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Part 2A of Form ADV: Firm Brochure
Form ADV, Part 2A, Item 1
Cover Page
Discipline Wealth Solutions Inc.
15 Halton Green Way
Greenville, SC 29607
Tel: (864) 322-6046
Fax: (864) 322-6048
May 20, 2025
FORM ADV PART 2
FIRM BROCHURE
This brochure provides information about the qualifications and business practices of Discipline
Wealth Solutions Inc.. If you have any questions about the contents of this brochure, please
contact us at (864) 322-6046. 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 Discipline Wealth Solutions Inc. is also available on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Discipline Wealth
Solutions Inc. is 315846.
Discipline Wealth Solutions Inc. is a Registered Investment Adviser. Registration with the United
States Securities and Exchange Commission or any state securities authority does not imply a
certain level of skill or training.
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Form ADV, Part 2A, Item 2
Material Changes
Annual Update
The Material Changes section of this brochure will be updated annually or when material
changes occur since the previous release of the Firm Brochure. Each year, we will ensure that
you receive a summary of any material changes to this and subsequent brochures by April 30th.
We will further provide you with our most recent brochure at any time at your request, without
charge. You may request a brochure by contacting us at (864) 322-6046.
Material Changes since the Last Update
Discipline Wealth Solutions Inc. was established as a new Registered Investment Advisor in
August 2021 with the Securities and Exchange Commission (“SEC”), under the rules and
regulations of the US Investment Advisers Act of 1940, as amended (the "Advisers Act"). The
following material changes have been made since the last filing on February 10, 2025:
• None.
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Form ADV, Part 2A, Item 3
Table of Contents
Advisory Business…………………………………………………………… 4
Fees and Compensation…………………………………………………….. 6
Performance-Based Fees and Side-By-Side Management……………. 10
Types of Clients………………………………………………………………. 10
Methods of Analysis, Investment Strategies, and Risk of Loss……… 10
Disciplinary Information…………………………………………………….. 13
Other Financial Industry Activities and Affiliations……………………. 13
Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading………………………………………………………………
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Brokerage Practices………………………………………………………….. 14
Review of Accounts………………………………………………………….. 16
Client Referrals and Other Compensation……………………………….. 16
Custody………………………………………………………………………… 17
Investment Discretion……………………………………………………….. 17
Voting Client Securities……………………………………………………… 18
Financial Information………………………………………………………… 18
Requirements for State-Registered Advisers…………………………… 18
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Form ADV Part 2A, Item 4
Advisory Business
Discipline Wealth Solutions Inc. (hereinafter called “DWS”) is a Registered Investment Adviser
based in Greenville, South Carolina, and incorporated under the laws of the State of South
Carolina. DWS is wholly owned by James Bryan Keith Ballentine. DWS is registered with the
SEC and subject to the rules and regulations of the US Advisers Act. Founded in August 2021,
DWS provides investment advisory services, which may include, but are not limited to, the
review of client investment objectives and goals, recommending asset allocation strategies of
managed assets among investment products such as cash, stocks, mutual funds and bonds,
annuities, and/or preparing written investment strategies. Our investment advice is tailored to
meet our clients’ needs and investment objectives. Clients may impose restrictions on investing
in certain securities or types of securities (such as a product type, specific companies, specific
sectors, etc.) by providing a signed and dated written notification, of which an e-mail is also an
acceptable form of notification. DWS also provides consulting services as part of their asset
management including, but not limited to, risk assessment/management, investment planning,
estate planning, financial organization, or financial decision making/negotiation.
DWS provides investment advisory and other financial services through its Investment Advisory
Representatives ("IAR") to accounts opened with DWS. Managed Accounts are available to
individuals, high net worth individuals, corporations, other advisors and retirement plans.
DWS provides discretionary and non-discretionary investment advisory services to some of its
clients through various managed account programs. DWS will assist clients in determining the
suitability of the Managed Account Programs for the client. The IAR is compensated through a
comprehensive single fee and the account may be assessed other charges associated with
conducting a brokerage business. DWS and its IAR, as appropriate, will be responsible for the
following:
• Performing due diligence
• Recommending strategic asset and style allocations
• Providing research on investment product options, as needed
• Providing client risk profile questionnaire
• Obtaining investment advisory contract from client with required financial, risk tolerance,
suitability and investment vehicle selection information for each new account
• Performing client suitability check on account documentation, review the investment
objectives and evaluate the investment vehicle selections
• Providing Firm Brochure (this document)
DWS offers a cash management service for clients where the firm advises on placement of cash
and cash equivalents and negotiates the price for doing so. All such funds will be maintained at
qualified custodians (Charles Schwab or Axos).
