View Document Text
CRD #122309
FIRM BROCHURE
FORM ADV PART 2A
100 N. Westlake Blvd., Suite 201
Westlake Village, CA 91362
805.446.4494 Phone
805.446.4499 Fax
www.fmbwealth.com
Dated: February 12, 2026
ITEM 1 – COVER PAGE
This ADV Part 2A Firm Brochure provides information about the qualifications and advisory business
practices of FMB Wealth Management (“FMBWM”). FMBWM is a Registered Investment Advisor with the
United States Securities and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940, as
amended (the “Advisers Act”). However, such registration of an investment advisor does not imply any
level of skill or training. If you have any questions about the contents of this brochure, please contact us at
(805) 446‐4494 or by email at info@fmbwealth.com.
The information contained in this brochure has not been approved or verified by the SEC or by any state
securities regulatory authority.
Additional information about FMB Wealth Management (CRD# 122309) is also available on the SEC’s
website at www.Adviserinfo.sec.gov.
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
1
ITEM 2 – MATERIAL CHANGES
Annual Update
This Brochure dated February 12, 2026 is our amended and most current Brochure, retiring our
prior Brochure dated March 28, 2025.
Material Changes Since the Last Update
This section is intended to point out any material changes that have been made to our business
and in this ADV Part 2A Disclosure Brochure since our prior Brochure, and to provide you with a
summary of those material changes. We must state clearly that we are discussing only material
changes since the last update of our Brochure.
Since our prior Form ADV Part 2A Firm Disclosure Brochure there have been no material changes
to FMB’s business.
Full Brochure Available
If you are receiving this information as a summary disclosure page, you may receive a complete
copy of our firm’s Brochure by contacting us by telephone at (805) 446‐4494 or by email at
info@fmbwealth.com.
Please review this Form ADV Part 2A Disclosure Brochure carefully for other important
disclosures and information describing our firm and services we offer.
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
2
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............................................................................................................ 5
A. Advisor Background ...................................................................................................................... 5
B. Management and Advisory Personnel ........................................................................................ 5
C. Use of Professional Designations: ...................................................................................................... 9
D. Advisory Services .............................................................................................................................. 13
E. Client Needs ........................................................................................................................................ 13
F. Wrap Programs ................................................................................................................................... 13
G. Client Assets Under Management................................................................................................... 14
ITEM 5 – FEES AND COMPENSATION ............................................................................................ 15
A. Compensation for Advisory Services ........................................................................................ 15
Billing Method .............................................................................................................................. 15
B.
C. Other Fees and Expenses ............................................................................................................. 15
D.
Termination ................................................................................................................................... 16
E. Additional Compensation ........................................................................................................... 16
ITEM 6 – PERFORMANCE FEES ......................................................................................................... 17
ITEM 7 ‐ TYPES OF CLIENTS ............................................................................................................... 18
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES & RISK OF LOSS .............. 19
A. Methods of Analysis .................................................................................................................... 19
Investment Strategies ................................................................................................................... 19
B.
Risk of Loss ................................................................................................................................... 20
C.
D. Using Sub‐Advisors ......................................................................................................................... 21
E. Sources of Information ...................................................................................................................... 21
Risks of Specific Securities Utilized ........................................................................................... 21
F.
G. Margin Disclosure Statement ..................................................................................................... 22
ITEM 9 – DISCIPLINARY ACTION..................................................................................................... 23
ITEM 10 ‐ OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ....................... 24
ITEM 11 – CODE OF ETHICS: PARTICIPATION OR INTEREST IN CLIENT TRANS‐ ACTIONS
AND PERSONAL TRADING ............................................................................................................... 25
Participation/Interest in Client Transactions ............................................................................ 26
A.
B.
Insider Trading Policy ................................................................................................................. 26
ITEM 12 – BROKERAGE PRACTICES ................................................................................................ 28
Best Execution ............................................................................................................................... 28
A.
Research and Other Soft‐Dollar Benefits .................................................................................. 28
B.
Brokerage for Client Referrals .................................................................................................... 29
C.
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
3
ITEM 13 – REVIEW OF ACCOUNTS .................................................................................................. 30
Individual Portfolio Management ........................................................................................................ 30
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION .............................................. 31
Referrals, Endorsements and Promoters................................................................................... 31
A.
Employee Bonus Compensation ................................................................................................ 31
B.
C.
