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ITEM 1: COVER PAGE
PART 2A OF FORM ADV: FIRM BROCHURE
August 2025
7530 Lucerne Drive, Suite 400
Middleburg Heights, OH 44130
(440) 572-5552
www.FidatoWealth.com
Firm Contact:
Eric Pucek
Managing Director & Chief Compliance Officer
This brochure provides information about the qualifications and business practices of Fidato
Wealth LLC. If you have any questions about the contents of this brochure, please contact by
telephone at 440-572-5552 or email at eric@fidatowealth.com . The information in this
brochure has not been approved or verified by the United States Securities and Exchange
Commission or by any State Securities Authority. Additional information about Fidato Wealth
LLC also is available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD
#158173.
Please note that the use of the term “registered investment adviser” and description of Fidato
Wealth LLC and/or our associates as “registered” does not imply a certain level of skill or
training. You are encouraged to review this Brochure and Brochure Supplements for our
firm’s associates who advise you for more information on the qualifications of our firm and
our employees.
Item 2: Material Changes
Fidato Wealth LLC is required to advise you of any material changes to our Firm Brochure
(“Brochure”) from our last annual update. Since our last annual amendment filing on March 13th,
2025, the following changes have been made:
• Our firm has increased the initial consultation fee we charge. Please see Item 5 of this
brochure for more information.
• Our firm has amended Item 5 of this brochure to disclose the fees associated for donor-
advised fund accounts. Please see Item 5 for more information.
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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 ........................................................ 9
Item 9: Disciplinary Information .............................................................................................................. 18
Item 10: Other Financial Industry Activities & Affiliations .................................................................... 18
Item 11: Code of Ethics, Participation, or Interest in ............................................................................. 18
Client Transactions & Personal Trading .................................................................................................. 18
Item 12: Brokerage Practices ................................................................................................................... 19
Item 13: Review of Accounts or Financial Plans ..................................................................................... 23
Item 14: Client Referrals & 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
We provide individuals and other types of clients with a wide array of investment advisory services.
Our firm is a limited liability company formed in the State of Ohio. Our firm has been in business as
an investment adviser since 2011 and is owned by the Anthony S. D’Amico Trust UAD (96%), the
Amy J. D’Amico Trust UAD (1%), Brian Eberhardt (1%), Marissa Beyer (1%), & Lindsay Fiore (1%).
We specialize in Asset Management and Financial Planning & Consulting services. Our assets under
management are $406,511,047 as of December 31, 2024.
Types of Advisory Services We Offer
Asset Management & Financial Planning:
We emphasize continuous and regular account supervision. As part of our asset management service,
we generally create a portfolio, consisting of individual stocks or bonds, exchange traded funds (“ETFs”),
mutual funds and other public and private securities or investments. The client’s individual investment
strategy is tailored to their specific needs and may include some or all the previously mentioned
securities. Each portfolio will be initially designed to meet a particular investment goal, which we
determine to be suitable to the client’s circumstances. Once the appropriate portfolio has been
determined, we review the portfolio at least quarterly and if necessary, rebalance the portfolio based
upon the client’s individual needs, stated goals and objectives.
We may also provide a variety of financial planning and consulting services to individuals, families,
and other clients regarding the management of their financial resources based upon an analysis of
the client’s current situation, goals, and objectives. Some clients are provided ongoing financial
planning services, and other clients may not be provided financial planning services. This decision to
offer ongoing financial planning services is done on a discretionary basis by our firm. It is indicated
on the client’s Asset Management and Financial Planning Agreement if financial planning services
will be provided or not. When financial planning services are provided, these services are included
in Item 5 below.
Our financial planning services will generally involve preparing a financial plan for clients based on
the client’s financial goals and investment objectives. This planning may encompass one or more of
the following areas based upon the client’s indicated goals & needs: Investment Planning, Retirement
Planning, Estate Planning, Charitable Planning, Education Planning, Personal Tax Planning,
Mortgage/Debt Analysis, Business Financial Planning, Personal Financial Planning, Stock
Options/Executive Compensation, Legacy Planning, Retirement Income & Distribution Management,
Social Security Analysis, Pension Analysis, Risk Management/Insurance Planning and Ongoing
Financial Plan & Monitoring.
Financial plans are prepared with information and/or documents requested by our firm. We rely on
client participation in order to mutually identify, define and prioritize financial planning efforts, and
mutually define implementation responsibilities. We rely on the client to provide complete &
accurate data. Incomplete or inaccurate information received from clients will impact financial
planning conclusions and recommendations. If incomplete information is provided, we will limit our
financial planning recommendations to only those areas that can be advised on in consideration of
the information we have. If material participation or material information is not provided, then we
will not provide any financial planning advice and limit our services to asset management services
only. Financial Planning services rendered usually include recommendations for a course of activity
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or specific actions to be taken by the clients. For example, recommendations may be made that the
client begins or revises investment programs, create or revise wills or trusts, obtain or revise
insurance coverage, commence or alter retirement savings, or establish education or charitable
giving programs. Financial Planning clients are provided a copy of their financial plan and a verbal
report of observations and recommendations.
It should also be noted that we may refer clients to a third party for the provision of additional
professional services, such as an accountant, attorney, or other specialist, as necessary for non-
advisory related services. If client chooses to hire these individuals for their services, additional fees
from the provider will apply, and the Client will be billed directly by that provider. Our firm is not
compensated for referrals made to professional service providers.
Our firm utilizes the sub-advisory services of third-party investment advisory firms to aid in the
implementation of an investment portfolio designed by our firm. Before selecting a firm or individual,
our firm will ensure that the chosen party is properly licensed or registered. Our firm will not offer
advice on any specific securities or other investments once the third-party manager has discretionary
authority over those assets. We will provide initial due diligence on third party money managers and
ongoing reviews of their management of client accounts. In order to assist in the selection of a third
party money manager, our firm will gather client information pertaining to financial situation,
investment objectives, and reasonable restrictions to be imposed upon the management of the
account.
Our firm will periodically review third party money manager reports provided to the client at least
annually. Our firm will contact clients from time to time in order to review their financial situation
and objectives; communicate information to third party money managers as warranted; and, assist
the client in understanding and evaluating the services provided by the third party money manager.
Clients will be expected to notify our firm of any changes in their financial situation, investment
objectives, or account restrictions that could affect their financial standing.
Retirement Plan Consulting:
Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing
basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing,
monitoring, and reviewing their company's participant-directed retirement plan. As the needs of the
plan sponsor dictate, areas of advising could include investment options, plan structure and
participant education. Retirement Plan Consulting services typically include:
•
• Establishing an Investment Policy Statement – Our firm will assist in the development of a
statement that summarizes the investment goals and objectives along with the broad
strategies to be employed to meet the objectives.
Investment Options – Our firm will work with the Plan Sponsor to evaluate existing
investment options and make recommendations for appropriate changes.
•
• Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation
models to aid Participants in developing strategies to meet their investment objectives, time
horizon, financial situation, and tolerance for risk.
Investment Monitoring – Our firm will monitor the performance of the investments.