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Financial Planning
In addition to investment supervisory services, DWS may provide Financial Planning Services to
some of its clients. DWS' Financial Planning services may include recommendations for
portfolio customization based on their client's investment objectives, goals, and financial
situation. The financial planning services may include but not be limited to: preparing an annual
net worth statement; creating a cash flow statement; reviewing client's current investments, most
recent tax returns, life and disability insurance, and/or estate plan and making recommendations
thereon; completing a retirement analysis; and providing education planning advice. These
services are based on fixed fees or hourly fees and the final fee structure.
DWS will tailor its advisory services to its client's individual needs based on meetings and
conversations with the client. If clients wish to impose certain restrictions on investing in certain
securities or types of securities, DWS will address those restrictions with the client to have a
clear understanding of the client's requirements.
Sub-Advisory Investment Management Services for Advisers
DWS offers investment sub-advisory services to unaffiliated registered investment advisers
(“RIA’s”). Unaffiliated RIAs may choose to engage DWS for investment management of some
or all of their clients' assets. DWS shall have day-to-day responsibility for the active
discretionary management of the allocated assets through a limited power of attorney from the
unaffiliated advisor's client. The unaffiliated adviser RIA shall continue to render investment
advisory services to the client relative to the ongoing monitoring and review of account
performance, asset allocation and client investment objectives. The unaffiliated RIA’s may
receive compensation for referring clients to DWS under a written solicitation agreement, as
required by applicable regulations.
Third-Party Asset Management Services
DWS offers clients the option of utilizing third-party asset managers for investment management
services. These unaffiliated money managers will be monitored for performance and are subject
to being replaced should DWS deem their performance or level of service fail to meet
expectations. DWS will bill for advisory services rendered by DWS and our advisers while the
third-party money managers will be responsible for their own billing.
Third-Party Asset Management Services
DWS offers clients the option of utilizing third-party asset managers for investment management
services. These unaffiliated money managers will be monitored for performance and are subject
to being replaced should DWS deem their performance or level of service fail to meet
expectations. DWS will bill for advisory services rendered by DWS and our advisers while the
third-party money managers will be responsible for their own billing.
Company-Sponsored Retirement Plan Consulting Services
Discipline Wealth Solutions offers retirement plan advisory services to defined contribution
retirement plans (the “Plan(s)”) and to the Plan’s named fiduciary (the “Plan Sponsor”). These
services may include either discretionary or nondiscretionary investment advice concerning the
retirement plan's investment options that are available to participants in the plan.
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Investment Manager 3(38) Fiduciary Services: The Adviser shall serve as an “Investment
Manager” and a “fiduciary” within the meaning of Section 3(38) of ERISA with respect to
accounts in the Plan. (As a Section 3(38) fiduciary, an “Investment Manager” has discretion,
authority and control of a plan’s assets. Under ERISA, a Plan Sponsor can delegate the job of
selecting, monitoring and replacing plan investments to the Investment Manager, but the Plan
Sponsor retains liability for the selection, monitoring and benchmarking of the Investment
Manager.)
If we are engaged as an Investment Manager, we will select the investment options that are to be
offered to the Plan's participants. We will also monitor the selected investment options and make
changes to them as necessary. In addition, we may aid with respect to the establishment and
maintenance of an investment policy statement for the Plan.
We shall be responsible for selecting the Qualified Default Investment Alternatives (“QDIA”)
for the Plan as permitted under Section 404(c) of ERISA in the form of an investment fund or
model portfolios that seek both long-term appreciation and capital preservation through a mix of
equity and fixed income investments.
Participant Services – In addition to providing plan-level advisory services, we may offer
participant-level education services and may also assist with participant enrollment meetings and
provide investment- related educational seminars to plan participants on such topics as
diversification, risk tolerance and time horizon. Our educational seminars may include other
investment-related topics specific to the plan.
We may also provide additional types of retirement plan advisory and consulting services to
Plans on an individually negotiated basis. All services, whether discussed above or customized
based upon a Plan Sponsor’s requirements, shall be detailed in a written agreement and be
consistent with the parameters set forth in the plan documents.
As of 12/31/2024, the firm has the following assets under management: Discretionary AUM:
$316,318,696 and Non-Discretionary: $0.