Client Gifts .................................................................................................................................... 32
ITEM 15 ‐ CUSTODY .............................................................................................................................. 33
ITEM 16 ‐ INVESTMENT DISCRETION ............................................................................................. 34
ITEM 17 – VOTING CLIENT SECURITIES ......................................................................................... 35
ITEM 18 – FINANCIAL INFORMATION ........................................................................................... 36
PRIVACY POLICY NOTICE ................................................................................................................. 37
Business Continuity and Disaster Recovery Plan .............................................................................. 40
Client Disclosure Notice ........................................................................................................................ 40
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
4
ITEM 4 – ADVISORY BUSINESS
A. Advisor Background
FMB Wealth Management (“FMBW M”) was founded in 1994 as Fields Financial Associates and
incorporated as Fields Financial Associates, Inc. in 2001. An amendment was filed in 2008
changing the name of the corporation to FMB Wealth Management (FMBWM).
FMBWM is a privately‐owned Registered Investment Advisor (RIA) registered with the U.S.
Securities and Exchange Commission (SEC) under the Investment Advisor’s Act of 1940, as
amended since 2001. FMBWM’s principal office is located in Westlake Village, California.
FMBWM’s principal majority shareholder and owner is Debra A. Fields, CFP®. Grant Blindbury,
CFP®, Jeremy J. Fields, CFP®, David Howerton and Daniel Mock, CFP® are minority shareholders.
FMBWM and its investment advisor representatives (“IARs”) are considered “fiduciaries” and as
such, provide investment advice in the best interests of their clients as part of their fiduciary duty
of care, and the industry’s impartial conduct standards.
B. Management and Advisory Personnel
Debra A. Fields, CFP®
Year of Birth: 1958
Designations: CFP® (Certified Financial Planner™)
Education: BA French/Business, University of Redlands, 1980
CFP® Certified Financial Planning Board of Standards, 1987
FMB Wealth Management
Business
Background: President, CFO, Secretary; 2018 – present Secretary, Treasurer, and Director; 2001 ‐
present
FMB Retirement Services
President, CFO, Secretary; 2018 – present Secretary, Treasurer and Director; 2012 –
present
FMB Insurance Services
President, Secretary; 2018 – present
Secretary, Treasurer and Director; 2016 – present
Reportable Ms. Fields has not been involved in a disclosure event where she was found
Disclosures:
liable in any civil, self‐regulatory organization, or administrative proceeding; and
has not been the subject of a bankruptcy petition.
Other Business
Activities:
Debra A. Fields does not have any other business activities other than
administrative management of FMBWM’s related advisor, FMB Retirement
Services and FMBWM’s related insurance agency, FMB Insurance Services.
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
5
Grant E. Blindbury, CFP®
Year of Birth: 1979
Designations: CFP® (Certified Financial Planner™)
Licenses:
NASAA Uniform Combined State Law Examination (Series 66) California Life,
Health and Disability Insurance licensed
Education:
BA Business, UCLA, 2001
CFP® Certified Financial Planning Board of Standards, 2008
FMB Wealth Management, 2001 ‐ present
Business
Background: Partner, Director, Investment Advisor Representative
FMB Retirement Services, 2012 ‐ present
Partner, Director, Investment Advisor Representative
Reportable Mr. Blindbury has not been involved in a disclosure event where he was found
Disclosures:
liable in any civil, self‐regulatory organization, or administrative proceeding; and
has not been the subject of a bankruptcy petition.
Other Business
Activities:
Grant E. Blindbury is licensed to sell insurance products in the State of California
and could receive insurance commissions for doing so. Mr. Blindbury is a Director,
Partner and IAR with FMBWM’s affiliated Advisor through common ownership,
FMB Retirement Services (“FMBRS”).
Mr. Blindbury reports directly to Debra Fields for all FMBWM business. You may contact Ms.
Fields at (805) 446‐4494.
Jeremy J. Fields, CFP®, AIF®, FBS®, RF™
Year of Birth: 1988
Designations: CFP® (Certified Financial Planner™)
AIF® (Accredited Investment Fiduciary)
RF™ (Registered Fiduciary)
FBS® (Certified Financial Behavior Specialist)
Licenses:
NASAA Uniform State Investment Advisor Law Exam (Series 65) California Life,
Health and Disability Insurance licensed
Education:
BS Business Administration, University of San Diego, 2010
CFP® Certified Financial Planning Board of Standards, 2016
Business
FMB Wealth Management
Background: Partner, Investment Advisor Representative; 2012 ‐ present
FMB Retirement Services
Managing Director, Investment Advisor Representative; 2012 ‐ present
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
6
FMB Insurance Services
Chief Financial Officer; 2018 ‐ present
Reportable
Disclosures:
Jeremy J. Fields has not been involved in a disclosure event where he was found
liable in any civil, self‐regulatory organization, or administrative proceeding; and
has not been the subject of a bankruptcy petition.