In providing services for retirement plan consulting, our firm does not provide any advisory services
with respect to the following types of assets: employer securities, real estate (excluding real estate
funds and publicly traded REITS), participant loans, non-publicly traded securities or assets, other
illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement
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plan consulting services shall be in compliance with the applicable state laws regulating retirement
consulting services. This applies to client accounts that are retirement or other employee benefit
plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended
(“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to provide
services to such accounts, our firm acknowledges its fiduciary standard within the meaning of Section
3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to
the provision of services described therein.
Tailoring of Advisory Services
We offer individualized investment advice to clients utilizing our Asset Management Service.
Additionally, we offer individualized financial planning and guidance to clients to which we are
providing ongoing financial planning services. General investment advice will be offered to
Retirement Financial Planning & Consulting and Third-Party Money Management clients. We usually
do not allow clients to impose restrictions on investing in certain securities or types of securities due
to the level of difficulty this would entail in managing their account. In the rare instance that we
would allow restrictions, it would be limited to our Asset Management service.
It is expressly understood and agreed between the parties of this Agreement that our firm will not
provide accounting or legal advice nor prepare any accounting or legal documents for the
implementation of the Client’s financial planning objectives. The Client is urged to work closely with
his/her attorney and/or accountant in implementing recommendations set forth in the financial plan.
Participation in Wrap Fee Programs
We do not offer wrap fee programs.
Regulatory Assets Under Management
As of December 31, 2024, our firm manages $406,511,047 on a discretionary basis.
Item 5: Fees & Compensation
How We Are Compensated
Asset Management & Financial Planning:
For Directly Managed Accounts:
Assets Under Management Annual % of Assets Charge
First $1,000,000
$1,000,001 to $3,000,000
$3,000,001 to $5,000,000
$5,000,001 to $10,000,000
$10,000,001 to $25,000,000
$25,000,001 and Greater
1.50%
1.00%
0.80%
0.70%
0.60%
0.50%
Quarterly % of Assets Charge
0.375%
0.250%
0.200%
0.175%
0.150%
0.125%
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For Held Away Accounts:
Assets Under Management Annual % of Assets Charge Quarterly % of Assets Charge
Any Assets
1.00%
0.250%
Our firm’s advisory fees will not exceed 1.50%. We rarely negotiate our fees. However, at our
discretion, we may negotiate our fees under certain circumstances. The minimum annual fee for
directly managed accounts is $5,000. However, at our discretion, we may negotiate or waive this
requirement under certain circumstances.
For clients who have not yet subscribed to our Asset Management and Financial Planning Services,
we may charge a consultation fee to prepare an investment analysis and initial financial plan analysis.
For the initial consultative process, we charge a fee that ranges from $750 to $25,000. This fee will
be waived if the client engages with our firm for our Asset Management & Financial Planning services.
Fees are billed on a pro-rata annualized basis quarterly in arrears based on the value of your account
on the last day of the quarter. Fees will be adjusted for deposits and withdrawals made during the
quarter. The ultimate fee assessed will be detailed in an advisory agreement to be signed by the client.
A client’s fee is based on the amount of assets under management, and the scope and complexity of
the client’s portfolio and financial situation. Unless otherwise noted in writing, our firm bills on cash.
Fees will be deducted from the client’s managed account. 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; and
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.
The maximum annual combined management fee charged to clients between our firm and a third-
party manager, if selected, will not exceed 1.90%. Our firm will debit fees for this service as disclosed
in the executed advisory agreement between the client and our firm. This fee shall be in addition to
any fees assessed by the chosen third-party money manager. The third-party money managers we
recommend will not directly charge you a higher fee than they would have charged without us
introducing you to them. Third party money managers establish and maintain their own separate
billing processes over which we have no control. They will directly bill you and describe how this
works in their Form ADV and/or agreement with you.
Retirement Plan Consulting:
Our Retirement Plan Consulting services are based on the percentage of Plan assets under
management. 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
Clients will incur transaction charges for trades executed in their accounts, either based on
transaction charges, or percentage of the dollar amount of assets in the account(s) on a quarterly
basis. When an account is receiving contributions of at least $500 per month, and based upon the
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account size, the account will be charged on an annual asset-based fee (“ABF”) of 0.10%. Fidato
Wealth LLC conducts a biennial review of advisory accounts to determine the appropriate billing
method for each account at our discretion. The review will take into account market fluctuations, the
account size, account transaction history, and future events specific to the client. These transaction
fees are separate from our firm’s advisory fees and will be disclosed by the chosen custodian. 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 (i.e., fund management fees, initial or deferred sales charges, mutual fund sales
loads, 12b-1 fees, surrender charges, variable annuity fees, IRA and qualified retirement plan fees,
and other fund expenses). Our firm does not receive a portion of these fees.
For donor-adviser fund accounts, the donor-advised fund administrator charges an annual fee
directly debited quarterly, in advance, from the client donor-advised fund account. Donor-advised
fund fees are based upon the following tiered structure: First $500,000; .65%, next $500,000; .35%,
next $1,500,000; .25%, next $12,500,000; .15%, and above $15,000,000; .10%. This will be outlined
in the advisory agreement signed by the client.
Termination & Refunds
We charge our advisory fees quarterly in arrears. If you wish to terminate our services, you need to
contact us in writing and state that you wish to cancel our Asset Agreement Upon receipt of your
letter of termination, we will proceed to close out your account and charge you a pro-rata advisory
fee(s) for services rendered up to the point of termination.
Upon the written notice to terminate our services, Financial Planning & Consulting clients will be
refunded the difference between the initial paid retainer less the time calculated for services
rendered up to the point of written notice of termination.
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
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
We do not sell securities for a commission. In order to sell securities for a commission, we would
need to have our associated persons registered with a broker-dealer. We have chosen not to do so.
Item 6: Performance-Based Fees & Side-By-Side Management
We do not charge performance fees to our clients.
Item 7: Types of Clients & Account Requirements
We have the following types of clients: Individuals and High Net Worth Individuals; Pension and
Profit-Sharing Plans; and Trusts, Estates.
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Our firm’s services require a household minimum greater than $1,000,000 in investable assets.
However, at our discretion, we may make exceptions to this asset level requirement, as we take into
account the complexity of the situation, and factors such as an anticipated lump sum due to a
retirement, the sale of a business, a lump sum from an inheritance or legal proceeding, the ability to
save and invest, and other factors that would contribute to someone having a financial plan with a
high probability of success.
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
The following methods of analysis and investment strategies may be utilized in formulating our
investment advice and/or managing client assets, provided that such methods and/or strategies are
appropriate to the needs of the client and consistent with the client's investment objectives, risk
tolerance, and time horizons, among other considerations.
General Risks of Owning Securities
The prices of securities held in client accounts and the income they generate may decline in response
to certain events taking place around the world. These include events directly involving the issuers
of securities held as underlying assets of mutual funds in a client’s account, conditions affecting the
general economy, and overall market changes. Other contributing factors include local, regional, or
global political, social, or economic instability and governmental or governmental agency responses
to economic conditions. Finally, currency, interest rate, and commodity price fluctuations may also
affect security prices and income.