Form ADV, Part 2A, Item 5
Fees and Compensation
The following types of fees will be assessed:
Asset Management – Fees are charged monthly as negotiated in arrears or advance and are
based primarily on asset size and the level of complexity of the services provided. In individual
cases, DWS has the sole discretion to negotiate fees that are lower than the standard fee shown or
to waive fees. Fees are not based on the share of capital gains or capital appreciation of the
funds or any portion of the funds. Comparable services for lower fees may be available from
other sources. Fees for the initial month will be prorated based upon the number of calendar
days in the calendar month that the advisory agreement is in effect. Fees are based on the market
value of the assets on the last business day of the month. The maximum annual advisory fees
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would range from 1.32% to 1.65%, depending on the amount of assets under management
(“AUM”) with the adviser receiving 1.25% and DWS receiving a range from 0.07% to 0.40%,
depending on the amount of assets under management (“AUM”) – See chart below. Consulting
services are included in these fees for asset management services with the exception of unique
circumstances that may require a separate agreement for financial planning services (description
and fees are discussed below).
Fee Schedule for Asset Management:
Maximum Adviser’s Fee DWS Fee
Total Account Value
First $250,000 1.65% 0.40%
Next $250,000 1.55% 0.30%
Next $500,000
1.50% 0.25%
Next $1,000,000 1.40% 0.15%
Next $3,000,000 1.35% 0.10%
Above $5,000,000 1.32% 0.07%
As authorized in the client agreement, the account custodian withdraws Discipline Wealth
Solutions Inc.’s advisory fees directly from the clients’ accounts according to the custodian’s
policies, practices, and procedures. The custodial statement includes the amount of any fees paid
to DWS for advisory services. You should carefully review the statement from your
custodian/broker-dealer’s statement and verify the calculation of fees. Your custodian/broker-
dealer does not verify the accuracy of fee calculations.
Fees are charged in arrears or advance on a monthly basis, meaning that advisory fees for a
month are charged on the first day of the month. Clients may terminate investment advisory
services obtained from DWS, without penalty, upon written notice within five (5) business days
after entering into the advisory agreement with DWS. The client is responsible for any fees and
charges incurred by the client from third parties as a result of maintaining the account such as
transaction fees for any securities transactions executed and account maintenance or custodial
fees. Thereafter, the client may terminate advisory services upon written notice delivered to and
received by DWS. Clients who terminate investment advisory services during a month are
charged a prorated advisory fee based on the date of DWS’s receipt of client’s written notice to
terminate. Any earned but unpaid fees are immediately due and payable, and any prepaid and
unearned fees will be immediately refunded. In cases where a third-party money manager is
utilized, the custodian calculates and deducts the fees and places that amount in the DWS sundry
account where the third-party managers are paid from. DWS will then retain the fees that are
due to them from that arrangement.
The client may obtain a refund of a pre-paid fee if the advisory contract is terminated before the
end of the billing period by contacting James Bryan Keith Ballentine at (864) 322-6046. Upon
receipt of written notification, any earned fee will immediately become due and payable, and any
prepaid and unearned fees will be immediately refunded. A client may terminate an advisory
agreement without being assessed any fees or expenses within five (5) days of its signing.
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Financial Planning
Some clients will contract to have financial planning advice provided based on an hourly fee.
DWS’ hourly fee will be billed at a rate ranging from $125 to $500 based on the complexity and
skill level/experience needed for each client. Hourly fees are invoiced monthly in arrears as
services are provided. The fees are negotiable. Clients may terminate their contracts without
penalty within five business days of signing the advisory contract.
DWS will charge a fixed fee for comprehensive financial planning services of up to $30,000 per
plan based on the complexity of the case (e.g., net worth, income, needs of client, asset level,
family complexity and other issues) as contracted for with client. Fixed fees may be negotiated in
advance at the discretion of DWS. Clients may terminate their contracts without penalty within
five business days of signing the advisory contract. Fixed fee-based clients are either billed
monthly in arrears as services are provided or as a one-time fixed fee upfront and/or upon
delivery of services. Those paid upfront will be completed/delivered within six months.
Cash Management
DWS offers a cash management service which is charged at a fixed rate. The rate will not exceed
0.50% per annum. The accounts will be charged the flat fee separately from the above tiered
schedule, in arrears on a monthly, quarterly, or annual basis.
