform in service of such client. DMWM can delegate discretionary trading
authority to DWM and/or third-party managers to affect investment and reinvestment of client assets with the
ability to buy, sell or otherwise affect investment transactions and allocate client assets. If a client is
participating in certain Investment Programs, DWM or the designated third-party manager, as applicable, is
also authorized without prior consultation of DMWM or the client to buy, sell, trade or allocate such client’s
assets in accordance with the client’s designated portfolio and to deliver instructions to the designated
broker-dealer and/or custodian of such client’s assets.
In providing investment advice and portfolio management services to clients, the Firm acts as an investment
adviser and fiduciary to and on behalf of each client and not as an agent of Dynasty or DWM.
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Item 5. Fees and Compensation
DMWM offers services on a fee basis, which includes fixed, as well as fees based upon assets under
management or advisement. Additionally, certain of the Firm’s Supervised Persons, in their individual
capacities, offer insurance products under a separate commission-based arrangement.
Financial Planning and Consulting Fees
DMWM charges a fixed fee for providing financial planning and consulting services under a stand-alone
engagement. These fees are negotiable but range from $10,000 to $50,000 depending upon the scope and
complexity of the services and the professional rendering the financial planning and/or the consulting
services. If the client engages the Firm for additional investment advisory services, DMWM can offset all
or a portion of its fees for those services based upon the amount paid for the financial planning and/or
consulting services.
The terms and conditions of the financial planning and/or consulting engagement are set forth in the
Advisory Agreement. For project-based services DMWM requires one-half of the fee payable upon
execution of the Advisory Agreement. The outstanding balance is due upon delivery of the financial plan
or completion of the agreed upon services. The Firm does not, however, take receipt of $1,200 or more in
prepaid fees, six or more months in advance of services rendered.
Wealth Management Fees
DMWM offers wealth management services for an annual fee based on the amount of assets under the
Firm’s management. The wealth management services include a broad range of financial planning and
consulting services as well as discretionary management of investment portfolios. This management fee
varies in accordance with the following blended fee schedule, which is effective for new households as of
March 2026:
PORTFOLIO VALUE
BASE FEE
First $1,000,000
Next $2,000,000
Next $2,000,000
Next $5,000,000
Assets more than$10,000,000
1.10%
0.80%
0.70%
0.60%
0.25%
For clarification, this is a blended fee schedule. All clients will pay 1.1% on their first $1M of AUM. The
next $2M of AUM will be billed at 0.8%. Thus a $3M client would pay $11,000 on the first $1M and
$16,000 on the next $2M, for a total of $27,000, which equates to a blended rate of 0.9%. The annual fee
is prorated and charged quarterly, in advance, based upon the market value of the assets being managed by
DMWM on the last day of the previous quarter as determined by a party independent from the Firm
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(including the client’s custodian or another third-party).
Prior Fee Structure for Legacy Clients
The standard fee structure in place prior to March 2026 is as follows: Clients will pay 1.1% on their first
$1M of AUM. The next $2M of AUM will be billed at 0.7%. Thus a $3M client would pay $11,000 on
the first $1M and $14,000 on the next $2M, for a total of $25,000, which equates to a blended rate of
0.8333%. The annual fee is prorated and charged quarterly, in advance, based upon the market value of the
assets being managed by DMWM on the last day of the previous quarter as determined by a party
independent from the Firm (including the client’s custodian or another third-party).
PORTFOLIO VALUE
BASE FEE
First $1,000,000
Next $2,000,000
Next $2,000,000
Next $5,000,000
Assets more than$10,000,000
1.10%
0.70%
0.60%
0.50%
0.25%
The Firm includes cash in a client’s account in determining the valuation for billing purposes. The Firm
can, in its sole discretion, not include cash in determining the fee, especially when a client has a high
percentage of cash for reasons other than the Firm's investment management decision.
If assets are deposited into or withdrawn from an account after the inception of a billing period, fee
adjustments will be made for deposits and withdrawals in excess of $50,000 during the quarter. For the
initial period of an engagement, the fee is calculated on a pro rata basis. In the event the advisory agreement
is terminated, the fee for the final billing period is prorated through the effective date of the termination and
the outstanding or unearned portion of the fee is charged or refunded to the client, as appropriate.
Additionally, for asset management services the Firm provides with respect to certain client holdings (e.g.,
held-away assets, accommodation accounts, alternative investments, etc.), DMWM can negotiate a fee rate
that differs from the range set forth above. Clients are advised that a conflict of interest exists for the Firm
to recommend that clients engage DMWM for additional services for compensation, including rolling over
retirement accounts or moving other assets to the Firm’s management. Clients retain absolute discretion
over all decisions regarding engaging the Firm and are under no obligation to act upon any of the
recommendations.
Fee Discretion
DMWM can, in its sole discretion, negotiate to charge a lesser fee based upon certain criteria, such as
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anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be
managed, related accounts, account composition, pre-existing/legacy client relationship, account retention,
pro bono activities, or competitive purposes.