The prices of, and the income generated by, most debt securities held by a client’s account may be
affected by changing interest rates and by changes in the effective maturities and credit ratings of
these securities. For example, the prices of debt securities in the client’s account generally will decline
when interest rates rise and increase when interest rates fall. In addition, falling interest rates may
cause an issuer to redeem, “call” or refinance a security before its stated maturity, which may result
in our firm having to reinvest the proceeds in lower yielding securities. Longer maturity debt
securities generally have higher rates of interest and may be subject to greater price fluctuations than
shorter maturity debt securities. Debt securities are also subject to credit risk, which is the possibility
that the credit strength of an issuer will weaken, and/or an issuer of a debt security will fail to make
timely payments of principal or interest and the security will go into default.
The guarantee of a security backed by the U.S. Treasury or the full faith and credit of the U.S.
government only covers the timely payment of interest and principal when held to maturity. This
means that the current market values for these securities will fluctuate with changes in interest rates.
Investments in securities issued by entities based outside the United States may be subject to
increased levels of the risks described above. Currency fluctuations and controls, different
accounting, auditing, financial reporting, disclosure, regulatory and legal standards, and practices
could also affect investments in securities of foreign issuers. Additional factors may include
expropriation, changes in tax policy, greater market volatility, different securities market structures,
and higher transaction costs.
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Finally, various administrative difficulties, such as delays in clearing and settling portfolio
transactions, or in receiving payment of dividends can increase risk. Finally, investments in securities
issued by entities domiciled in the United States may also be subject to many of these risks.
Methods of Analysis:
Securities analysis methods rely on the assumption that the companies whose securities are
purchased and/or sold, the rating agencies that review these securities, and other publicly available
sources of information about these securities, are providing accurate and unbiased data. While our
firm is alert to indications that data may be incorrect, there is always a risk that our firm’s analysis
may be compromised by inaccurate or misleading information.
Fundamental Analysis: The analysis of a business's financial statements (usually to analyze the
business's assets, liabilities, and earnings), health, and its competitors and markets. When analyzing
a stock, futures contract, or currency using fundamental analysis there are two basic approaches one
can use: bottom-up analysis and top down analysis. The terms are used to distinguish such analysis
from other types of investment analysis, such as quantitative and technical. Fundamental analysis is
performed on historical and present data, but with the goal of making financial forecasts. There are
several possible objectives: (a) to conduct a company stock valuation and predict its probable price
evolution; (b) to make a projection on its business performance; (c) to evaluate its management and
make internal business decisions; (d) and/or to calculate its credit risk; and (e) to find out the
intrinsic value of the share.
When the objective of the analysis is to determine what stock to buy and at what price, there are two
basic methodologies investors rely upon: (a) Fundamental analysis maintains that markets may
misprice a security in the short run but that the "correct" price will eventually be reached. Profits can
be made by purchasing the mispriced security and then waiting for the market to recognize its
"mistake" and reprice the security; and (b) Technical analysis maintains that all information is
reflected already in the price of a security. Technical analysts analyze trends and believe that
sentiment changes predate and predict trend changes. Investors' emotional responses to price
movements lead to recognizable price chart patterns. Technical analysts also analyze historical
trends to predict future price movement. Investors can use one or both of these different but
complementary methods for stock picking. This presents a potential risk, as the price of a security
can move up or down along with the overall market regardless of the economic and financial factors
considered in evaluating the stock.
Mutual Fund and/or Exchange Traded Fund (“ETF”) Analysis: Analysis of the experience and
track record of the manager of the mutual fund or ETF in an attempt to determine if that manager
has demonstrated an ability to invest over a period of time and in different economic conditions. The
underlying assets in a mutual fund or ETF are also reviewed in an attempt to determine if there is
significant overlap in the underlying investments held in another fund(s) in the Client’s portfolio. The
funds or ETFs are monitored in an attempt to determine if they are continuing to follow their stated
investment strategy. A risk of mutual fund and/or ETF analysis is that, as in all securities investments,
past performance does not guarantee future results. A manager who has been successful may not be
able to replicate that success in the future. In addition, as our firm does not control the underlying
investments in a fund or ETF, managers of different funds held by the Client may purchase the same
security, increasing the risk to the Client if that security were to fall in value. There is also a risk that
a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which
could make the holding(s) less suitable for the Client’s portfolio.
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Technical Analysis: A security analysis methodology for forecasting the direction of prices through
the study of past market data, primarily price and volume. A fundamental principle of technical
analysis is that a market's price reflects all relevant information, so their analysis looks at the history
of a security's trading pattern rather than external drivers such as economic, fundamental and news
events. Therefore, price action tends to repeat itself due to investors collectively tending toward
patterned behavior – hence technical analysis focuses on identifiable trends and conditions.
Technical analysts also widely use market indicators of many sorts, some of which are mathematical
transformations of price, often including up and down volume, advance/decline data and other
inputs. These indicators are used to help assess whether an asset is trending, and if it is, the
probability of its direction and of continuation. Technicians also look for relationships between
price/volume indices and market indicators. Technical analysis employs models and trading rules
based on price and volume transformations, such as the relative strength index, moving averages,
regressions, inter-market and intra-market price correlations, business cycles, stock market cycles
or, classically, through recognition of chart patterns. Technical analysis is widely used among traders
and financial professionals and is very often used by active day traders, market makers and pit
traders. The risk associated with this type of analysis is that analysts use subjective judgment to
decide which pattern(s) a particular instrument reflects at a given time and what the interpretation
of that pattern should be.
Third-Party Money Manager Analysis: The analysis of the experience, investment philosophies,
and past performance of independent third-party investment managers in an attempt to determine
if that manager has demonstrated an ability to invest over a period of time and in different economic
conditions. Analysis is completed by monitoring the manager’s underlying holdings, strategies,
concentrations and leverage as part of our overall periodic risk assessment. Additionally, as part of
the due-diligence process, the manager’s compliance and business enterprise risks are surveyed and
reviewed. The risk of investing with a third-party manager who has been successful in the past is that
they may not be able to replicate that success in the future. In addition, as our firm does not control
the underlying investments in a third-party manager’s portfolio, there is also a risk that a manager
may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable
investment for our clients. Moreover, as our firm does not control the manager’s daily business and
compliance operations, our firm may be unaware of the lack of internal controls necessary to prevent
business, regulatory or reputational deficiencies.
Investment Strategies & Asset Classes:
Asset Allocation: The implementation of an investment strategy that attempts to balance risk versus
reward by adjusting the percentage of each asset in an investment portfolio according to the
investor's risk tolerance, goals, and investment time frame. Asset allocation is based on the principle
that different assets perform differently in different market and economic conditions. A fundamental
justification for asset allocation is the notion that different asset classes offer returns that are not
perfectly correlated, hence diversification reduces the overall risk in terms of the variability of
returns for a given level of expected return. Although risk is reduced as long as correlations are not
perfect, it is typically forecast (wholly or in part) based on statistical relationships (like correlation
and variance) that existed over some past period. Expectations for return are often derived in the
same way.
