Overview
- Headquarters
- Surprise, AZ
- Total Firm Assets
- $193 million
- Average High-Net-Worth Client Portfolio Size
- $2.5 million
- Minimum Account Size
- $250,000
Fee Structure
Primary Fee Schedule (DYNAMIC WEALTH ADVISORS FORM ADV PART 2A FIRM BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $250,000 | 2.00% |
| $250,001 | $500,000 | 1.75% |
| $500,001 | $750,000 | 1.50% |
| $750,001 | $1,000,000 | 1.25% |
| $1,000,001 | $3,000,000 | 1.00% |
| $3,000,001 | and above | 0.75% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $16,250 | 1.62% |
| $5 million | $51,250 | 1.02% |
| $10 million | $88,750 | 0.89% |
| $50 million | $388,750 | 0.78% |
| $100 million | $763,750 | 0.76% |
Clients
- High-Net-Worth Share of Firm Assets
- 63.44%
- Number of High-Net-Worth Clients
- 49
- Total Client Accounts
- 792
- Discretionary Accounts
- 792
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting
Regulatory Filings
- SEC CRD Number
- 169792
Primary Brochure: DYNAMIC WEALTH ADVISORS FORM ADV PART 2A FIRM BROCHURE (2026-08-26)
View Document Text
Item 1: Cover Page
Part 2A of Form ADV: Firm Brochure
August 2026
14749 W. Mountain View Blvd., Suite 144,
Surprise, AZ 85374
623-466-6060
www.DynamicWealthMgt.com
Firm Contact:
Adam Carlini
Chief Compliance Officer
This brochure provides information about the qualifications and business practices of Dynamic
Wealth Advisors, Inc. (“Dynamic Wealth Advisors” or “DWA”). If clients have any questions about the
contents of this brochure, please contact us at 623-466-6060. The information in this brochure has
not been approved or verified by the United States Securities and Exchange Commission or by any
State Securities Authority. Additional information about our firm is also available on the SEC’s
website at www.adviserinfo.sec.gov by searching CRD #169792.
Please note that the use of the term “registered investment adviser” and description of our firm
and/or our associates as “registered” does not imply a certain level of skill or training. Clients are
encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise
clients for more information on the qualifications of our firm and our employees.
Item 2: Material Changes
Dynamic Wealth Advisors is required to notify clients of any information that has changed since the
last annual update of the Firm Brochure (“Brochure”) that may be important to them. Clients can
request a full copy of our Brochure or contact us with any questions that they may have about the
changes.
Since our last annual amendment filed on 06/30/2025, we do not have any material change(s) to
report.
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Dynamic Wealth Advisors
Item 3: Table of Contents
Item 1: Cover Page .................................................................................................................................................................. 1
Item 2: Material Changes ...................................................................................................................................................... 2
Item 3: Table of Contents ..................................................................................................................................................... 3
Item 4: Advisory Business.................................................................................................................................................... 4
Item 5: Fees & Compensation ............................................................................................................................................. 6
Item 6: Performance-Based Fees & Side-By-Side Management ........................................................................... 8
Item 7: Types of Clients & Account Requirements .................................................................................................... 8
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ................................................................... 8
Item 9: Disciplinary Information .................................................................................................................................... 10
Item 10: Other Financial Industry Activities & Affiliations .................................................................................. 10
Item 11: Code of Ethics, Participation or Interest in ............................................................................................... 11
Item 12: Brokerage Practices ........................................................................................................................................... 11
Item 13: Review of Accounts or Financial Plans ....................................................................................................... 14
Item 14: Client Referrals & Other Compensation ..................................................................................................... 14
Item 15: Custody .................................................................................................................................................................... 15
Item 16: Investment Discretion ....................................................................................................................................... 16
Item 17: Voting Client Securities ..................................................................................................................................... 16
Item 18: Financial Information ........................................................................................................................................ 16
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Dynamic Wealth Advisors
Item 4: Advisory Business
Dynamic Wealth Advisors (“DWA”) is a fee-based investment advisor specializing in dynamic (pro-
active and adaptive) investment management. We are risk managers and strategists. Our approach
is a holistic one involving a thorough review of each client’s goals, resources and comfort with risk
before making investment recommendations. DWA offers a wide range of investment advisory
services including financial planning, investment advice and asset management for consideration
(fees) based on a percentage of assets under management. As fiduciaries, we place our clients’
interests above our own and are committed to helping our clients preserve, manage and grow their
assets in a prudent manner and in accordance with their stated financial goals.