Additional Fees and Expenses
In addition to the advisory fees paid to DMWM, 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 securities brokerage commissions,
transaction fees, custodial fees, fees attributable to alternative assets, fees charged by the third-party
managers, margin and other borrowing costs, charges imposed directly 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. The Firm’s brokerage practices are
described at length in Item 12, below.
Dynasty Fees
As discussed in Item 4, DMWM uses Dynasty’s TAMP services. As described above, Program Fees and
the third-party manager-related charges are also not included in the investment management fee client pays
to DMWM. Clients will be charged, separate from and in addition to their investment management fee, any
third-party manager fees applicable. DMWM does not receive any portion of the fees paid directly to
Dynasty or the service providers made available through its platform, including the third-party managers.
If an account is being charged a minimum account Program fee because of the total market value of the
account, the advisory fee charged can be higher than the stated maximum annual fee quoted in both fee
schedules above.
The third-party manager fees are determined by the particular program(s) and manager(s) with which the
client’s assets are invested and are calculated based upon a percentage of the client assets under
management, as applicable. The Program fee generally ranges from 0 - 0.30% annually and can be subject
to a minimum account fee up to $120. Third party fixed income manager fees generally range up to 0.90%
annually, and third-party equity manager fees generally range up to 1.50% annually. There can be other
administrative fees ranging from 1 – 3bps charged for setting up the third-party managers on the TAMP.
If a third-party manager is used to manage your account, there are some third-party managers that charge
their management fees using average daily balance. The TAMP will calculate these third-party money
manager fees as described above, quarterly in advance. Because these two methodologies differ,
reconciliation is necessary at the end of the quarter to ensure accurate billing. This true-up billing, which
can be a credit or debit, reflects the difference between the quarterly in advance fee (TAMP) and the actual
fee based on average daily balances (Third-party manger).
Clients should note that the total fee reflected on their custodial statement will represent the sum of
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DMWM’s investment management fee, Program Fee(s), and third-party manager fees, accordingly.
Clients should review such statements to determine the total amount of fees associated with their requisite
investments.
Under the Dynasty TAMP, DMWM can use mutual funds and ETF asset allocation strategies. The Program
fee for these strategies/models will be up to .04%. The Program fee will be separate from the investment
management fee. The Client should be aware that the underlying securities have internal expenses and/or
management fees associated with it, however the Firm does not participate in any of Dynasty’s or other
third-party fees.
Use of Third-Party for Certain Assets Held Away
For assets held at a custodian that is not directly accessible by DMWM ("Held Away Accounts"), the Firm
can, but is not required to, manage these Held Away Accounts using Pontera that allows the Firm to view
and manage assets. The annual fee for investment management services for Held Away Accounts will
follow the Firm’s fee schedule as noted above. The fees will not be deducted directly from the accounts
managed through Pontera. The client does not pay an additional fee for Pontera. Clients will give written
authorization to deduct the Firm’s fees from an account managed the Firm. Further, the qualified custodian
will deliver an account statement to clients at least quarterly. These account statements will show all
disbursements in the account.
Direct Fee Debit
Clients provide DMWM and/or certain third-party managers with the authority to directly debit their
accounts for payment of the investment advisory fees. The Financial Institutions that act as qualified
custodians for client accounts, from which the Firm retains the authority to directly deduct fees, have agreed
to send statements to clients not less than quarterly detailing all account transactions, including any amounts
paid to DMWM.
Account Additions and Withdrawals
Clients can make additions to and withdrawals from their account at any time, subject to DMWM’s right to
terminate an account. Additions can be in cash or securities provided that the Firm reserves the right to
liquidate any transferred securities or declines to accept particular securities into a client’s account. Clients
can withdraw account assets on notice to DMWM, subject to the usual and customary securities settlement
procedures. As discussed above, Fee adjustments will be made for deposits and withdrawals in excess of
$50,000 during the quarter. The Firm designs its portfolios as long-term investments, and the withdrawal
of assets can impair the achievement of a client’s investment objectives. DMWM can consult with its
clients about the options and implications of transferring securities. Clients are advised that when
transferred securities are liquidated, they can be subject to transaction fees, short-term redemption fees, fees
assessed at the mutual fund level (e.g., contingent deferred sales charges) and/or tax ramifications.
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Item 6. Performance-Based Fees and Side-by-Side Management
DMWM does not provide any services for a performance-based fee (i.e., a fee based on a share of capital
gains or capital appreciation of a client’s assets).
Item 7. Types of Clients
DMWM offers services to individuals, trusts, estates, charitable organizations, corporations and other
business entities, pension, and profit-sharing plans.
Minimum Account Value
As a condition for starting and maintaining an investment management relationship, DMWM imposes a
minimum portfolio value of $1,000,000. DMWM can, in its sole discretion, accept clients with smaller
portfolios based upon certain criteria, including anticipated future earning capacity, anticipated future
additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-
existing client, account retention, and pro bono activities. DMWM only accepts clients with less than the
minimum portfolio size if the Firm determines the smaller portfolio size will not cause a substantial increase
of investment risk beyond the client’s identified risk tolerance. DMWM can, in its sole discretion, aggregate
the portfolios of family members to meet the minimum portfolio size.