An asset class is a group of economic resources sharing similar characteristics, such as riskiness and
return. There are many types of assets that may or may not be included in an asset allocation strategy.
The "traditional" asset classes are stocks (value, dividend, growth, or sector-specific [or a "blend" of
any two or more of the preceding]; large-cap versus mid-cap, small-cap or micro-cap; domestic,
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foreign [developed], emerging or frontier markets), bonds (fixed income securities more generally:
investment-grade or junk [high-yield]; government or corporate; short-term, intermediate, long-
term; domestic, foreign, emerging markets), and cash or cash equivalents. Allocation among these
three provides a starting point. Usually included are hybrid instruments such as convertible bonds
and preferred stocks, counting as a mixture of bonds and stocks. Other alternative assets that may be
considered include: commodities: precious metals, nonferrous metals, agriculture, energy, others;
Commercial or residential real estate (also REITs); Collectibles such as art, coins, or stamps;
insurance products (annuity, life settlements, catastrophe bonds, personal life insurance products,
etc.); derivatives such as long-short or market neutral strategies, options, collateralized debt, and
futures; foreign currency; venture capital; private equity; and/or distressed securities.
There are several types of asset allocation strategies based on investment goals, risk tolerance, time
frames and diversification. The most common forms of asset allocation are strategic, dynamic,
tactical, and core-satellite.
• Strategic Asset Allocation: The primary goal of a strategic asset allocation is to create an asset
mix that seeks to provide the optimal balance between expected risk and return for a long-
term investment horizon. Generally speaking, strategic asset allocation strategies are
agnostic to economic environments, i.e., they do not change their allocation postures relative
to changing market or economic conditions.
• Dynamic Asset Allocation: Dynamic asset allocation is similar to strategic asset allocation in
that portfolios are built by allocating to an asset mix that seeks to provide the optimal balance
between expected risk and return for a long-term investment horizon. Like strategic
allocation strategies, dynamic strategies largely retain exposure to their original asset
classes; however, unlike strategic strategies, dynamic asset allocation portfolios will adjust
their postures over time relative to changes in the economic environment.
• Tactical Asset Allocation: Tactical asset allocation is a strategy in which an investor takes a
more active approach that tries to position a portfolio into those assets, sectors, or individual
stocks that show the most potential for perceived gains.
• Core-Satellite Asset Allocation: Core-Satellite allocation strategies generally contain a 'core'
strategic element making up the most significant portion of the portfolio, while applying a
dynamic or tactical 'satellite' strategy that makes up a smaller part of the portfolio. In this
way, core-satellite allocation strategies are a hybrid of the strategic and dynamic/tactical
allocation strategies mentioned above.
Debt Securities (Bonds): Issuers use debt securities to borrow money. Generally, issuers pay
investors periodic interest and repay the amount borrowed either periodically during the life of the
security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-
coupon bonds, which do not pay current interest, but rather are priced at a discount from their face
values and their values increase over time to face value at maturity. The market prices of debt
securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In
general, market prices of debt securities decline when interest rates rise and increase when interest
rates fall. Bonds with longer rates of maturity tend to have greater interest rate risks.
Certain additional risk factors relating to debt securities include: (a) When interest rates are
declining, investors have to reinvest their interest income and any return of principal, whether
scheduled or unscheduled, at lower prevailing rates; (b) Inflation causes tomorrow’s dollar to be
worth less than today’s; in other words, it reduces the purchasing power of a bond investor’s future
interest payments and principal, collectively known as “cash flows.” Inflation also leads to higher
interest rates, which in turn leads to lower bond prices; (c) Debt securities may be sensitive to
economic changes, political and corporate developments, and interest rate changes. Investors can
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also expect periods of economic change and uncertainty, which can result in increased volatility of
market prices and yields of certain debt securities. For example, prices of these securities can be
affected by financial contracts held by the issuer or third parties (such as derivatives) relating to the
security or other assets or indices; (d) Debt securities may contain redemption or call provisions
entitling their issuers to redeem them at a specified price on a date prior to maturity. If an issuer
exercises these provisions in a lower interest rate market, the account will have to replace the
security with a lower yielding security, resulting in decreased income to investors. Usually, a bond is
called at or close to par value. This subjects investors that paid a premium for their bond to the risk
of lost principal. In reality, prices of callable bonds are unlikely to move much above the call price if
lower interest rates make the bond likely to be called; (e) If the issuer of a debt security defaults on
its obligations to pay interest or principal or is the subject of bankruptcy proceedings, the account
may incur losses or expenses in seeking recovery of amounts owed to it; (f) There may be little
trading in the secondary market for particular debt securities, which may affect adversely the
account's ability to value accurately or dispose of such debt securities. Adverse publicity and investor
perceptions, whether or not based on fundamental analysis, may decrease the value and/or liquidity
of debt securities.
Our firm attempts to reduce the risks described above through diversification of the client’s portfolio
and by credit analysis of each issuer, as well as by monitoring broad economic trends and corporate
and legislative developments, but there can be no assurance that our firm will be successful in doing
so. Credit ratings for debt securities provided by rating agencies reflect an evaluation of the safety of
principal and interest payments, not market value risk. The rating of an issuer is a rating agency's
view of past and future potential developments related to the issuer and may not necessarily reflect
actual outcomes. There can be a lag between the time of developments relating to an issuer and the
time a rating is assigned and updated.
Exchange Traded Funds (“ETFs”): An ETF is a type of Investment Company (usually, an open-end
fund or unit investment trust) whose primary objective is to achieve the same return as a particular
market index. The vast majority of ETFs are designed to track an index, so their performance is close
to that of an index mutual fund, but they are not exact duplicates. A tracking error, or the difference
between the returns of a fund and the returns of the index, can arise due to differences in
composition, management fees, expenses, and handling of dividends. ETFs benefit from continuous
pricing; they can be bought and sold on a stock exchange throughout the trading day. Because ETFs
trade like stocks, you can place orders just like with individual stocks - such as limit orders, good-
until-canceled orders, stop loss orders etc. They can also be sold short. Traditional mutual funds are
bought and redeemed based on their net asset values (“NAV”) at the end of the day. ETFs are bought
and sold at the market prices on the exchanges, which resemble the underlying NAV but are
independent of it. However, arbitrageurs will ensure that ETF prices are kept very close to the NAV
of the underlying securities. Although an investor can buy as few as one share of an ETF, most buy in
board lots. Anything bought in less than a board lot will increase the cost to the investor. Anyone can
buy any ETF no matter where in the world it trades. This provides a benefit over mutual funds, which
generally can only be bought in the country in which they are registered.
One of the main features of ETFs is their low annual fees, especially when compared to traditional
mutual funds. The passive nature of index investing, reduced marketing, and distribution and
accounting expenses all contribute to the lower fees. However, individual investors must pay a
brokerage commission to purchase and sell ETF shares; for those investors who trade frequently,
this can significantly increase the cost of investing in ETFs. That said, with the advent of low-cost
brokerage fees, small or frequent purchases of ETFs are becoming more cost efficient.