Other Business
Activities:
Jeremy J. Fields is also a Director, Partner and IAR with FMBWM’s affiliated
Advisor through common ownership, FMB Retirement Services (“FMBRS”). Mr.
Fields is licensed to sell insurance products in the State of California and could
receive insurance commissions for doing so.
Jeremy J. Fields reports directly to Debra Fields for all FMBWM business. You may contact Ms.
Fields at (805) 446‐4494.
Daniel L. Mock, CFP®, M.S.
Year of Birth: 1991
Designations: CFP® (Certified Financial Planner™)
M.S. (Masters of Science)
Licenses:
NASAA Uniform State Investment Adviser Law Exam (Series 65) California Life,
Health and Disability Insurance licensed
Education:
B.A. Economics, California Lutheran University, 2013
B.A. Political Science, California Lutheran University 2013
Masters of Science (M.S.), Quantitative Economics, California Lutheran University,
2014
CFP® Certified Financial Planning Board of Standards, 2016
FMB Wealth Management
Business
Background: Partner, Investment Advisor Representative; 8/2014 ‐ Present
FMB Retirement Services
Investment Advisor Representative; 8/2014 – Present
Reportable Daniel Mock has not been involved in any disclosure event where he was found
Disclosures:
liable in an arbitration claim alleging damages in excess of $2,500, or found liable in
a civil, self-regulatory organization, or administrative proceeding; and has not been
the subject of a bankruptcy petition.
Other Business
Activities: Mr. Mock is a registered IAR employee with FMBWM’s affiliated RIA under
common ownership, FMB Retirement Services (“FMBRS”). Mr. Mock is also
licensed to sell insurance products in the State of California and could receive
insurance commissions for doing so.
Daniel Mock reports directly to Debra Fields for all FMBWM business. You may contact Ms. Fields
at (805) 446‐4494.
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
7
Andrew J. Miller, CRPS®
Year of birth: 1979
Designations: CRPS® (Chartered Retirement Plans Specialist)
Licenses:
NASAA Uniform State Investment Adviser Law Exam (Series 65) California Life,
Health and Disability Insurance licensed
Education:
Bachelor of Science in Kinesiology, California State University, Northridge, 2003
FMB Wealth Management
Business
Background: Investment Advisor Representative; 8/2016 – Present
FMB Retirement Services
Investment Advisor Representative; 1/2020 – Present
Reportable Andrew J. Miller has not been involved in any disclosure event where he was found
liable in an arbitration claim, or found liable in a civil, self‐regulatory organization,
Disclosures:
or administrative proceeding, and has not been the subject of a bankruptcy petition.
Other Business
Activities:
Mr. Miller is a registered IAR employee with FMBWM’s affiliated RIA under
common ownership, FMB Retirement Services (“FMBRS”). Mr. Miller is also licensed
to sell insurance products in the State of California and could receive insurance
commissions for doing so.
Andrew J. Miller reports directly to Debra Fields for all FMBWM business. You may contact Ms.
Fields at (805) 446‐4494.
Jake L. Berman, MBA
Year of birth: 1995
Licenses:
NASAA Uniform State Investment Adviser Law Exam (Series 65)
Education:
Bachelor of Science in Business Administration, California State University Channel
Islands, May 2017
Master of Business Administration (MBA), May 2022
Business
FMB Wealth Management
Background: Director of Advisor Services ; 4/2021 – Present
FMB Wealth Management
Wealth Management Coordinator; 8/2018 – 4/2021
FMB Retirement Services
Investment Advisor Representative; 3/2023 ‐ Present
Reportable Mr. Berman has not been involved in any disclosure event where he was found
Disclosures:
liable in an arbitration claim, or found liable in a civil, self‐regulatory organization,
or administrative proceeding; and has not been the subject of a bankruptcy petition.
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
8
Other Business
Activities: Mr. Berman is a registered IAR employee with FMBWM’s affiliated RIA under
common ownership, FMB Retirement Services (“FMBRS”).
Jake Berman reports directly to Debra Fields for all FMBWM business. You may contact Ms. Fields
at (805) 446‐4494.