Each client has his or her own unique account(s). Assets are held at independent custodians and are
titled in each client’s individual name and are not commingled with any other client and are NOT held
in the name of DWA.
DWA is a corporation formed under the laws of the State of Arizona founded in 2012 and has been in
business as an investment adviser since 2013. DWA is wholly owned by Adam Carlini. Mr. Carlini is
also the Chief Investment Officer and President of DWA.
The purpose of this Brochure is to disclose the conflicts of interest associated with the investment
transactions, compensation and any other matters related to investment decisions made by DWA or
its representatives. As a fiduciary, it is DWA’s duty to always act in the client’s best interest. This is
accomplished in part by knowing our client.
DWA makes its services available through independent financial professionals, individuals who are
investment advisor representatives (“IAR” or may also be referred to in this document as simply
“Advisor”) and who may also be licensed as securities registered representatives. Each IAR should
provide his or her advisory clients with details of his or her background in a 2B Brochure Supplement,
which should be included herein. If you have not received such 2B Brochure Supplement, please
contact your advisor or DWA.
Types of Advisory Services Offered
Investment Management & Supervision Services:
DWA offers discretionary management for a fee, based on a percentage of the assets managed. Services
include ongoing monitoring of the account, selection of securities and execution of trades consistent with
the client’s Investment Objective as declared in the Advisory Agreement and consistent with the
Investment Policy Statement (“IPS”). Investment recommendations will be based on the IPS, which will
be established based on each client’s goals, risk tolerance, time horizon, liquidity needs and tax
considerations. Clients may have multiple accounts that are managed differently from one another for
the purpose of diversification of investment style, maximization of tax benefits or to meet other stated
goals.
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Dynamic Wealth Advisors
There is no guarantee that the recommendations or trades will meet a client’s investment objective over
any given timeframe. Past performance is not a guarantee of future results. While we seek to produce
consistent returns in all market environments, investment performance will vary and there is the
potential for capital losses in your account.
DWA will rely on information provided by the client or third party statements provided by the client and
is not under obligation to verify this information. The client is responsible to notify DWA of any material
change in their goals or circumstances so that appropriate changes may be made regarding the
management of their account(s).
Advisor will deliver to the client or confirm that the custodian will deliver to the client, performance
reports on at least an annual basis.
The custodian will provide account statements directly to the client. DWA encourages the client to
promptly review all such account statement information for accuracy and report any discrepancies.
DWA will not have custody of client accounts, but will have limited authority through the Advisory
Agreement to direct the custodian to deduct investment advisory fees. Fees will not be deducted more
than 90 days in advance. For tax planning purposes, client may authorize and direct DWA to pay fees for
one managed account from another managed account.
We do not currently provide investment advice on Forex, Futures, or Commodities Contracts.
Retirement Plan Consulting:
DWA advisors may provide retirement plan consulting by assisting clients in establishing new or
converting existing retirement plan accounts and/or offering allocation recommendations for
existing plans not administered by DWA. Such services are only offered under an Advisory
Agreement or Retirement Plan Advisory Agreement.
Tailoring of Advisory Services
Our firm offers individualized investment advice to our Investment Management clients. General
investment advice will be offered to our Retirement Plan Consulting clients.
Each Investment Management client has the opportunity to place reasonable restrictions on the types
of investments to be held in the portfolio. Restrictions on investments in certain securities or types of
securities may not be possible due to the level of difficulty this would entail in managing the account.