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
DMWM utilizes a combination of fundamental, technical, and cyclical methods of analysis.
Fundamental analysis involves an evaluation of the fundamental financial condition and competitive
position of a particular fund or issuer. For DMWM, this process typically involves an analysis of an issuer’s
management team, investment strategies, style drift, past performance, reputation and financial strength in
relation to the asset class concentrations and risk exposures of the Firm’s model asset allocations. A
substantial risk in relying upon fundamental analysis is that while the overall health and position of a
company may be good, evolving market conditions may negatively impact the security.
Technical analysis involves the examination of past market data rather than specific issuer information in
determining the recommendations made to clients. Technical analysis may involve the use of mathematical
based indicators and charts, such as moving averages and price correlations, to identify market patterns and
trends which may be based on investor sentiment rather than the fundamentals of the company. A
substantial risk in relying upon technical analysis is that spotting historical trends may not help to predict
such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that DMWM will
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be able to accurately predict such a reoccurrence.
Cyclical analysis is similar to technical analysis in that it involves the assessment of market conditions at a
macro (entire market or economy) or micro (company specific) level, rather than focusing on the overall
fundamental analysis of the health of the particular company that DMWM is recommending. The risks with
cyclical analysis are similar to those of technical analysis.
Investment Strategies
DMWM primarily employs a core-satellite methodology when designing investment portfolios for clients.
Core-satellite portfolios consist of two primary components. The core, which makes up the majority of the
portfolio, is generally invested in passive investment strategies that track market indices, provide broad
diversification at low cost, and are designed to be tax efficient. Satellite strategies, which comprise a smaller
portion of the portfolio, are included to complement the core and typically include active investment
strategies designed to either provide an opportunity for higher returns or to lower the risk characteristics of
the portfolio.
For core investment strategies, the Firm uses third-party stock and bond managers (third-party managers),
exchange-traded funds, and mutual funds. Satellite investment strategies include third-party active stock
managers (third-party managers), active mutual funds, and alternative investment strategies.
DMWM’s investment strategies and advice will vary depending upon each client's specific financial
situation. As such, the Firm determines investments and allocations based upon each client’s objectives,
risk tolerance, time horizon, financial information, liquidity needs and other factors. A client’s restrictions
and guidelines can affect the composition of the portfolio. It is important that clients notify the Firm
immediately with respect to any material changes to their financial circumstances, including for
example, a change in current or expected income level, tax circumstances, or employment status.
Risk of Loss
The following list of risk factors does not purport to be a complete enumeration or explanation of the risks
involved with respect to the Firm’s investment management activities. Clients should consult with their
legal, tax, and other advisors before engaging the Firm to provide investment management services on their
behalf.
Market Risks
Investing involves risk, including the potential loss of principal, and all investors should be guided
accordingly. The profitability of a significant portion of DMWM’s recommendations and/or investment
decisions can depend to a great extent upon correctly assessing the future course of price movements of
stocks, bonds and other asset classes. In addition, investments can be adversely affected by financial
markets and economic conditions throughout the world. There can be no assurance that DMWM will be
able to predict these price movements accurately or capitalize on any such assumptions.
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Volatility Risks
The prices and values of investments can be highly volatile, and are influenced by, among other things,
interest rates, general economic conditions, the condition of the financial markets, the financial condition
of the issuers of such assets, changing supply and demand relationships, and programs and policies of
governments.
Cash Management Risks
The Firm can invest some of a client’s assets temporarily in money market funds or other similar types of
investments, during which time an advisory account can be prevented from achieving its investment
objective.
Equity-Related Securities and Instruments
The Firm can take long positions in common stocks of U.S. and non-U.S. issuers traded on national
securities exchanges and over-the-counter markets. The value of equity securities varies in response to
many factors. These factors include, without limitation, factors specific to an issuer and factors specific to
the industry in which the issuer participates. Individual companies may report poor results or be negatively
affected by industry and/or economic trends and developments, and the stock prices of such companies may
suffer a decline in response. In addition, equity securities are subject to stock risk, which is the risk that
stock prices historically rise and fall in periodic cycles. U.S. and non-U.S. stock markets have experienced
periods of substantial price volatility in the past and may do so again in the future. In addition, investments
in small-capitalization, midcapitalization and financially distressed companies may be subject to more
abrupt or erratic price movements and may lack sufficient market liquidity, and these issuers often face
greater business risks.
Fixed Income Securities
While the Firm emphasizes risk-averse management and capital preservation in its fixed-income bond
portfolios, clients who invest in this product can lose money, including losing a portion of their original
investment. The prices of the securities in our portfolios fluctuate. The Firm does not guarantee any
particular level of performance. Below is a representative list of the types of risks clients should consider
before investing in this product.
•
Interest rate risk. Prices of bonds tend to move in the opposite direction to interest rate changes.