David R. Howerton, IACCP®
Year of birth: 1961
Designations: IACCP® (The Investment Advisor Certified Compliance Professional®)
information about the IACCP designation can be
Mr. Howerton is certified as an Investment Advisor Certified Compliance Professional® or
IACCP®, and may use this certification mark. The IACCP certification is voluntary and is
sponsored by COMPLY and the Investment Adviser Association (IAA). No federal or state
law or regulation requires investment adviser compliance professionals to hold the IACCP
found at
designation. More
www.comply.com/services/education‐iaccp.
Licenses:
NASAA Uniform State Investment Adviser Law Exam (Series 65)
Education:
Bachelor of Arts, Management, Antioch University
FMB Wealth Management
Business
Background: Chief Operations Officer/Chief Compliance Officer; 7/2015 – Present
FMB Retirement Services
Chief Operations Officer/Chief Compliance Officer; 7/2015 ‐ Present
Reportable David Howerton has not been involved in any disclosure event where he was found
liable in an arbitration claim, or found liable in a civil, self‐regulatory organization,
Disclosures:
or administrative proceeding, and has not been the subject of a bankruptcy petition.
Other Business
Activities:
Mr. Howerton is the Chief Operations Officer, Chief Compliance Officer, and
registered IAR employee with FMBWM’s affiliated RIA under common ownership,
FMB Retirement Services (“FMBRS”).
David Howerton reports directly to Debra Fields for all FMBWM business. You may contact Ms.
Fields at (805) 446‐4494.
C. Use of Professional Designations:
Certified Financial Planner™ (CFP®). The Certified Financial Planner™ and federally registered
“CFP” marks (collectively, the “CFP® marks”) are professional certification marks granted in the
United States by Certified Financial Planner Board of Standards, Inc. (“CFP® Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires
financial planners to hold CFP® certification. It is recognized in the United States and a number of
other countries for its (1) high standard of professional education; (2) stringent code of conduct
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
9
and standards of practice; and (3) ethical requirements that govern professional engagements with
clients. Currently, more than 62,000 individuals have obtained CFP® certification in the United
States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following
requirements:
Education – Complete an advanced college‐level course of study addressing the
financial planning subject areas that CFP® Board’s studies have determined as
necessary for the competent and professional delivery of financial planning services and
attain a bachelor’s degree from a regionally accredited United States college or
university (or its equivalent from a foreign university). CFP® Board’s financial planning
subject areas include insurance planning and risk management, employee benefits
planning, investment planning, income tax planning, retirement planning, and estate
planning;
Examination – Pass the comprehensive CFP® Certification Examination. The
examination, administered in 10 hours over a two‐day period, includes case studies
and client scenarios designed to test one’s ability to correctly diagnose financial
planning issues and apply one’s knowledge of financial planning to real world
circumstances;
Experience – Complete at least three years of full‐time financial planning‐related
experience (or the equivalent, measured as 2,000 hours per year); and
Ethics – Agree to be bound by CFP® Board’s Standards of Professional Conduct, a set of
documents outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics
requirements to maintain the right to continue to use the CFP® marks:
Continuing Education – Complete 30 hours of continuing education hours every two
years, including two hours on the Code of Ethics and other parts of the Standards of
Professional Conduct, to maintain competence and keep up with developments in the
financial planning field; and
Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The
Standards prominently require that CFP® professionals provide financial planning
services at a fiduciary standard of care. This means CFP® professionals must provide
financial planning services in the best interests of their clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject
to CFP® Board’s enforcement process, which could result in suspension or permanent revocation
of their CFP® certification.
Accredited Investment Fiduciary (AIF®). The AIF® (Accredited Investment Fiduciary®)
professional designation is the first and only designation that demonstrates knowledge and
competency in the area of fiduciary responsibility. With the media awash with stories of financial
scandals, investors are demanding that investment advisors embrace a higher standard of practice
than ever before. The AIF® professional designation and certification is issued by the Center for
Fiduciary Studies, and the training is the best way for investment fiduciaries and professionals to
absorb the Prudent Practices, their legal underpinnings and how to apply them within existing
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
10
fiduciary policies and procedures.
Holders of the AIF® mark have successfully completed this specialized program on investment
fiduciary standards and subsequently passed a comprehensive examination. To qualify for the
AIF® Designation, candidates must meet minimum criteria for Screening, Education and Training
standards, Professional Development standards, and Relevant Industry Experience standards.
The AIF® training concludes with an examination to apply for and earn the AIF® Designation. The
AIF® final exam is a proctored exam. The requirement for a proctor ensures the integrity of the
examination process as one of the high standards for earning the AIF® Designation.