Participation in Wrap Fee Programs
Our firm does not offer or sponsor a wrap fee program.
Regulatory Assets Under Management
Our firm manages $193,346,000 on a discretionary basis as of March 31st, 2026.
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Item 5: Fees & Compensation
Compensation for Our Advisory Services
Investment Management Services:
DWA charges a fee for providing Investment Management services. These services include
investment consulting, portfolio design, monitoring, trade execution, allocation, investment
supervision and other account management activities. The Investment Management, Portfolio
Monitoring & Consulting Services fees are calculated and payable quarterly in advance, based on the
portfolio value as of the last business day of the prior quarter as reported by the custodian. Fees are
assessed on all assets under management, including securities, cash and money market funds. When
accounts are first established, the initial fee will be prorated based on the days remaining before the
end of the calendar quarter and the fee will begin when funds arrive in the account. Initially, there
may be multiple days of funds arriving in the account and thus multiple pro- rations for each amount
and time period until the end of the calendar quarter.
All accounts managed by DWA for a single household may be aggregated to arrive at a lower overall
rate to be charged on each of the individual accounts managed for the household. This figure will be
reviewed annually for purposes of determining the overall rate to be charged. DWA reserves the right
to review the aggregate value more frequently and on a case-by-case basis as an incentive for clients
to bring more money under DWA management and thus reach a breakpoint. The table below
illustrates the various maximum rates that would apply and breakpoints where fees are reduced.
Fees are negotiable and may be lower than the standard schedule depending upon services provided
by Advisor. Clients will be subject to the fee schedule disclosed in their signed Investment
Management Advisory Agreement. Services are offered through the Investment Management
Advisory Agreement.
Investment Management, Portfolio Monitoring & Consulting Services Fees Standard Fee Schedule:
Portfolio Assets Valued At
First $250,000
Next $250,000 (up to $500,000)
Next $250,000 (up to $750,000)
Next $250,000 (up to $1 million)
Next $2 million (up to $3 million)
Amounts above $3 million
Annualized Fee
2.00%
1.75%
1.50%
1.25%
1.00%
0.75%
Fees will be deducted from client account(s). In rare cases, our firm will agree to directly invoice. As
part of this process, Clients understand the following:
a) The client’s independent custodian sends statements at least quarterly showing the market
values for each security included in the Assets and all account disbursements, including the
amount of the advisory fees paid to our firm;
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Dynamic Wealth Advisors
b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our
firm will send an invoice directly to the custodian; and
c) If our firm sends a copy of our invoice to the client, a legend urging the comparison of
information provided in our statement with those from the qualified custodian will be
included.
Retirement Plan Consulting:
Retirement Plan consulting fees are negotiable depending upon the services offered by Advisor. Fees
are payable as described in the Advisory Agreement. Our Retirement Plan Consulting services are
billed on an hourly or flat fee basis or a fee based on the percentage of Plan assets under management.
The total estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of
our engagement with the client. The maximum hourly fee to be charged will not exceed $250. Our flat
fees range from $750 to $10,000. Fees based on a percentage of managed Plan assets will not exceed
1.00%. The fee-paying arrangements will be determined on a case-by-case basis and will be detailed
in the signed consulting agreement.
Other Types of Fees & Expenses
The custodian may charge custodial fees, redemption fees, retirement plan fees and other
administrative fees. Additionally, the custodian may charge ticket charges/commissions for trade
executions. These amounts vary by custodian. Our recommended custodian, Charles Schwab & Co.,
Inc. (“Schwab”), does not charge transaction fees for U.S. listed equities and exchange traded funds.
DWA does not share in these fees and has sought to minimize them by using multiple custodians. For
certain types of investment strategies, the platform of one custodian may result in lower expenses
than another and thus provide a cost savings to the client. The custodian will provide statements at
least on a quarterly basis that show account value and activity including any custodial fees and any
advisory fees charged.