Company-Sponsored Retirement Plan Consulting Services – Fees are charged quarterly as
negotiated in arrears or advanced depending on client preference and are based primarily on asset
size and the level of complexity of the services provided. In individual cases, DWS has the sole
discretion to negotiate fees that are lower than the standard fee shown or to waive fees. Fees are
not based on the share of capital gains or capital appreciation of the funds or any portion of the
funds. Comparable services for lower fees may be available from other sources. Fees for the
initial quarter will be prorated based upon the number of calendar days in the calendar quarter
that the advisory agreement is in effect. Fees are based on the market value of the assets on the
last business day of the quarter. The maximum annual advisory fees would range from 1.10% to
1.30%, depending on the amount of assets under management (“AUM”) with the adviser
receiving 1.00% and DWS receiving a range from 0.10% to 0.30% – See chart below.
Consulting services are included in these fees for asset management services.
Fee Schedule for Retirement Plan Asset Management:
Maximum Adviser’s Fee DWS Fee
Total Account Value
First $500,000 1.30% 0.30%
Next $500,000 1.25% 0.25%
Next $1,500,000
1.20% 0.20%
Next $2,500,000 1.15% 0.15%
Above $5,000,000 1.10% 0.10%
As authorized in the client agreement, the account custodian withdraws Discipline Wealth
Solutions Inc.’s advisory fees directly from the clients’ accounts according to the custodian’s
policies, practices, and procedures. The custodial statement includes the amount of any fees paid
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to DWS for advisory services. You should carefully review the statement from your
custodian/broker-dealer’s statement and verify the calculation of fees. Your custodian/broker-
dealer does not verify the accuracy of fee calculations.
Fees are charged in arrears on a quarterly basis, meaning that advisory fees for a quarter are
charged on the first day of the following quarter. Clients may terminate investment advisory
services obtained from DWS, without penalty, upon written notice within five (5) business days
after entering into the advisory agreement with DWS. The client is responsible for any fees and
charges incurred by the client from third parties as a result of maintaining the account such as
transaction fees for any securities transactions executed and account maintenance or custodial
fees. Thereafter, the client may terminate advisory services upon written notice delivered to and
received by DWS. Clients who terminate investment advisory services during a quarter are
charged a prorated advisory fee based on the date of DWS’s receipt of client’s written notice to
terminate. Any earned but unpaid fees are immediately due and payable, and any prepaid and
unearned fees will be immediately refunded.
The client may obtain a refund of a pre-paid fee if the advisory contract is terminated before the
end of the billing period by contacting James Bryan Keith Ballentine at (864) 322-6046. Upon
receipt of written notification, any earned fee will immediately become due and payable, and any
prepaid and unearned fees will be immediately refunded. A client may terminate an advisory
agreement without being assessed any fees or expenses within five (5) days of its signing.
Additional Fees and Expenses
In addition to advisory fees paid to DWS as explained above, clients may pay custodial service,
account maintenance, transaction, and other fees associated with maintaining the account. These
fees vary by broker and/or custodian. Clients should ask DWS for details on transaction fees or
other custodial fees specific to their account, as these fees are not included in the annual advisory
fee. DWS does not share any portion of such fees. Additionally, for any mutual funds
purchased, the client may pay their proportionate share of the funds’ distribution, internal
management, investment advisory and administrative fees. Such fees are not shared with DWS
and are compensation to the fund manager. Clients are urged to read the mutual fund prospectus
prior to investing.
Mutual fund companies impose internal fees and expenses on clients. These fees are in addition
to the costs associated with the investment advisory services as described above. Complete
details of such internal expenses are specified and disclosed in each mutual fund company’s
prospectus. Clients are strongly advised to review the prospectus(es) prior to investing in such
securities.
Mutual funds purchased or sold in broker-dealer accounts may generate transaction fees that
would not exist if the purchase or sale were made directly with the mutual fund company.
Mutual funds held in broker-dealer accounts also charge management fees. These mutual fund
management fees may be more or less than the mutual fund management fees charged if the
client held the mutual fund directly with the mutual fund company.
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Clients may purchase shares of mutual funds directly from the mutual fund issuer, its principal
underwriter, or a distributor without purchasing the services of DWS or paying the advisory fee
on such shares (but subject to any applicable sales charges). Certain mutual funds are offered to
the public without a sales charge. In the case of mutual funds offered with a sales charge, the
prevailing sales charge (as described in the mutual fund prospectus) may be more or less than the
applicable advisory fee. However, clients would not receive DWS’s assistance in developing an
investment strategy, selecting securities, monitoring performance of the account, and making
changes as necessary.