Typically, a rise in interest rates will negatively affect bond prices. The longer the duration and
average maturity of a portfolio, the greater the likely reaction to interest rate moves.
• Credit (or default) risk. A bond’s price will generally fall if the issuer fails to make a scheduled
interest or principal payment, if the credit rating of the security is downgraded, or if the perceived
creditworthiness of the issuer deteriorates.
• Liquidity risk. Sectors of the bond market can experience a sudden downturn in trading activity.
When there is little or no trading activity in a security, it can be difficult to sell the security at or
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near its perceived value. In such a market, bond prices may fall.
• Call risk. Some bonds give the issuer the option to call or redeem the bond before the maturity date.
If an issuer calls a bond when interest rates are declining, the proceeds may have to be reinvested
at a lower yield. During periods of market illiquidity or rising rates, prices of callable securities
may be subject to increased volatility.
• Prepayment risk. When interest rates fall, the principal of mortgage-backed securities may be
prepaid. These prepayments can reduce the portfolio’s yield because proceeds may have to be
reinvested at a lower yield.
• Extension risk. When interest rates rise or there is a lack of refinancing opportunities, prepayments
of mortgage-backed securities or callable bonds may be less than expected. This would lengthen
the portfolio’s duration and average maturity and increase its sensitivity to rising rates and its
potential for price declines.
Mutual Funds and ETFs
An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF
shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s
underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains,
as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for
a profit that cannot be offset by a corresponding loss.
Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a
broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily
per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees, redemption
fees). The per share NAV of a mutual fund is calculated at the end of each business day, although the actual
NAV fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a
mutual fund’s shares may differ from the NAV during periods of market volatility, which may, among other
factors, lead to the mutual fund’s shares trading at a premium or discount to actual NAV.
Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary
market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least
once daily for index-based ETFs and potentially more frequently for actively managed ETFs. However,
certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There
is also no guarantee that an active secondary market for such shares will develop or continue to exist.
Generally, an ETF only redeems shares when aggregated as creation units (usually 20,000 shares or more).
Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may have
no way to dispose of such shares.
Finally, some mutual funds and ETFs may have lock-up periods that restrict an investor from selling their
position for a period of time. Other mutual funds and ETFs could also have early redemption fees that are
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taken if the investor sells their position before a certain amount of time.
Use of Third-Party Managers
As stated above, DMWM selects certain third-party managers to manage a portion of its clients’ assets. In
these situations, DMWM continues to conduct ongoing due diligence of such managers, but such
recommendations rely to a great extent on the third-party managers’ ability to successfully implement their
investment strategies. In addition, DMWM does not have the ability to supervise the third-party managers
on a day-to-day basis.
Use of Private Collective Investment Vehicles
DMWM recommends that certain clients invest in privately placed collective investment vehicles (e.g.,
hedge funds, private equity funds, etc.). The managers of these vehicles have broad discretion in selecting
the investments. There are few limitations on the types of securities or other financial instruments which
may be traded and no requirement to diversify. Hedge funds may trade on margin or otherwise leverage
positions, thereby potentially increasing the risk to the vehicle. In addition, because the vehicles are not
registered as investment companies, there is an absence of regulation. There are numerous other risks in
investing in these securities. Clients should consult each fund’s private placement memorandum and/or
other documents explaining such risks prior to investing.
Real Estate Investment Trusts (REITs)
DMWM recommends an investment in, or allocate assets among, various real estate investment trusts
(“REITs”), the shares of which exist in the form of either publicly traded or privately placed securities.
REITs are collective investment vehicles with portfolios comprised primarily of real estate and mortgage
related holdings. Many REITs hold heavy concentrations of investments tied to commercial and/or
residential developments, which inherently subject REIT investors to the risks associated with a downturn
in the real estate market. Investments linked to certain regions that experience greater volatility in the local
real estate market may give rise to large fluctuations in the value of the vehicle’s shares. Mortgage related
holdings may give rise to additional concerns pertaining to interest rates, inflation, liquidity, and
counterparty risk.
Currency Risks
An advisory account that holds investments denominated in currencies other than the currency in which the
advisory account is denominated may be adversely affected by the volatility of currency exchange rates.
Digital Assets Risks
Investing in digital assets comes with significant risk of loss (including complete loss) that clients should
be prepared to bear, including, but not limited to, volatile market price swings or flash crashes, market
manipulation, economic, regulatory, technical, and cybersecurity risks. In addition, digital currency markets
and exchanges are not regulated with the same controls or customer protections available when investing
in traditional asset classes. A highlight of some, but not all, of the risks associate with digital currency is
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immediately below:
Volatility Risk: Digital currency is a speculative and volatile investment asset. Investors should be prepared
for volatile market swings and prolonged bear markets. Digital currency can have higher volatility than
other traditional investors such as stocks and bonds and market movements can be difficult to predict.
Economic Risk: The economic risk associated with digital currency includes the lack of widespread or
continuing digital currency adoption. The market and investors could decide that digital currency should
not be valued at the current market capitalization due to a variety of factors.