Clients may also pay holdings charges imposed by the chosen custodian for certain investments,
charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be
disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), distribution
fees, surrender charges, variable annuity fees, IRA and qualified retirement plan fees, mark-ups and
mark-downs, spreads paid to market makers, fees for trades executed away from custodian, wire
transfer fees and other fees and taxes on brokerage accounts and securities transactions. Our firm
does not receive a portion of these fees.
Termination & Refunds
With written notice either the client or DWA may terminate these contracts at any time. The client
would then receive a full pro-rata refund of unearned fees. Upon termination, we will have no further
obligation, nor responsibility to act or to manage the corresponding account(s), and you will be
responsible for monitoring and managing the account(s).
Either party to a Retirement Plan Consulting Agreement may terminate at any time by providing
written notice to the other party. Full refunds will only be made in cases where cancellation occurs
within 5 business days of signing an agreement. After 5 business days from initial signing, either
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Dynamic Wealth Advisors
party must provide the other party 30 days written notice to terminate billing. Billing will terminate
30 days after receipt of termination notice. Clients will be charged on a pro-rata basis, which takes
into account work completed by our firm on behalf of the client. Clients will incur charges for bona
fide advisory services rendered up to the point of termination (determined as 30 days from receipt
of said written notice) and such fees will be due and payable.
Commissionable Securities Sales
Our firm and representatives do not sell securities for a commission in advisory accounts.
Item 6: Performance-Based Fees & Side-By-Side Management
DWA does not receive a share of any gains produced in our clients’ managed accounts. Such sharing
is known as performance-based fees. We do not charge performance-based fees. We only charge a
fee based on the assets we manage as previously explained under “Fees & Compensation”.
Item 7: Types of Clients & Account Requirements
DWA provides advisory services and investment advice to individuals, pension plans, profit sharing
plans, defined benefit plans, trusts and estates.
Our minimum household account size is one that can invest at least $250,000 with us. We will
consider smaller households when related to or referred by an existing client or on a case-by-case
basis.
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
Methods of Analysis
We use both fundamental analysis and technical analysis in the construction of our portfolios. We
obtain our information from investment publications, online subscriptions, corporate press releases
and filings, screening programs and charting programs, the research of others and our own
proprietary research. We believe loss-avoidance is key. This is especially true with retirees whose
time-frame is the shortest of the various investor types and thus they generally cannot afford a
significant decline in their portfolios.
Many advisors reduce risk by diversifying by asset type and further by owning baskets of securities
so as to reduce individual security risk. We take diversification several steps further by diversifying
also by strategy, by relative strength and by holding time-frame. We may also employ options to
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Dynamic Wealth Advisors
hedge against market and security specific downside risk in special situations and we may also
establish short positions to benefit from expected declines.
Investment Strategies We Use
We manage our clients’ accounts through models designed to meet specific investment goals. The
models each take a different strategic approach to meeting their corresponding goals. They are
organized under 3 categories which are Income, Trend Following Growth and Opportunistic Growth:
1) Income
High Current Income—This model invests in securities that pay dividends or interest in
excess of 5% and which we believe is sustainable. This model generally includes MLP’s, REITs,
Option Income Funds, High Yield funds, floating rate funds, preferred stocks and closed-end
income funds bought at a discount below their historic norm. This model is designed to
produce steady, sustainable income but may experience short-term volatility and potential
erosion of principal.
Income with Growth— This model screens for quality, dividend-paying companies that have
consistently paid and increased their dividends. We then screen for those with the strongest
chart patterns, using proprietary screens and buy those stocks. We regularly re-run the
screens and sell the stocks that have run up into technical resistance and buy those that are
at support and rising.
2) Trend Following Growth
ETF Relative Strength Rotation--We use a proprietary screen to find ETF’s (exchange- traded
funds) that are relatively strong compared to their peers and exhibit lower relative volatility.
We re-evaluate every month. This helps to keep us invested in the strongest, most stable
sectors in up markets and has historically shifted holdings into the safer groups when the
market is trending lower.