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Equity Securities: Equity securities represent an ownership position in a company. Equity securities
typically consist of common stocks. The prices of equity securities fluctuate based on, among other
things, events specific to their issuers and market, economic and other conditions. For example,
prices of these securities can be affected by financial contracts held by the issuer or third parties
(such as derivatives) relating to the security or other assets or indices. There may be little trading in
the secondary market for particular equity securities, which may adversely affect our firm 's ability
to value accurately or dispose of such equity securities. Adverse publicity and investor perceptions,
whether or not based on fundamental analysis, may decrease the value and/or liquidity of equity
securities. Investing in smaller companies may pose additional risks as it is often more difficult to
value/dispose of small company stocks or obtain information about them, and the prices may be
more volatile than stocks of larger, more established companies. Clients should have a long-term
perspective and, for example, be able to tolerate potentially sharp declines in value.
Fixed Income: Fixed income is a type of investing or budgeting style for which real return rates or
periodic income is received at regular intervals and at reasonably predictable levels. Fixed-income
investors are typically retired individuals who rely on their investments to provide a regular, stable
income stream. This demographic tends to invest heavily in fixed-income investments because of the
reliable returns they offer. Fixed-income investors who live on set amounts of periodically paid
income face the risk of inflation eroding their spending power.
Some examples of fixed-income investments include treasuries, money market instruments,
corporate bonds, asset-backed securities, municipal bonds, and international bonds. The primary
risk associated with fixed-income investments is the borrower defaulting on its payment. Other
considerations include exchange rate risk for international bonds and interest rate risk for longer-
dated securities. The most common type of fixed-income security is a bond. Bonds are issued by
federal governments, local municipalities, and major corporations. Fixed-income securities are
recommended for investors seeking a diverse portfolio; however, the percentage of the portfolio
dedicated to fixed income depends on your own personal investment style. There is also an
opportunity to diversify the fixed-income component of a portfolio. Riskier fixed-income products,
such as junk bonds and longer-dated products, should comprise a lower percentage of your overall
portfolio.
The interest payment on fixed-income securities is considered regular income and is determined
based on the creditworthiness of the borrower and current market rates. In general, bonds and fixed-
income securities with longer-dated maturities pay a higher rate, also referred to as the coupon rate,
because they are considered riskier. The longer the security is on the market, the more time it has to
lose its value and/or default. At the end of the bond term, or at bond maturity, the borrower returns
the amount borrowed, also referred to as the principal or par value.
Individual Stocks: A common stock is a security that represents ownership in a corporation. Holders
of common stock exercise control by electing a board of directors and voting on corporate policy.
Investing in individual common stocks provides us with more control of what you are invested in and
when that investment is made. Having the ability to decide when to buy or sell helps us time the
taking of gains or losses. Common stocks, however, bear a greater amount of risk when compared to
certificate of deposits, preferred stock, and bonds. It is typically more difficult to achieve
diversification when investing in individual common stocks. Additionally, common stockholders are
on the bottom of the priority ladder for ownership structure; if a company goes bankrupt, the
common stockholders do not receive their money until the creditors and preferred shareholders
have received their respective share of the leftover assets.
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Long-Term Purchases: Our firm may buy securities for your account and hold them for a relatively
long time (more than a year) in anticipation that the security’s value will appreciate over a long
horizon. The risk of this strategy is that our firm could miss out on potential short-term gains that
could have been profitable to your account, or it’s possible that the security’s value may decline
sharply before our firm make a decision to sell.
Mutual Funds: A mutual fund is a company that pools money from many investors and invests the
money in a variety of differing security types based the objectives of the fund. The portfolio of the
fund consists of the combined holdings it owns. Each share represents an investor’s proportionate
ownership of the fund’s holdings and the income those holdings generate. The price that investors
pay for mutual fund shares is the funds per share net asset value (“NAV”) plus any shareholder fees
that the fund imposes at the time of purchase (such as sales loads). Investors typically cannot
ascertain the exact make-up of a fund’s portfolio at any given time, nor can they directly influence
which securities the fund manager buys and sells or the timing of those trades. With an individual
stock, investors can obtain real-time (or close to real-time) pricing information with relative ease by
checking financial websites or by calling a broker or your investment adviser. Investors can also
monitor how a stock’s price changes from hour to hour—or even second to second. By contrast, with
a mutual fund, the price at which an investor purchases or redeems shares will typically depend on
the fund’s NAV, which is calculated daily after market close.
The benefits of investing through mutual funds include: (a) Mutual funds are professionally managed
by an investment adviser who researches, selects, and monitors the performance of the securities
purchased by the fund; (b) Mutual funds typically have the benefit of diversification, which is an
investing strategy that is generally summed up as “Don’t put all your eggs in one basket.” Spreading
investments across a wide range of companies and industry sectors can help lower the risk if a
company or sector fails. Some investors find it easier to achieve diversification through ownership of
mutual funds rather than through ownership of individual stocks or bonds; (c) Some mutual funds
accommodate investors who do not have a lot of money to invest by setting relatively low dollar
amounts for initial purchases, subsequent monthly purchases, or both; and (d) At any time, mutual
fund investors can readily redeem their shares at the current NAV, less any fees and charges assessed
on redemption.
Mutual funds also have features that some investors might view as disadvantages: (a) Investors must
pay sales charges, annual fees, and other expenses regardless of how the fund performs. Depending
on the timing of their investment, investors may also have to pay taxes on any capital gains
distribution they receive. This includes instances where the fund went on to perform poorly after
purchasing shares; (b) Investors typically cannot ascertain the exact make-up of a fund’s portfolio at
any given time, nor can they directly influence which securities the fund manager buys and sells or
the timing of those trades; and (c) With an individual stock, investors can obtain real-time (or close
to real-time) pricing information with relative ease by checking financial websites or by calling a
broker or your investment adviser. Investors can also monitor how a stock’s price changes from hour
to hour—or even second to second. By contrast, with a mutual fund, the price at which an investor
purchases or redeems shares will typically depend on the fund’s NAV, which the fund might not
calculate until many hours after the investor placed the order. In general, mutual funds must calculate
their NAV at least once every business day, typically after the major U.S. exchanges close.
When investors buy and hold an individual stock or bond, the investor must pay income tax each year
on the dividends or interest the investor receives. However, the investor will not have to pay any
capital gains tax until the investor actually sells and makes a profit. Mutual funds are different. When
an investor buys and holds mutual fund shares, the investor will owe income tax on any ordinary
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dividends in the year the investor receives or reinvests them. Moreover, in addition to owing taxes
on any personal capital gains when the investor sells shares, the investor may have to pay taxes each
year on the fund’s capital gains. That is because the law requires mutual funds to distribute capital
gains to shareholders if they sell securities for a profit and cannot use losses to offset these gains.
Risk of Loss: Investing in securities involves risk of loss that clients should be prepared to bear.
While the stock market may increase and your account(s) could enjoy a gain, it is also possible that
the stock market may decrease, and your account(s) could suffer a loss. It is important that you
understand the risks associated with investing in the stock market, are appropriately diversified in
your investments, and ask us any questions you may have.