Please refer to Item 12 “Brokerage Practices” of this brochure for additional information.
Form ADV, Part 2A, Item 6
Performance-Based Fees and Side-By-Side Management
Discipline Wealth Solutions Inc. does not charge performance-based fees or participate in side-
by-side management. Side-by-side management refers to the practice of managing accounts that
are charged performance-based fees while at the same time managing accounts that are not
charged performance-based fees. Performance-based fees are fees that are based on a share of
capital gains or appreciation of the assets of a client. Our fees are calculated as described in Fees
and Compensation section above and are not charged on the basis of performance of your
advisory account.
Form ADV, Part 2A, Item 7
Types of Clients
DWS offers investment advisory services to individuals, high net worth individuals,
corporations, other advisors and retirement plans. There is no minimum account size to open
and maintain an advisory account.
Form ADV, Part 2A, Item 8
Methods of Analysis, Investment Strategies, and Risk of Loss
DWS’s methods of analysis and investment strategies incorporate the client’s needs and
investment objectives, time horizon, and risk tolerance. DWS is not bound to a specific
investment strategy for the management of investment portfolios, but rather consider the risk
tolerance levels pre-determined gathered at the account opening, as well as on an on-going basis.
Examples of methodologies that our investment strategies may incorporate include:
Asset Allocation – Asset Allocation is a broad term used to define the process of selecting a mix
of asset classes and the efficient allocation of capital to those assets by matching rates of return
to a specified and quantifiable tolerance for risk.
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Dollar-Cost Averaging – Dollar-cost averaging is the technique of buying a fixed dollar amount
of securities at regularly scheduled intervals, regardless of the price per share. This will
gradually, over time, decrease the average share price of the security. Dollar-cost averaging
lessens the risk of investing a large amount in a single investment at the wrong time.
Technical Analysis – involves studying past price patterns and trends in the financial markets to
predict the direction of both the overall market and specific stocks.
Long-Term Purchases – securities purchased with the expectation that the value of those
securities will grow over a relatively long period of time, generally greater than one year.
Short-Term Purchases – securities purchased with the expectation that they will be sold within a
relatively short period of time, generally less than one year, to take advantage of the securities’
short term price fluctuations.
Our strategies and investments may have unique and significant tax implications. Regardless of
your account size or other factors, we strongly recommend that you continuously consult with a
tax professional prior to and throughout the investing of your assets.
Investing in securities involves risk of loss that clients should be prepared to bear. Although we
manage your portfolio with strategies and in a manner consistent with your risk tolerances, there
can be no guarantee that our efforts will be successful. You should be prepared to bear the risk
of loss.
All investments involve the risk of loss, including (among other things) loss of principal, a
reduction in earnings (including interest, dividends, and other distributions), and the loss of
future earnings. These risks include market risk, interest rate risk, issuer risk, and general
economic risk. Regardless of the methods of analysis or strategies suggested for your particular
investment goals, you should carefully consider these risks, as they all bear risks.
DWS’s primary goal for investing is to help the client maintain purchasing power over the long
term. This may result in short term variability and loss of principal. Time horizon and risk
tolerance are key determinates of the proper asset allocation. DWS’s approach focuses on taking
appropriate risks for which clients are compensated (i.e. market risk) and seeking to limit or
eliminate risks that do not provide compensation over the long term (i.e. individual stock risk or
lack of portfolio risk).
Below are some more specific risks of investing:
Market Risk. The prices of securities in which clients invest may decline in response to certain
events taking place around the world, including those directly involving the companies whose
securities are owned by the client or an underlying fund; conditions affecting the general
economy; overall market changes; local, regional or global political, social or economic
instability; and currency, interest rate and commodity price fluctuations. Investors should have a
long-term perspective and be able to tolerate potentially sharp declines in market value.
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Management Risk. DWS’s investment approach may fail to produce the intended results. If our
perception of the performance of a specific asset class or underlying fund is not realized in the
expected time frame, the overall performance of client’s portfolio may suffer.
Equity Risk. Equity securities tend to be more volatile than other investment choices. The value
of an individual mutual fund or ETF can be more volatile than the market as a whole. This
volatility affects the value of the client’s overall portfolio. Small- and mid-cap companies are
subject to additional risks. Smaller companies may experience greater volatility, higher failure
rates, more limited markets, product lines, financial resources, and less management experience
than larger companies. Smaller companies may also have a lower trading volume, which may
disproportionately affect their market price, tending to make them fall more in response to
selling pressure than is the case with larger companies.