Diversified Mutual Fund Model--Our traditional mutual fund model invests in different asset
classes with the goal of staying invested in order to capture trends.
3) Opportunistic Growth
Short-term swing trading strategy—Invests in stocks, ETFs and options. The goal of swing
trading is to identify securities whose chart patterns exhibit a high probability of producing
an upward move in a period of 1 to 3 weeks. We will hold a fair amount in cash when no high
probability trades are identified. In other words, we seek to “Only swing at the good pitches”.
We may use cash protected puts and various forms of arbitrage to improve returns on cash.
We may employ option spreads to capture expected sharp movements. May also be employed
using an ETF or mutual fund model in place of cash for those desiring to be fully invested at
all times.
S&P 500 Lower Volatility Opportunistic Growth--Similar to the strategy above, but only
invests in large-cap companies that are part of the S&P 500 index or of similar quality
(considered “Blue chip”). This strategy is expected to result in lower returns than the strategy
above, but with the expected benefit of lower volatility as well.
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Dynamic Wealth Advisors
To determine which strategies to use and how to combine them we first we create a financial plan
for each prospective client. We analyze their financial situation—goals, resources, timeframes,
liquidity needs, need for income or growth, risk tolerance, tax circumstances, etc. We then model a
retirement cash-flow projection and determine the minimum rate of return needed to avoid running
out of money under various scenarios. We add a cushion of 1 to 2 percent to this figure.
Then we consider what combination of portfolio strategies might best produce the desired return
with the least amount of risk.
Next we run a tax screen to determine which strategies work best in the types of accounts (IRA, Roth
IRA, Trust, etc.) that are available to the client. Normally investments that produce short-term gains,
interest or ordinary income are better to hold inside of IRA’s. Qualified Dividend payers and long-
term gain assets are generally better in taxable accounts.
Strategies that seek to produce short-term gains also can be excellent in taxable accounts if there are
significant loss carryovers which can be combined with the short-term gains to make them effectively
tax-free. Finally, high growth, short-term gain strategies tend to fit well inside of Roth IRA’s.
Risk of Loss
There are multiple risks including unforeseen risks that can wreak havoc on any portfolio strategy.
Investing involves risk. We seek to identify and mitigate the risks that we perceive as most likely but
there can be no assurance that our strategies will work. Past performance does not guarantee future
results. Loss of principal is possible.
Item 9: Disciplinary Information
Registered Investment Advisors are required to disclose all material facts regarding any legal or
disciplinary events that would be material to you evaluation of DWA or the integrity of DWA
management personnel. No events have occurred at DWA and none have occurred with any of its
officers that are applicable to this item.
Item 10: Other Financial Industry Activities & Affiliations
Representatives of our firm are licensed insurance agents. As a result of these transactions, they
receive normal and customary commissions. A conflict of interest exists as these commissionable
sales create an incentive to recommend products based on the compensation earned. To mitigate this
potential conflict, our firm will act in the client’s best interest.
Representatives of our firm are Certified Public Accountants. In such capacity, they also provide
income tax preparation or accounting services. These services are independent of our financial
planning and investment advisory services and are governed under a separate engagement
agreement.
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Dynamic Wealth Advisors
Adam Carlini also provides estate and income tax planning and preparation in his individual financial
practice through his other company, Dynamic Wealth Management. This activity takes up less than
10% of his time. These services are independent of our financial planning and investment advisory
services and are governed under a separate engagement agreement.
Item 11: Code of Ethics, Participation or Interest in
Client Transactions & Personal Trading
DWA maintains an Investment Advisory Code of Ethics based on ethical conduct and fundamental
principles of good faith, fair dealing, integrity, honesty, and full and fair disclosure. DWA Advisors
acknowledge in writing that they will follow DWA's Code of Ethics. For a copy of the Code of Ethics please
contact DWA or your Advisor.