Regulatory Risk: Digital currency could be banned or highly regulated by governments that would deter
investors from buying or holding digital currency.
Technical Risk: Digital currency is a dynamic network with a codebase that is updated to add new security
and functionality features. The updated code that is merged by the core developers could potentially have
an error that threatens the security or functionality of the digital currency network.
Cybersecurity Risk: Digital currency exchanges and wallets have been hacked and digital currency has been
stolen in the past. This is a potential risk that clients must be comfortable with when investing and holding
digital currency. Theft is less likely, but still possible, when holding digital currency at a qualified custodian
in offline systems (cold storage) with institutional security and controls.
Interest Rate Risks
Interest rates may fluctuate significantly, causing price volatility with respect to securities or instruments
held by clients.
Item 9. Disciplinary Information
DMWM has not been involved in any legal or disciplinary events that are material to a client’s evaluation
of its advisory business or the integrity of its management.
Item 10. Other Financial Industry Activities and Affiliations
This item requires investment advisers to disclose certain financial industry activities and affiliations.
Licensed Insurance Agents
A number of the Firm’s Supervised Persons are licensed insurance agents and offer certain insurance
products on a fully-disclosed commissionable basis. A conflict of interest exists to the extent that DMWM
recommends the purchase of insurance products where its Supervised Persons are entitled to insurance
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commissions or other additional compensation. DMWM utilizes Advisors Excel to facilitate insurance
products. This can lead to other benefits received for processing insurance products through the Advisors
Excel platform. The Firm has procedures in place whereby it seeks to ensure that all recommendations are
made in its clients’ best interest regardless of any such affiliations.
Relationship with Dynasty Financial Partners, LLC
DMWM maintains a business relationship with Dynasty Financial Partners, LLC (“Dynasty”). Dynasty
offers operational and back-office core service support including access to a network of service providers.
Through the Dynasty network of service providers, the Firm can receive preferred pricing on trading
technology, transition support, reporting, custody, brokerage, compliance, and other related consulting
services.
While DMWM believes this open architecture structure for operational services best serves the interests of
its clients, this relationship presents certain conflicts of interest due to the fact that Dynasty is paid by the
Firm or its clients for the services referenced above. The Firm does not receive any portion of the fees paid
directly to Dynasty, its affiliates or the service providers made available through Dynasty’s platform. In
addition, the Firm reviews such relationships, including the service providers engaged through Dynasty, on
a periodic basis in an effort to ensure clients are receiving competitive rates in relation to the quality and
scope of the services provided. In addition, the Firm can receive more advantageous pricing from DWM
as assets increase, which poses a conflict of interest.
DMWM has obtained financing for its business through Dynasty Advisors Financing Services, LLC
(“DAFS”), a wholly-owned subsidiary of Dynasty and an affiliate of DWM. DAFS, in partnership with
various independent banks, has provided DMWM with a lending facility to assist with business transition
and organizational expenses and other costs associated with launching the firm. DMWM is not obligated to
use the DAFS lending facility in order to obtain other services from Dynasty. All lending is subject to
standard underwriting requirements. A portion of this loan can be furnished directly from Dynasty as a co-
lender. In such situations, DMWM will be subject to the same lending facility criteria and requirements as
applied by the independent bank.
Additionally, Dynasty Financial Partners, LLC has a minority, non-controlling interest in DMWM which
creates a conflict of interest in that it influences DMWM to use the services of Dynasty due to all the
arrangements and relationship with Dynasty. There may be other entities available that supply similar
services at a lower fee. DMWM believes that Dynasty's breadth of services, open-architecture, and
operational expertise enables DMWM to manage their clients' accounts in the client's best interests.
Controlling owners of DMWM will have full authority over all aspects of DMWM and Dynasty will have
no influence whatsoever.
In light of the foregoing, DMWM seeks at all times to ensure that any material conflicts are addressed on a
fully-disclosed basis and handled in a manner that is aligned with its clients’ best interests.
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Item 11. Code of Ethics
DMWM has adopted a code of ethics in compliance with applicable securities laws (“Code of Ethics”) that
sets forth the standards of conduct expected of its Supervised Persons. DMWM’s Code of Ethics contains
written policies reasonably designed to prevent certain unlawful practices such as the use of material non-
public information by the Firm or any of its Supervised Persons and the trading by the same of securities
ahead of clients in order to take advantage of pending orders.
The Code of Ethics also requires certain of DMWM’s personnel to report their personal securities holdings
and transactions and obtain pre-approval of certain investments (e.g., initial public offerings, limited
offerings). However, the Firm’s Supervised Persons are permitted to buy or sell securities that it also
recommends to clients if done in a fair and equitable manner that is consistent with the Firm’s policies and
procedures. This Code of Ethics has been established recognizing that some securities trade in sufficiently
broad markets to permit transactions by certain personnel to be completed without any appreciable impact
on the markets of such securities. Therefore, under limited circumstances, exceptions may be made to the
policies stated below.