Fixed Income Risk. The issuer of a fixed income security may not be able to make interest and
principal payments when due. Generally, the lower the credit rating of a security, the greater the
risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower
rating, the value of the debt security will decline because investors will demand a higher rate of
return. As nominal interest rates rise, the value of fixed income securities is likely to decrease. A
nominal interest rate is the sum of a real interest rate and an expected inflation rate.
Municipal Securities Risk. The value of municipal obligations can fluctuate over time, and may
be affected by adverse political, legislative and tax changes, as well as by financial developments
that affect the municipal issuers. Because many municipal obligations are issued to finance
similar projects by municipalities (e.g., housing, healthcare, water and sewer projects, etc.),
conditions in the sector related to the project can affect the overall municipal market. Payment
of municipal obligations may depend on an issuer’s general unrestricted revenues, revenue
generated by a specific project, the operator of the project, or government appropriation or aid.
There is a greater risk if investors can look only to the revenue generated by the project. In
addition, municipal bonds generally are traded in the “over-the-counter” market among dealers
and other large institutional investors. From time to time, liquidity in the municipal bond market
(the ability to buy and sell bonds readily) may be reduced in response to overall economic
conditions and credit tightening.
Investment Companies Risk. When a client invests in open end mutual funds or ETFs, the
client indirectly bears its proportionate share of any fees and expenses payable directly by those
funds. Therefore, the client will incur higher expenses, many of which may be duplicative. In
addition, the client’s overall portfolio may be affected by losses of an underlying fund and the
level of risk arising from the investment practices of an underlying fund (such as the use of
derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a
market price that is above or below their net asset value; (ii) the ETF may employ an investment
strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the
listing exchange’s officials deem such action appropriate, the shares are de-listed from the
exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases
in stock prices) halts stock trading generally. DWS has no control over the risks taken by the
underlying funds.
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Form ADV, Part 2A, Item 9
Disciplinary Information
Discipline Wealth Solutions Inc. or its Principal Executive Officers have not had any reportable
disclosable events in the past ten years.
Form ADV, Part 2A, Item 10
Other Financial Industry Activities and Affiliations
James Bryan Keith Ballentine, owner of DWS, is not currently registered with any broker dealer.
James Bryan Keith Ballentine, the sole owner of DWS, is also the principal owner and Managing
Partner of BCA Private Wealth, Inc. (“BCA”), a registered investment adviser.
The relationship between DWS and BCA may create a conflict of interest, because DWS may be
incentivized to recommend investments in order to generate management fees for itself and for
BCA, its related entity. However, to help mitigate against this conflict of interest, DWS’s
recommendations to invest are non-discretionary (i.e., DWS clients make their own decision
where to invest and, if so, will complete documentation materials for the same). In addition,
clients of Discipline Wealth Solutions will not pay fees to BCA for assets invested at DWS.
Neither DWS nor its representatives are registered as a Futures Commission Merchant,
Commodity Pool Operator, or a Commodity Trading Advisor.
Representatives of the firm may also be a licensed agent. From time to time, he will offer
clients advice or products from those activities. Clients should be aware that these services pay a
commission and involve a possible conflict of interest, as commissionable products can conflict
with the fiduciary duties of a registered investment adviser. DWS always acts in the best interest
of the client; including the sale of commissionable products to advisory clients. Clients are in no
way required to implement the plan through any representative of DWS in their capacity as an
insurance agent
Mr. Colancecco, an executive officer of BCA, serves on the Axos Advisor Services advisor panel.
The panel is to provide Axos with enhancements for advisors and end clients.
Form ADV, Part 2A, Item 11
Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
DWS’s Code of Ethics includes guidelines for professional standards of conduct for our
Associated Persons. Our goal is to protect client interests at all times and to demonstrate our
commitment to fiduciary duties of honesty, good faith, and fair dealing. All of DWS’s
Associated Persons are expected to strictly adhere to these guidelines. Persons associated with
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Discipline Wealth Solutions Inc. are also required to report any violations to the Code of Ethics.
Additionally, the firm maintains and enforces written policies reasonably designed to prevent the
misuse or dissemination of material, non-public information about our clients or client accounts
by persons associated with our firm.