In summary, DWA's Code of Ethics:
(1) Requires full and fair disclosure of all material elements of the investment advisory relationship with
the Client;
(2) Requires compliance with certain Policies on Personal Securities Trading, which, in general:
(a) Prohibit an Advisor from trading a security before a Client; and (b) prohibit an Advisor from opening
or having a personal securities trading account without DWA’s prior approval;
(3) Prohibits an Advisor from acting on or distributing material, nonpublic information;
(4) Prohibits an Advisor from participating in an initial public offering without prior written approval
from DWA’s President.
Item 12: Brokerage Practices
Selecting a Brokerage Firm
While our firm does not maintain physical custody of client assets, we are deemed to have custody of
certain client assets if given the authority to withdraw assets from client accounts (see Item 15
Custody, below). Client assets must be maintained by a qualified custodian. Our firm seeks to
recommend a custodian who will hold client assets and execute transactions on terms that are overall
most advantageous when compared to other available providers and their services. The factors
considered, among others, are these:
• Timeliness of execution
• Timeliness and accuracy of trade confirmations
• Research services provided
• Ability to provide investment ideas
• Execution facilitation services provided
• Record keeping services provided
• Custody services provided
• Frequency and correction of trading errors
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Dynamic Wealth Advisors
• Ability to access a variety of market venues
• Expertise as it relates to specific securities
• Financial condition
• Business reputation
• Quality of services
With this in consideration, our firm recommends Charles Schwab & Co., Inc. (“Schwab”) as a custodian.
Schwab offers services to independent investment advisers which includes custody of securities,
trade execution, clearance and settlement of transactions. Schwab enables us to obtain many no-load
mutual funds without transaction charges and other no-load funds at nominal transaction charges.
Schwab does not charge client accounts separately for custodial services. Client accounts will be charged
transaction fees, commissions or other fees on trades that are executed or settle into the client’s
custodial account. Transaction fees may be charged via individual transaction charges. These fees are
negotiated with Schwab and are generally discounted from customary retail commission rates. This
benefits clients because the overall fee paid is often lower than would be otherwise.
Schwab may make certain research and brokerage services available at no additional cost to our firm.
Research products and services provided by Schwab may
include: research reports on
recommendations or other information about particular companies or industries; economic surveys,
data and analyses; financial publications; portfolio evaluation services; financial database software and
services; computerized news and pricing services; quotation equipment for use in running software
used in investment decision-making; and other products or services that provide lawful and appropriate
assistance by Schwab to our firm in the performance of our investment decision-making responsibilities.
The aforementioned research and brokerage services qualify for the safe harbor exemption defined in
Section 28(e) of the Securities Exchange Act of 1934.
Schwab does not make client brokerage commissions generated by client transactions available for
our firm’s use. The aforementioned research and brokerage services are used by our firm to manage
accounts for which our firm has investment discretion. Without this arrangement, our firm might be
compelled to purchase the same or similar services at our own expense.
As part of our fiduciary duty to our clients, our firm will endeavor at all times to put the interests of
our clients first. Clients should be aware, however, that the receipt of economic benefits by our firm
or our related persons creates a potential conflict of interest and may indirectly influence our firm’s
choice of Schwab as a custodial recommendation. Our firm examined this potential conflict of interest
when our firm chose to recommend Schwab and have determined that the recommendation is in the
best interest of our firm’s clients and satisfies our fiduciary obligations, including our duty to seek best
execution.
Our clients may pay a transaction fee or commission to Schwab that is higher than another qualified
broker dealer might charge to effect the same transaction where our firm determines in good faith
that the commission is reasonable in relation to the value of the brokerage and research services
provided to the client as a whole.
In seeking best execution, the determinative factor is not the lowest possible cost, but whether the
transaction represents the best qualitative execution, taking into consideration the full range of a
broker-dealer’s services, including the value of research provided, execution capability, commission
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Dynamic Wealth Advisors
rates, and responsiveness. Although our firm will seek competitive rates, to the benefit of all clients,
our firm may not necessarily obtain the lowest possible commission rates for specific client account
transactions.