When the Firm is engaging in or considering a transaction in any security on behalf of a client, no
Supervised Person with access to this information may knowingly effect for themselves or for their
immediate family (i.e., spouse, minor children and adults living in the same household) a transaction in that
security unless:
the transaction has been completed;
•
the transaction for the Supervised Person is completed as part of a batch trade with clients; or
•
a decision has been made not to engage in the transaction for the client.
•
These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii)
money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper,
repurchase agreements and other high quality short-term debt instruments, including repurchase
agreements; (iii) shares issued by money market funds; and iv) shares issued by other unaffiliated open-end
mutual funds.
Clients and prospective clients can contact DMWM to request a copy of its Code of Ethics by contacting
the Firm at the phone number on the cover page of this brochure.
Item 12. Brokerage Practices
Recommendation of Broker-Dealers for Client Transactions
DMWM recommends that clients utilize the custody, brokerage and clearing services of Charles Schwab
& Co, Inc. through its Schwab Advisor Services division (“Schwab”) and/or National Financial Services
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LLC and Fidelity Brokerage Services LLC (together with affiliates, “Fidelity” and together with Schwab
(“Custodian”) for investment management accounts. The final decision to custody assets with Custodian is
at the discretion of the client, including those accounts under ERISA or IRA rules and regulations, in which
case the client is acting as either the plan sponsor or IRA accountholder. DMWM is independently owned
and operated and not affiliated with Custodian. Custodian provides DMWM with access to its institutional
trading and custody services, which are typically not available to retail investors.
Factors which DMWM considers in recommending Custodian or any other broker-dealer to clients include
their respective financial strength, reputation, execution, pricing, research, and service. Custodian enables
the Firm to obtain many mutual funds without transaction charges and other securities at nominal
transaction charges. The commissions and/or transaction fees charged by Custodian can be higher or lower
than those charged by other Financial Institutions.
The commissions paid by DMWM’s clients to Custodian comply with the Firm’s duty to obtain “best
execution.” Clients can pay commissions that are higher than another qualified Financial Institution might
charge to effect the same transaction where DMWM determines that the commissions are reasonable in
relation to the value of the brokerage and research services received. In seeking best execution, the
determinative factor is not the lowest possible cost, but whether the transaction represents the best
qualitative execution, taking into consideration the full range of a Financial Institution’s services, including
among others, the value of research provided, execution capability, commission rates and responsiveness.
DMWM seeks competitive rates but may not necessarily obtain the lowest possible commission rates for
client transactions.
Consistent with obtaining best execution, brokerage transactions are directed to certain broker-dealers in
return for investment research products and/or services which assist DMWM in its investment decision-
making process. Such research will be used to service all of the Firm’s clients, but brokerage commissions
paid by one client may be used to pay for research that is not used in managing that client’s portfolio. The
receipt of investment research products and/or services as well as the allocation of the benefit of such
investment research products and/or services poses a conflict of interest because DMWM does not have to
produce or pay for the products or services.
Dynasty Securities, LLC (“Dynasty Securities”), which is a wholly owned subsidiary of Dynasty Financial
Partners, LLC, and an affiliate of Dynasty Wealth Management, LLC (“Dynasty Wealth Management”)
(collectively “Dynasty”) has entered into a Marketing and Business Development Agreement
(“Agreement”) with Schwab whereby Dynasty Securities and Schwab collaborate to identify financial
advisor candidates that establish a custodial relationship with Schwab and to use Dynasty’s integrated
platform services. Dynasty Securities receives payment from Schwab each quarter in connection with the
Agreement. The Agreement creates an incentive for Dynasty to encourage its network advisors to custody
clients’ assets with Schwab due to the economic benefit it may receive which is a conflict of interest. There
may be other entities available to supply similar custody services at a lower fee. Financial advisors, such
as the Firm, joining the Dynasty network of registered investment advisers are not required to select Schwab
as their custodian in order to receive services from Dynasty.
DMWM periodically and systematically reviews its policies and procedures regarding its recommendation
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of Financial Institutions in light of its duty to obtain best execution.
Software and Support Provided by Financial Institutions
DMWM receives without cost from Custodian administrative support, computer software, related systems
support, as well as other third-party support as further described below (together "Support") which allow
DMWM to better monitor client accounts maintained at Custodian and otherwise conduct its business.
DMWM receives the Support without cost because the Firm renders investment management services to
clients that maintain assets at Custodian. The Support is not provided in connection with securities
transactions of clients (i.e., not “soft dollars”). The Support benefits DMWM, but not its clients directly.
Clients should be aware that DMWM’s receipt of economic benefits such as the Support from a broker-
dealer creates a conflict of interest since these benefits will influence the Firm’s choice of broker-dealer
over another that does not furnish similar software, systems support or services Custodian. In fulfilling its
duties to its clients, DMWM endeavors at all times to put the interests of its clients first and has determined
that the recommendation of Custodian is in the best interest of clients and satisfies the Firm's duty to seek
best execution.