DWS and its employees may buy or sell securities that are also held by clients. It is the
expressed policy of the advisor that no person employed by our firm purchase or sell any security
prior to the transaction being implemented for an advisory account; therefore, preventing such
employees from benefiting from transactions placed on behalf of the advisory clients.
The advisor does not have, nor plans to have, an interest or position in a security which is then
also recommended to the client. As these situations may present a conflict of interest, the
advisor has established the following restrictions in order to ensure its fiduciary responsibilities
should this issue ever arise:
1. A director, officer or employee of the advisor shall not buy or sell a security for their
personal portfolio(s) where their decision is substantially derived, in whole or part, by
reason of his or her employment, unless the information is also available to the investing
public. No owner/employee of DWS shall prefer their own interest to that of the client.
2. The advisor maintains a list of all securities held by the company and all directors, officers,
and employees. These holdings are reviewed on a quarterly basis by the principal of the
firm.
3. The advisor requires that all employees must act in accordance with all applicable Federal
and State regulations governing registered investment advisors.
4. The advisor may block personal trades with those of clients but will ensure that clients are
not at a disadvantage.
DWS’s Code of Ethics is available to you upon request. You may obtain a copy of our Code of
Ethics by contacting James Bryan Keith Ballentine at (864) 322-6046.
Form ADV, Part 2A, Item 12
Brokerage Practices
DWS offers a clearing platform to execute securities business for investment advisory services
through Charles Schwab & Co., Inc. (“Schwab”), or Axos Advisory Services (“Axos”), both
members of FINRA/SIPC. In order for DWS to provide asset management services, we request
you utilize the brokerage and custodial services of Schwab or Axos. Schwab and Axos are
independent SEC-registered broker dealers and are separate and unaffiliated with DWS. Schwab
and Axos offer services to independently registered investment advisors which include custody
of securities, trade execution and clearance and settlement of transactions.
DWS evaluates broker dealer/custodians based on our projected AUM and the best fit for our
business model. In considering which independent qualified custodians would be the best fit for
DWS’s business model, we evaluate the following factors, which is not an all-inclusive list:
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➢ Financial strength
➢ Reputation
➢ Reporting capabilities
➢ Execution capabilities
➢ Pricing, and
➢ Types and quality of research
A detailed description, list of services, and additional disclosures will be made during the
revision of this brochure once an arrangement is finalized.
While you are free to choose any broker-dealer or other service provider, we recommend that
you establish an account with a brokerage firm with which we have an existing relationship.
Such relationships may include benefits provided to our firm, including, but not limited to
research, market information, and administrative services that help our firm manage your
account(s). We believe that recommended broker-dealers provide quality execution services for
our clients at competitive prices. Price is not the sole factor we consider in evaluating best
execution. We also consider the quality of the brokerage services provided by the recommended
broker-dealers, including the value of research provided, the firm’s reputation, execution
capabilities, commission rates, and responsiveness to our clients and our firm.
You may direct us in writing to use a particular broker-dealer to execute some or all of the
transactions for your account. If you do so, you are responsible for negotiating the terms and
arrangements for the account with that broker-dealer. We may not be able to negotiate
commissions, obtain volume discounts, or best execution. In addition, under these circumstances
a difference in commission charges may exist between the commissions charged to clients who
direct us to use a particular broker or dealer and other clients who do not direct us to use a
particular broker or dealer.
DWS does not receive client referrals from broker-dealers in exchange for cash or other
compensation, such as brokerage services or research.
DWS does not have any formal soft dollar arrangements.
When DWS buys or sells the same security for two or more clients (including our personal
accounts), we may place concurrent orders to be executed together as a single “block” in order to
facilitate orderly and efficient execution. Each client account will be charged or credited with
the average price per unit. We receive no additional compensation or remuneration of any kind
because we aggregate client transactions. No client is favored over any other client. If an order
is not completely filled, it is allocated pro-rata based on an allocation statement prepared by
DWS prior to placing the order. Because of an order’s aggregation, some clients may pay higher
transaction costs, or greater spreads, or receive less favorable net prices on transactions than
would otherwise be the case if the order had not been aggregated.
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Form ADV, Part 2A, Item 13
Review of Accounts
Client accounts are reviewed at least quarterly by Anthony Colancecco, Principal Executive
Officer of the firm. Anthony Colancecco reviews clients’ accounts with regards to their
investment policies and risk tolerance levels. All accounts at DWS are assigned to this reviewer.