Soft Dollars
Our firm does not receive soft dollars in excess of what is allowed by Section 28(e) of the Securities
Exchange Act of 1934. The safe harbor research products and services obtained by our firm will
generally be used to service all of our clients but not necessarily all at any one particular time.
Brokerage for Client Referrals
Our firm does not receive brokerage for client referrals.
Directed Brokerage
Neither our firm nor any of our firm’s representatives have discretionary authority in making the
determination of the brokers-dealers and/or custodians with whom orders for the purchase or sale
of securities are placed for execution, and the commission rates at which such securities transactions
are effected. Our firm routinely recommends/ that clients direct us to execute through a specified
broker-dealer. Our firm recommends the use of Schwab. Each client will be required to establish their
account(s) with Schwab if not already done. Please note that not all advisers have this requirement.
Special Considerations for ERISA Clients
A retirement or ERISA plan client may direct all or part of portfolio transactions for its account
through a specific broker or dealer in order to obtain goods or services on behalf of the plan. Such
direction is permitted provided that the goods and services provided are reasonable expenses of the
plan incurred in the ordinary course of its business for which it otherwise would be obligated and
empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services
purchased are not for the exclusive benefit of the plan. Consequently, our firm will request that plan
sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will
be for the exclusive benefit of the plan.
Trade Aggregation
Because we manage using predefined models, most of our trades are block trades made on behalf of all
or substantially all clients who have selected the same model. A block trade involves entering one large
trade and allocating shares among multiple Client accounts. This may facilitate more timely execution as
well as a more equitable and efficient approach to achieving favorable price execution for a group of
Clients. Clients participating in any such block or aggregated transactions will receive an average share
price on a pro-rata basis.
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Dynamic Wealth Advisors
Item 13: Review of Accounts or Financial Plans
DWA reviews holdings in its investment models on a continual basis. Advisors review individual
Investment Management client accounts quarterly to determine whether the models, positions,
transactions, and strategies are consistent with the Client's stated investment objective(s). Advisors
review accounts with each Client in person or by phone, if necessary, on an ongoing basis. Reviews
occur at least annually and generally follow a predetermined schedule based on each Client's
preferences. Clients may request a review of accounts with their Advisor at any time. Our firm does
not provide written reports to clients, unless asked to do so.
Additionally, certain events such as market downturns may lead an Advisor to have more frequent
account reviews and/or more frequent Client communication. Periodically DWA employees and
officers may also review accounts for consistency with stated Client objectives.
Retirement Plan Consulting clients receive reviews of their retirement plans for the duration of the
service. Our firm also provides ongoing services where clients are met with upon their request to
discuss updates to their plans, changes in their circumstances, etc. Retirement Plan Consulting clients
do not receive written or verbal updated reports regarding their plans unless they choose to engage
our firm for ongoing services.
Item 14: Client Referrals & Other Compensation
Schwab
Neither DWA nor its advisors receive other compensation related to any advisory accounts other
than the compensation described in the investment advisory contract. However, out of an abundance
of caution to provide disclosure we make the following observation:
The custodians we choose to work with may provide ancillary products and services that benefit us
but may not directly benefit your account(s). This could be construed as a form of compensation and
potential conflict of interest.
Many of these other products and services assist us in managing and administering your account(s).
These include, but are not limited to, software that facilitates trade execution (and allocation of block
trades for multiple accounts), provides access to account data (such as trade confirmations, account
statements and tax information), provides research and market data, facilitates payment of our fees
from your account, and assists with recordkeeping, reporting and other back-office functions.
The custodians also make available to us other services intended to help us manage and further
develop our business. These services may include consulting, publications and conferences on
practice management, information technology, business succession, regulatory compliance,
investment management and marketing.
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Dynamic Wealth Advisors
In addition, the custodians may make available, arrange and/or pay for these services provided to us
by third parties. The custodians may discount or waive fees that they would otherwise charge for
some of these services or pay all or a part of the fees of a third-party providing these services to us.