Specifically, DMWM receives the following benefits from Custodian: i) receipt of duplicate client
confirmations and bundled duplicate statements; ii) access to a trading desk that exclusively services its
institutional traders; iii) access to block trading which provides the ability to aggregate securities
transactions and then allocate the appropriate shares to client accounts; and iv) access to an electronic
communication network for client order entry and account information.
Custodian also makes available to the Firm, at no additional charge, certain research and brokerage services,
including research services obtained by Custodian directly from independent research companies, as
selected by DMWM (within specified parameters). These research and brokerage services are used by the
Firm to manage accounts for which it has investment discretion.
These services generally are available to independent investment advisors on an unsolicited basis, at no
charge to them so long as a certain amount of the advisor’s clients’ assets are maintained in accounts at
Custodian. Custodian’s services include brokerage services that are related to the execution of securities
transactions, custody, research, including that in the form of advice, analyses and reports, and access to
mutual funds and other investments that are otherwise generally available only to institutional investors or
would require a significantly higher minimum initial investment.
For client accounts maintained in its custody, Custodian generally does not charge separately for custody
services but is compensated by account holders through commissions or other transaction-related or asset-
based fees for securities trades that are executed through Custodian or that settle into Custodian accounts.
Custodian also makes available to the Firm other products and services that benefit the Firm but may not
benefit its clients’ accounts. These benefits can include national, regional, or Firm specific educational
events organized and/or sponsored by Custodian. Other potential benefits can include occasional business
entertainment of personnel of DMWM by Custodian personnel, including meals, invitations to sporting
events, including golf tournaments, and other forms of entertainment, some of which may accompany
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educational opportunities. Other of these products and services assist DMWM in managing and
administering clients’ accounts. These include software and other technology (and related technological
training) that provide access to client account data (such as trade confirmations and account statements),
facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide
research, pricing information and other market data, facilitate payment of the Firm's fees from its clients’
accounts, and assist with back-office training and support functions, recordkeeping, and client reporting.
Many of these services generally can be used to service all or some substantial number of the Firm’s
accounts, including accounts not maintained at Custodian. Custodian also makes available to DMWM other
services intended to help the Firm manage and further develop its business enterprise. These services can
include 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. In addition, Custodian may make available,
arrange and/or pay vendors for these types of services rendered to the Firm by independent third parties.
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 the Firm. While, as a fiduciary, DMWM
endeavors to act in its clients’ best interests, the Firm's recommendation that clients maintain their assets in
accounts at Custodian may be based in part on the benefits received and not solely on the nature, cost or
quality of custody and brokerage services provided by Custodian, which creates a potential conflict of
interest.
Brokerage for Client Referrals
DMWM does not consider, in selecting or recommending broker-dealers, whether the Firm receives client
referrals from the Financial Institutions or other third party.
Directed Brokerage
The client may direct DMWM in writing to use a particular Financial Institution to execute some or all
transactions for the client. In that case, the client will negotiate terms and arrangements for the account
with that Financial Institution and the Firm will not seek better execution services or prices from other
Financial Institutions or be able to “batch” client transactions for execution through other Financial
Institutions with orders for other accounts managed by DMWM (as described above). As a result, the client
can pay higher commissions or other transaction costs, greater spreads or can receive less favorable net
prices, on transactions for the account than would otherwise be the case. Subject to its duty of best
execution, DMWM can decline a client’s request to direct brokerage if, in the Firm’s sole discretion, such
directed brokerage arrangements would result in additional operational difficulties or violate restrictions
imposed by other broker-dealers (as further discussed below).
Trade Aggregation
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Transactions for each client will be affected independently, unless DMWM decides to purchase or sell the
same securities for several clients at approximately the same time. DMWM can (but is not obligated to)
combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates or
to allocate equitably among the Firm’s clients, differences in prices and commissions or other transaction
costs that might not have been obtained had such orders been placed independently. Under this procedure,
transactions will be averaged as to price and allocated among DMWM’s clients pro rata to the purchase and
sale orders placed for each client on any given day. To the extent that the Firm determines to aggregate
client orders for the purchase or sale of securities, including securities in which DMWM’s Supervised
Persons may invest, the Firm does so in accordance with applicable rules promulgated under the Advisers
Act and no-action guidance provided by the staff of the U.S. Securities and Exchange Commission. DMWM
does not receive any additional compensation or remuneration as a result of the aggregation.
In the event that the Firm determines that a prorated allocation is not appropriate under the particular
circumstances, the allocation will be made based upon other relevant factors, which include: (i) when only
a small percentage of the order is executed, shares can be allocated to the account with the smallest order
or 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; (ii) allocations can be given to one account when one
account has limitations in its investment guidelines which prohibit it from purchasing other securities which
are expected to produce similar investment results and can be purchased by other accounts; (iii) if an account
reaches an investment guideline limit and cannot participate in an allocation, shares can be reallocated to
other accounts (this may be due to unforeseen changes in an account’s assets after an order is placed); (iv)
with respect to sale allocations, allocations can be given to accounts low in cash; (v) in cases when a pro
rata allocation of a potential execution would result in a de minimis allocation in one or more accounts, the
Firm can exclude the account(s) from the allocation; the transactions can be executed on a pro rata basis
among the remaining accounts; or (vi) in cases where a small proportion of an order is executed in all
accounts, shares can be allocated to one or more accounts on a random basis.