All financial planning accounts are reviewed upon financial plan creation and plan delivery by
James Bryan Keith Ballentine, Principal Executive Officer of the firm. There is only one level of
review and that is the total review conducted to create the financial plan.
Reviews may be triggered by material market, economic or political events, or by changes in
client's financial situations (such as retirement, termination of employment, physical move, or
inheritance).
Each client will receive at least quarterly a written report that details the clients’ account which
may come from the custodian. Clients are encouraged to review these statements to verify
accuracy and calculation correctness.
Clients are provided a one-time financial plan concerning their financial situation. After the
presentation of the plan, there are no further reports. Clients may request additional plans or
reports for a fee.
Form ADV, Part 2A, Item 14
Client Referrals and Other Compensation
DWS does not receive compensation for referring clients to other professional service providers.
DWS may enter into “Promoter/Finder” relationships. These promoters refer prospective clients
to DWS. DWS pays a referral fee to the promoter or finder typically based on a portion of the
management fees charged by DWS and memorialized in a written agreement (“Promoter
Agreement”). In all cases, DWS will comply with the cash solicitation rules established by the
SEC, state regulators and the client disclosure requirements. If a referred prospective client
enters into an investment advisory agreement with DWS, a referral fee is paid to the referring
party. The referral relationship will not result in clients being charged any fees over and above
the normal advisory fees charged for the advisory services provided. DWS will pay the
promoter/finder their share of the total fee. The Promoter Agreement requires that the
promoter/finder be appropriately registered under federal and state securities laws where
applicable. Clients receive all related agreements and disclosures prior to or at the time of
entering into an Investment Advisory Agreement with DWS.
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Form ADV, Part 2A, Item 15
Custody
DWS does not have physical custody of any client funds and/or securities and does not take
custody of client accounts at any time. Client funds and securities will be held with a bank,
broker dealer, or other independent qualified custodian. However, by granting DWS written
authorization to automatically deduct fees from client accounts, DWS is deemed to have limited
custody. You will receive account statements from the independent, qualified custodian holding
your funds at least quarterly. The account statement from your custodian will indicate the
amount of advisory fees deducted from your account(s) each billing cycle. Clients should
carefully review statements received from the custodian.
Some clients may execute limited powers of attorney or other standing letters of authorization
that permit the firm to transfer money from their account with the client’s independent qualified
custodian to third-parties. This authorization to direct the custodian may be deemed to cause our
firm to exercise limited custody over your funds or securities and for regulatory reporting
purposes, we are required to keep track of the number of clients and accounts for which we may
have this ability. We do not have physical custody of any of your funds and/or securities. Your
funds and securities will be held with a bank, broker-dealer, or other independent, qualified
custodian. You will receive account statements from the independent, qualified custodian(s)
holding your funds and securities at least quarterly. The account statements from your
custodian(s) will indicate any transfers that may have taken place within your account(s) each
billing period. You should carefully review account statements for accuracy.
Form ADV, Part 2A, Item 16
Investment Discretion
Before DWS can buy or sell securities on your behalf, you must first sign our discretionary
management agreement, a limited power of attorney, and/or trading authorization forms. By
choosing to do so, you may grant the firm discretion over the selection and amount of securities
to be purchased or sold for your account(s) without obtaining your consent or approval prior to
each transaction. Clients may impose limitations on discretionary authority for investing in
certain securities or types of securities (such as a product type, specific companies, specific
sectors, etc.), as well as other limitations as expressed by the client. Limitations on discretionary
authority are required to be provided to the IAR in writing. Please refer to the “Advisory
Business” section of this Brochure for more information on our discretionary management
services.
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Form ADV, Part 2A, Item 17
Voting Client Securities
We do not vote proxies on behalf of your advisory accounts. At your request, we may offer you
advice regarding corporate actions and the exercise of your proxy voting rights. If you own
shares of common stock or mutual funds, you are responsible for exercising your right to vote as
a shareholder.
In most cases, you will receive proxy materials directly from the account custodian. However, in
the event we were to receive any written or electronic proxy materials, we would forward them
directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in
which case, we would forward any electronic solicitation to vote proxies.
Form ADV, Part 2A, Item 18
Financial Information
DWS is not required to provide financial information to our clients because we do not require or
solicit the prepayment of more than $1,200 six or more months in advance.
Form ADV, Part 2A, Item 19
Requirements for State-Registered Advisers
This section is not applicable as DWS is SEC registered and not state registered.
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