Capital Risk: Capital risk is one of the most basic, fundamental risks of investing; it is the risk that
you may lose 100% of your money. All investments carry some form of risk and the loss of capital is
generally a risk for any investment instrument.
Company Risk: When investing in stock positions, there is always a certain level of company or
industry specific risk that is inherent in each investment. This is also referred to as unsystematic risk
and can be reduced through appropriate diversification. There is the risk that the company will
perform poorly or have its value reduced based on factors specific to the company or its industry.
For example, if a company’s employees go on strike or the company receives unfavorable media
attention for its actions, the value of the company may be reduced.
Credit Risk: Credit risk can be a factor in situations where an investment’s performance relies on a
borrower’s repayment of borrowed funds. With credit risk, an investor can experience a loss or
unfavorable performance if a borrower does not repay the borrowed funds as expected or required.
Investment holdings that involve forms of indebtedness (i.e., borrowed funds) are subject to credit
risk.
Currency Risk: Fluctuations in the value of the currency in which your investment is denominated
may affect the value of your investment and thus, your investment may be worth more or less in the
future. All currency is subject to swings in valuation and thus, regardless of the currency
denomination of any particular investment you own, currency risk is a realistic risk measure. That
said, currency risk is generally a much larger factor for investment instruments denominated in
currencies other than the most widely used currencies (U.S. dollar, British pound, German mark,
Euro, Japanese yen, French franc, etc.).
Economic Risk: The prevailing economic environment is important to the health of all businesses.
Some companies, however, are more sensitive to changes in the domestic or global economy than
others. These types of companies are often referred to as cyclical businesses. Countries in which a
large portion of businesses are in cyclical industries are thus also very economically sensitive and
carry a higher amount of economic risk. If an investment is issued by a party located in a country that
experiences wide swings from an economic standpoint or in situations where certain elements of an
investment instrument are hinged on dealings in such countries, the investment instrument will
generally be subject to a higher level of economic risk.
Equity (Stock) Market Risk: Common stocks are susceptible to general stock market fluctuations
and to volatile increases and decreases in value as market confidence in and perceptions of their
issuers change. If you held common stock, or common stock equivalents, of any given issuer, you
would generally be exposed to greater risk than if you held preferred stocks and debt obligations of
the issuer.
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ETF & Mutual Fund Risk: When investing in an ETF or mutual fund, you will bear additional
expenses based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including
the potential duplication of management fees. The risk of owning an ETF or mutual fund generally
reflects the risks of owning the underlying securities the ETF or mutual fund holds. Clients will also
incur brokerage costs when purchasing ETFs.
Financial Risk: Financial risk is represented by internal disruptions within an investment or the
issuer of an investment that can lead to unfavorable performance of the investment. Examples of
financial risk can be found in cases like Enron or many of the dot com companies that were caught
up in a period of extraordinary market valuations that were not based on solid financial footings of
the companies.
Fixed Income Securities Risk: Typically, the values of fixed-income securities change inversely with
prevailing interest rates. Therefore, a fundamental risk of fixed-income securities is interest rate risk,
which is the risk that their value will generally decline as prevailing interest rates rise, which may
cause your account value to likewise decrease, and vice versa. How specific fixed income securities
may react to changes in interest rates will depend on the specific characteristics of each security.
Fixed-income securities are also subject to credit risk, prepayment risk, valuation risk, and liquidity
risk. Credit risk is the chance that a bond issuer will fail to pay interest and principal in a timely
manner, or that negative perceptions of the issuer’s ability to make such payments will cause the
price of a bond to decline.
Inflation Risk: Inflation risk involves the concern that in the future, your investment or proceeds
from your investment will not be worth what they are today. Throughout time, the prices of resources
and end-user products generally increase and thus, the same general goods and products today will
likely be more expensive in the future. The longer an investment is held, the greater the chance that
the proceeds from that investment will be worth less in the future than what they are today. Said
another way, a dollar tomorrow will likely get you less than what it can today.
Interest Rate Risk: Certain investments involve the payment of a fixed or variable rate of interest to
the investment holder. Once an investor has acquired or has acquired the rights to an investment that
pays a particular rate (fixed or variable) of interest, changes in overall interest rates in the market
will affect the value of the interest-paying investment(s) they hold. In general, changes in prevailing
interest rates in the market will have an inverse relationship to the value of existing, interest paying
investments. In other words, as interest rates move up, the value of an instrument paying a particular
rate (fixed or variable) of interest will go down. The reverse is generally true as well.
Legal/Regulatory Risk: Certain investments or the issuers of investments may be affected by
changes in state or federal laws or in the prevailing regulatory framework under which the
investment instrument or its issuer is regulated. Changes in the regulatory environment or tax laws
can affect the performance of certain investments or issuers of those investments and thus, can have
a negative impact on the overall performance of such investments.
Liquidity Risk: Certain assets may not be readily converted into cash or may have a very limited
market in which they trade. Therefore, you may experience the risk that your investment or assets
within your investment may not be able to be liquidated quickly, thus, extending the period of time
by which you may receive the proceeds from your investment. Liquidity risk can also result in
unfavorable pricing when exiting (i.e., not being able to quickly get out of an investment before the
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Fidato Wealth LLC
price drops significantly) a particular investment and therefore, can have a negative impact on
investment returns.
Market Risk: The value of your portfolio may decrease if the value of an individual company or
multiple companies in the portfolio decreases or if our belief about a company’s intrinsic worth is
incorrect. Further, regardless of how well individual companies perform, the value of your portfolio
could also decrease if there are deteriorating economic or market conditions. It is important to
understand that the value of your investment may fall, sometimes sharply, in response to changes in
the market, and you could lose money. Investment risks include price risk as may be observed by a
drop in a security’s price due to company specific events (e.g., earnings disappointment or
downgrade in the rating of a bond) or general market risk (e.g. such as a “bear” market when stock
values fall in general). For fixed-income securities, a period of rising interest rates could erode the
value of a bond since bond values generally fall as bond yields go up. Past performance is not a
guarantee of future returns.
Material, Significant or Unusual Risks: We generally invest client’s cash balances in money market
funds, FDIC Insured Certificates of Deposit, high-grade commercial paper and/or government backed debt
instruments. Ultimately, we try to achieve the highest return on our client’s cash balances through relatively
low-risk conservative investments. In most cases, at least a partial cash balance will be maintained in a
money market account so that our firm may debit advisory fees for our services related to Asset
Management service.
Item 9: Disciplinary Information
There are no legal or disciplinary events that are material to the evaluation of our advisory business
or the integrity of our management.