Item 13. Review of Accounts
Account Reviews
DMWM monitors client portfolios on a continuous and ongoing basis and regular account reviews are
conducted on at least an annual basis. Such reviews are conducted by the Firm’s investment adviser
representatives. All investment advisory clients are encouraged to discuss their needs, goals and objectives
with DMWM and to keep the Firm informed of any changes thereto.
Account Statements and Reports
Clients are provided with transaction confirmation notices and regular summary account statements directly
from the Financial Institutions where their assets are custodied. From time-to-time or as otherwise
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requested, clients may also receive written or electronic reports from DMWM and/or an outside service
provider, which contain certain account and/or market-related information, such as an inventory of account
holdings or account performance. Clients should compare the account statements they receive from their
custodian with any documents or reports they receive from DMWM or an outside service provider.
Item 14. Client Referrals and Other Compensation
Client Referrals
In the event a client is introduced to DMWM by either an unaffiliated or an affiliated promoter, the Firm
can pay that promoter a referral fee in accordance with applicable state securities laws. Unless otherwise
disclosed, any such referral fee is paid solely from DMWM’s investment management fee and does not
result in any additional charge to the client. If the client is introduced to the Firm by an unaffiliated promoter,
the client will receive a promoter’s disclosure statement containing the terms and conditions of the referral
arrangement. Any affiliated promoter of DMWM is required to disclose the nature of his or her relationship
to prospective clients at the time of the referral and will provide all prospective clients with a copy of the
Firm’s written brochure(s) at the time of the referral. Our firm also participates in Dynasty Connect, a
referral program offered through Dynasty Wealth Management, LLC., an affiliate of Dynasty Financial
Partners, LLC.
Other Compensation
The Firm receives economic benefits from Custodian. The benefits, conflicts of interest and how they are
addressed are discussed above in response to Item 12.
Item 15. Custody
DMWM is deemed to have custody of client funds and securities because the Firm is given the ability to
debit client accounts for payment of the Firm’s fees. As such, client funds and securities are maintained at
one or more Financial Institutions that serve as the qualified custodian with respect to such assets. Such
qualified custodians will send account statements to clients at least once per calendar quarter that typically
detail any transactions in such account for the relevant period.
In addition, as discussed in Item 13, DMWM will also send, or otherwise make available, periodic
supplemental reports to clients. Clients should carefully review the statements sent directly by the Financial
Institutions and compare them to those received from DMWM. Any other custody disclosures can be found
in the Firm’s Form ADV Part 1.
Standing Letters of Authorization
DMWM also has custody due to clients giving the Firm limited power of attorney in a standing letter of
authorization (“SLOA”) to disburse funds to one or more third parties as specifically designated by the
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client. In such circumstances, the Firm will implement the steps in the SEC’s no-action letter on February
21, 2017 which includes (in summary): i) client will provide instruction for the SLOA to the custodian; ii)
client will authorize the Firm to direct transfers to the specific third party; iii) the custodian will perform
appropriate verification of the instruction and provide a transfer of funds notice to the client promptly after
each transfer; iv) the client will have the ability to terminate or change the instruction; v) the Firm will have
no authority or ability to designate or change the identity or any information about the third party; vi) the
Firm will keep records showing that the third party is not a related party of the Firm or located at the same
address as the Firm; and vii) the custodian will send the client an initial and annual notice confirming the
SLOA instructions.
Item 16. Investment Discretion
DMWM is given the authority to exercise discretion on behalf of clients. DMWM is considered to exercise
investment discretion over a client’s account if it can effect and/or direct transactions in client accounts
without first seeking their consent. DMWM is given this authority through a power-of-attorney included
in the agreement between DMWM and the client. Clients may request a limitation on this authority (such
as certain securities not to be bought or sold). DMWM takes discretion over the following activities:
• The securities to be purchased or sold;
• The amount of securities to be purchased or sold;
• When transactions are made; and
• The third-party managers to be hired or fired.
Item 17. Voting Client Securities
Declination of Proxy Voting Authority
DMWM does not accept the authority to vote a client’s securities (i.e., proxies) on their behalf. Clients
receive proxies directly from the Financial Institutions where their assets are custodied and may contact the
Firm at the contact information on the cover of this brochure with questions about any such issuer
solicitations.
Item 18. Financial Information
DMWM is not required to disclose any financial information listed in the instructions to Item 18 because:
• The Firm does not require or solicit the prepayment of more than $1,200 in fees six months or more
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in advance of services rendered;
• The Firm does not have a financial condition that is reasonably likely to impair its ability to meet
contractual commitments to clients; and
• The Firm has not been the subject of a bankruptcy petition at any time during the past ten years.
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