As a fiduciary, we endeavor to act in your best interest. Our recommendation that you maintain your
assets in accounts at one of our recommended custodians may be based in part on the benefit to us
or the availability of some of the foregoing products and services and not solely on the nature, cost
or quality of custody and brokerage services provided by the custodian. As a mitigating factor, we
point out that other custodians provide similar, if not equivalent, services and benefits to the advisors
who work with them.
Referral Fees
We may enter into written referral agreements with qualified third parties by which the third party
may refer clients to us. Should those referred individuals become advisory clients of DWA, we agree
to pay the third party a referral fee equal to a percentage of fees received by us from the referred
client(s). Those who refer clients to us in exchange for compensation must be duly licensed as IAR’s
and approved by DWA. They must agree to abide by the policies, procedures and code of ethics the
same as all advisors who work with us.
The fee to be paid by DWA will be borne entirely by DWA and there will be no additional fee, cost or
expense to the referred client resulting from the referral agreement. All referral agreements will be
governed by and comply with Rule 206(4)-3 under the Investment Advisers Act of 1940.
Item 15: Custody
Deduction of Advisory Fees:
DWA does not take custody of your account(s). Client assets are held at custodians independent of
DWA. This important protection ensures that your account(s) are not commingled with those of DWA
or of any of our other clients. Your account(s) are entirely separate and distinct. You are able to
directly access your account information from the custodian online and confirm all transactions and
activity in your account(s). We have carefully chosen the custodians we work with and consider them
best in class.
Third Party Money Movement:
On February 21, 2017, the SEC issued a no‐action letter (“Letter”) with respect to Rule 206(4)‐2
(“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided
guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client
funds to a third party under a standing letter of authorization (“SLOA”) is deemed to have custody.
As such, our firm has adopted the following safeguards in conjunction with our custodian:
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• The client provides an instruction to the qualified custodian, in writing, that includes the
client’s signature, the third party’s name, and either the third party’s address or the third
party’s account number at a custodian to which the transfer should be directed.
• The client authorizes the investment adviser, in writing, either on the qualified custodian’s
form or separately, to direct transfers to the third party either on a specified schedule or from
time to time.
• The client’s qualified custodian performs appropriate verification of the instruction, such as
a signature review or other method to verify the client’s authorization, and provides a
transfer of funds notice to the client promptly after each transfer.
• The client has the ability to terminate or change the instruction to the client’s qualified
custodian.
• The investment adviser has no authority or ability to designate or change the identity of the
third party, the address, or any other information about the third party contained in the
client’s instruction.
• The investment adviser maintains records showing that the third party is not a related party
of the investment adviser or located at the same address as the investment adviser.
• The client’s qualified custodian sends the client, in writing, an initial notice confirming the
instruction and an annual notice reconfirming the instruction.
Item 16: Investment Discretion
Our firm manages accounts on a discretionary basis. After you sign an agreement with our firm, we’re
allowed to buy and sell investments in your account without asking you in advance. Any limitations
will be described in the signed advisory agreement. We will have discretion until the advisory
agreement is terminated by you or our firm.
Item 17: Voting Client Securities
DWA does not vote client proxies. We will direct the custodians to send all proxy materials to your
attention. If we inadvertently receive proxy materials, we will make an effort to forward them to you
in a timely manner. However, we will not be held responsible for adverse events as a result of proxy
materials being incorrectly sent to us by the custodian.
Item 18: Financial Information
Our firm is not required to provide financial information in this Brochure because:
• Our firm does not require the prepayment of more than $1,200 in fees when services cannot
be rendered within 6 months.
• Our firm does not take custody of client funds or securities.
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Dynamic Wealth Advisors
• Our firm does not have a financial condition or commitment that impairs our ability to meet
contractual and fiduciary obligations to clients.
• Our firm has never been the subject of a bankruptcy proceeding.
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