Item 10: Other Financial Industry Activities & Affiliations
Fidato Wealth LLC is also a licensed insurance agency in the State of Ohio, through which Anthony
D’Amico, founder & CEO, is a licensed insurance agent, and in such capacity, may recommend, on a
commission basis, the purchase of certain fixed insurance products. Fixed insurance products such
as Life Insurance, Long Term Care, or Disability Insurance are used when it is part of the client’s
comprehensive financial plan, when they desire risk protection, and when these risk protection
strategies promote the client’s goals and best interests. A conflict of interest exists to the extent that
our firm recommends the purchase of insurance products where Mr. D’Amico receives insurance
commissions or other additional compensation. He spends less than 5% of his time on these
activities. Our firm’s clients are never under any obligation to purchase insurance products from
Fidato Wealth LLC in its separate capacity as an insurance agency, or from Mr. D’Amico in his capacity
as a licensed insurance agent.
Our firm is not, nor does it have management persons that are registered as a broker-dealer,
registered representative of a broker dealer, a futures commission merchant, commodity pool
operator, a commodity trading advisor, or an associated person of the foregoing entities.
Item 11: Code of Ethics, Participation, or Interest in
Client Transactions & Personal Trading
We recognize that the personal investment transactions of members and employees of our firm demand
the application of a high Code of Ethics and require that all such transactions be carried out in a way that
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Fidato Wealth LLC
does not endanger the interest of any client. At the same time, we believe that if investment goals are
similar for clients and for members and employees of our firm, it is logical and even desirable that there
be common ownership of some securities.
Therefore, in order to prevent conflicts of interest, we have in place a set of procedures (including a pre-
clearing procedure) with respect to transactions effected by our members, officers and employees for
their personal accounts1. In order to monitor compliance with our personal trading policy, we have a
quarterly securities transaction reporting system for all of our associates.
Furthermore, our firm has established a Code of Ethics which applies to all of our associated persons. An
investment adviser is considered a fiduciary. As a fiduciary, it is an investment adviser’s responsibility
to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our
clients at all times. We have a fiduciary duty to all clients. Our fiduciary duty is considered the core
underlying principle for our Code of Ethics which also includes Insider Trading and Personal Securities
Transactions Policies and Procedures. We require all of our supervised persons to conduct business with
the highest level of ethical standards and to comply with all federal and state securities laws at all times.
Upon employment or affiliation and at least annually thereafter, all supervised persons will sign an
acknowledgement that they have read, understand, and agree to comply with our Code of Ethics. Our
firm and supervised persons must conduct business in an honest, ethical, and fair manner and avoid all
circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients.
This disclosure is provided to give all clients a summary of our Code of Ethics. If a client or a potential
client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon request.
Neither our firm nor a related person recommends to clients, or buys or sells for client accounts,
securities in which our firm or a related person has a material financial interest.
Related persons of our firm may buy or sell securities and other investments that are also recommended
to clients. In order to minimize this conflict of interest, our related persons will place client interests
ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon
request.
Related persons of our firm may buy or sell securities for themselves at or about the same time they buy
or sell the same securities for client accounts. In order to minimize this conflict of interest, our related
persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a
copy of which is available upon request. When possible, our firm will trade client and related persons’
accounts in block trades. If related persons’ accounts are included in a block trade, our related persons
will always trade personal accounts last. When block trades cannot be completed, our related persons
will refrain from buying or selling for themselves the same securities transacted by a client until all client
transactions have been completed for the business day.
Item 12: Brokerage Practices
Custodian & Brokers Used
Our firm does not maintain custody of client assets (although our firm may be deemed to have
custody of client assets if given the authority to withdraw assets from client accounts. See Item 15
Custody, below). Client assets must be maintained in an account at a “qualified custodian,” generally
1 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse,
his/her minor children, or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our
associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect
beneficial interest in.
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a broker-dealer or bank. Our firm recommends that clients use the Schwab Advisor Services division
of Charles Schwab & Co. Inc. (“Schwab”), a FINRA-registered broker-dealer, member SIPC, as the
qualified custodian. Our firm is independently owned and operated, and not affiliated with Schwab.
Schwab will hold client assets in a brokerage account and buy and sell securities when instructed.
While our firm recommends that clients use Schwab as custodian/broker, clients will decide whether
to do so and open an account with Schwab by entering into an account agreement directly with them.
Our firm does not open the account. Even though the account is maintained at Schwab, our firm can
still use other brokers to execute trades, as described in the next paragraph.
How Brokers/Custodians Are Selected
Our firm seeks to recommend a custodian/broker who will hold client assets and execute
transactions on terms that are overall most advantageous when compared to other available
providers and their services. A wide range of factors are considered, including, but not limited to:
•
•
•
combination of transaction execution services along with asset custody services (generally
without a separate fee for custody)
capability to execute, clear and settle trades (buy and sell securities for client accounts)
capabilities to facilitate transfers and payments to and from accounts (wire transfers, check
requests, bill payment, etc.)
• breadth of investment products made available (stocks, bonds, mutual funds, exchange
traded funds (ETFs), etc.)
• availability of investment research and tools that assist in making investment decisions
• quality of services
•
competitiveness of the price of services (commission rates, margin interest rates, other fees,
etc.) and willingness to negotiate them
reputation, financial strength and stability of the provider
•
• prior service to our firm and our other clients
• availability of other products and services that benefit our firm, as discussed below (see
“Products & Services Available from Schwab”)
Custody & Brokerage Costs
Schwab generally does not charge a separate fee for custody services, but is compensated by charging
commissions or other fees to clients on trades that are executed or that settle into the Schwab
account. For some accounts, Schwab may charge a percentage of the dollar amount of assets in the
account in lieu of commissions. Schwab’s commission rates and/or asset-based fees applicable to
client accounts were negotiated based on our firm’s commitment to maintain a minimum threshold
of assets across all our client accounts at Schwab. This commitment benefits clients because the
overall commission rates and/or asset-based fees paid are lower than they would be if our firm had
not made the commitment. In addition to commissions or asset-based fees, Schwab charges a flat
dollar amount as a “prime broker” or “trade away” fee for each trade that our firm has executed by a
different broker-dealer but where the securities bought or the funds from the securities sold are
deposited (settled) into a Schwab account. These fees are in addition to the commissions or other
compensation paid to the executing broker-dealer. Because of this, in order to minimize client trading
costs, our firm has Schwab execute most trades for the accounts.
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Products & Services Available from Schwab
Schwab Advisor Services is Schwab’s business serving independent investment advisory firms like
our firm. They provide our firm and clients with access to its institutional brokerage – trading,
custody, reporting and related services – many of which are not typically available to Schwab retail
customers. Schwab also makes available various support services. Some of those services help
manage or administer our client accounts while others help manage and grow our business. Schwab’s
support services are generally available on an unsolicited basis (our firm does not have to request
them) and at no charge to our firm. The availability of Schwab’s products and services is not based
on the provision of particular investment advice, such as purchasing particular securities for clients.
Here is a more detailed description of Schwab’s support services:
Services that Benefit Clients
Schwab’s institutional brokerage services include access to a broad range of investment products,
execution of securities transactions, and custody of client assets. The investment products available
through Schwab include some to which our firm might not otherwise have access or that would
require a significantly higher minimum initial investment by firm clients. Schwab’s services
described in this paragraph generally benefit clients and their accounts.
Services that May Not Directly Benefit Clients
Schwab also makes available other products and services that benefit our firm but may not directly
benefit clients or their accounts. These products and services assist in managing and administering
our client accounts. They include investment research, both Schwab’s and that of third parties. This
research may be used to service all or some substantial number of client accounts, including accounts
not maintained at Schwab. In addition to investment research, Schwab also makes available software
and other technology that:
• provides access to client account data (such as duplicate trade confirmations and account
statements);
facilitates trade execution and allocate aggregated trade orders for multiple client accounts;
facilitates payment of our fees from our clients’ accounts; and
•
• provides pricing and other market data;
•
• assists with back-office functions, recordkeeping and client reporting.
Services that Generally Benefit Only Our Firm
Schwab also offers other services intended to help manage and further develop our business
enterprise. These services include:
technology, compliance, legal, and business consulting;
• educational conferences and events;
•
• publications and conferences on practice management and business succession; and
• access to employee benefits providers, human capital consultants and insurance providers.
Schwab may provide some of these services itself. In other cases, Schwab will arrange for third-party
vendors to provide the services to our firm. Schwab may also discount or waive fees for some of these
services or pay all or a part of a third party’s fees. Schwab may also provide our firm with other
benefits, such as occasional business entertainment for our personnel.
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Irrespective of direct or indirect benefits to our client through Schwab, our firm strives to enhance
the client experience, help clients reach their goals and put client interests before that of our firm or
associated persons.
Our Interest in Schwab’s Services.
The availability of these services from Schwab benefits our firm because our firm does not have to
produce or purchase them. Our firm does not have to pay for these services, and they are not
contingent upon committing any specific amount of business to Schwab in trading commissions or
assets in custody.
In light of our arrangements with Schwab, a conflict of interest exists as our firm may have incentive
to require that clients maintain their accounts with Schwab based on our interest in receiving
Schwab’s services that benefit our firm rather than based on client interest in receiving the best value
in custody services and the most favorable execution of transactions. 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 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.
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
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. Our firm believes that the selection of Schwab as a custodian and broker is in the best
interest of our clients. It is primarily supported by the scope, quality and price of Schwab’s services,
and not Schwab’s services that only benefit our firm.
Soft Dollars
Our firm does not accept products or services that do not qualify for Safe Harbor outlined in Section
28(e) of the Securities Exchange Act of 1934, such as those services that do not aid in investment
decision-making or trade execution. The qualifying products and/or services will be used to service
all of our clients.
Brokerage for Client Referrals
Our firm does not receive brokerage for client referrals.
Directed Brokerage
Neither we nor any of our firm’s related persons have discretionary authority in making the
determination of the brokers with whom orders for the purchase or sale of securities are placed for
execution, and the commission rates at which such securities transactions are affected.
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Fidato Wealth LLC
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, we 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.
Aggregation of Purchase or Sale
We perform investment management services for various clients. There are occasions on which
portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same
security for numerous accounts served by our firm, which involve accounts with similar investment
objectives. Although such concurrent authorizations potentially could be either advantageous or
disadvantageous to any one or more particular accounts, they are affected only when we believe that to
do so will be in the best interest of the affected accounts. When such concurrent authorizations occur,
the objective is to allocate the executions in a manner which is deemed equitable to the accounts
involved. In any given situation, we attempt to allocate trade executions in the most equitable manner
possible, taking into consideration client objectives, current asset allocation and availability of funds
using price averaging, proration, and consistently non-arbitrary methods of allocation.
Item 13: Review of Accounts or Financial Plans
Asset Management and Third-Party Money Management client accounts are reviewed on at least a
quarterly basis. The nature of these reviews is to learn whether clients’ accounts are in line with their
investment objectives, appropriately positioned based on market conditions, and investment
policies, if applicable. We provide Quarterly Portfolio Overview reports to all of our Asset
Management clients. Verbal reports to clients take place on at least an annual basis when we meet
with clients who subscribe to our Asset Management and Third-Party Money Management service.
We may review client accounts more frequently than described above. Among the factors which may
trigger an off-cycle review are major market or economic events, the client’s life events, requests by
the client, etc.
Financial planning clients receive reviews of their financial plans during their annual review meeting
they schedule with us. We do provide ongoing financial planning recommendations to financial
planning clients. These ongoing financial planning services are based upon mutually identified and
prioritized financial planning priorities. Some priorities are fully implemented by the clients
themselves, and certain priorities may be jointly worked on by the client and the advisor. Financial
planning clients will receive written or verbal updates regarding the status and progress of their
financial planning priorities.
Retirement Plan Consulting clients receive reviews of their retirement plans for the duration of the
service. Our firm also provides ongoing services where we meet clients 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.
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Fidato Wealth LLC
Item 14: Client Referrals & Other Compensation
Charles Schwab & Co., Inc.
Our firm receives economic benefits from Schwab in the form of the support products and services
made available to our firm and other independent investment advisors that have their clients
maintain accounts at Schwab. These products and services, how they benefit our firm, and the related
conflicts of interest are described above (see Item 12 – Brokerage Practices). The availability of
Schwab’s products and services is not based on our firm giving particular investment advice, such as
buying particular securities for our clients.
Referral Fees
In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm does not provide
cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or
endorsements (which include client referrals).
Item 15: Custody
Our firm has limited custody of client funds or securities because our firm directly debits client’s
managed accounts. All of our clients receive account statements directly from their custodians at
least quarterly upon opening of an account. If our firm decides to send account invoices to clients,
such notices and invoices include a legend that recommends the client compare the account
statements received from the custodian with the invoices received from our firm. Clients are
encouraged to raise any questions with us about the custody, safety or security of their assets and
our custodial recommendations.
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 instruction (“SLOA”) is deemed to have custody. As
such, our firm has adopted the following safeguards in conjunction with our custodian:
• 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.
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Fidato Wealth LLC
• 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 clients need to sign a discretionary investment advisory agreement with our firm for the
management of their account. This type of agreement only applies to our Asset Management clients.
We do not take or exercise discretion with respect to our other clients.
Item 17: Voting Client Securities
We do not and will not accept the proxy authority to vote client securities. Clients will receive proxies
or other solicitations directly from their custodian or a transfer agent. In the event that proxies are
sent to our firm, we will forward them on to you and ask the party who sent them to mail them
directly to you in the future. Clients may call, write, or email us to discuss questions they may have
about particular proxy votes or other solicitations.
Third party money managers selected or recommended by our firm may vote proxies for clients.
Therefore, except in the event a third party money manager votes proxies, clients maintain exclusive
responsibility for: (1) directing the manner in which proxies solicited by issuers of securities
beneficially owned by the client shall be voted, and (2) making all elections relative to any mergers,
acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s
investment assets. Therefore (except for proxies that may be voted by a third-party money manager),
our firm and/or the client shall instruct the qualified custodian to forward copies of all proxies and
shareholder communications relating to the client’s investment assets.
Item 18: Financial Information
We are not required to provide financial information in this Brochure because we do not require the
prepayment of more than $1,200 in fees per client six or more months in advance and we do 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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Fidato Wealth LLC