Registered Fiduciary™ (RF™). The Registered Fiduciary™ (RF™) certification identifies financial
professionals that have achieved pertinent academic qualifications and licenses, learned required
practices and have passed a background check. The RF™ certification prepares a candidate to
comply with the regulatory requirements of acting as a fiduciary under current laws.
This fiduciary standard distinguishes RF™ designated professionals as having met the highest
standard in the financial industry. All valid certified RF™ are listed on the Registry of Fiduciary
Professionals. RF™ certifications are further defined by specialties. Each designee has one or more
specialties that identify the services that he/she/they is/are qualified to provide.
Chartered Retirement Plans Specialist (CRPS®). The Chartered Retirement Plans Specialist®
(CRPS®) designation is a credential for those who create, implement and maintain retirement
plans for businesses. Unlike most other professional financial planning and advisory professional
designations, the CRPS® focuses on wholesale and business clients. It is awarded by the College
for Financial Planning to individuals who pass an exam demonstrating their expertise. Every two
years, CRPS® professionals must complete 16 hours of continuing education and pay a nominal
fee to continue using the designation.
The Chartered Retirement Plans Specialist® program is a case‐study‐based, client‐centered
problem‐solving approach. The study program to become a CRPS® covers types and
characteristics of retirement plans, including IRAs, small business retirement plans, defined
contribution plans, nonprofit plans, 401(k) and 403(b) plans, and government plans.
Keeping up with changes to tax codes and other laws is important for a chartered retirement plans
specialist. For example, the passage of the Setting Every Community Up for Retirement
Enhancement (SECURE) Act in December 2019 brought forth some hefty changes to the
retirement industry. As of 2020, under the new law, the age for taking required minimum
distributions (RMDs) is no longer 70.5, but age 72. Then, a few years later, Congress passed the
SECURE 2.0 Act which increased the RMD age to 73. Being mindful of these changes as they occur
are central to the role of chartered retirement plans specialist.
Certified Financial Behavior Specialist® (FBS®). The Certified Financial Behavior Specialist®
(FBS®) designation is a professional certification mark for financial professionals providing
financial consulting services conferred by the Financial Psychology Institute®. To receive
authorization to use the marks, the candidate must meet specific educational and continuing
education requirements in the areas of behavioral finance and financial behavior.
Certification Requirements:
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
11
Bachelor’s Degree or higher from a Regionally Accredited Institute of higher learning
and/or a License, Registration, or Certification in financial planning, counseling, coaching,
mental health, or a related field.
Completion of a Certificate in Financial Psychology & Behavioral Finance or related field.
Agreement to adhere to the Financial Psychology Instituteʹs Code of Ethics.
20 Hours of CEUs in approved courses related to financial planning, financial behavior, or
a related field every 2 years, either through the Financial Psychology Institute® or other
approved providers.
Two letters of recommendation from professionals familiar with financial psychology or
financial therapy, and who are also familiar with your work.
Certificate holders include practicing financial planners, financial coaches, financial
counselors, and mental health practitioners who use the theories and tools of financial
behavior to provide more holistic services to clients, better understand financial beliefs and
behaviors, and work more effectively with individuals, couples, families, and organizations
around money.
By using the marks, the FBS® Certificant promises to adhere to the ethical standards guide as
defined in the Financial Psychology Instituteʹs Code of Ethics.
Investment Adviser Certified Compliance Professional. IACCP Designees have met high
standards for education, examination, experience, and agree to adhere to professional and ethical
standards. To become an IACCP Designee, an individual must fulfill the following requirements:
• Education: The IACCP Program coursework consists of 17 required compliance courses
and three electives. The courses are grouped into the following categories: the Advisers Act,
Disclosures, Trading, Mandates, Ethics, Skills, and Electives. All are two hours in length and
are available either live/in‐person or live/online.
• Examination: Pass the comprehensive IACCP Certifying Examination. The Examination
tests the candidateʹs knowledge of investment adviser regulations as well as industry best
practice, as presented in the IACCP education courses and material. This representation of
industry best practice is driven by compliance industry consensus and periodic job task
analysis, gained through subject matter experts with decades of experience in the
compliance field. The purpose of the IACCP Examination is to help ensure that investment
adviser compliance professionals have a minimum level of general foundation knowledge
related to applicable regulatory laws, rules, requirements, and certain best practices.
• Experience: Provide proof of a minimum of two years of work experience relating to
investment adviser compliance.
• Ethics: Complete an Ethics Assessment and agree to adhere to the IACCP Code of Ethics
and Professional Standards of Conduct.
Individuals who become certified as IACCP Designees must complete the following ongoing
education and ethics requirements to maintain the right to continue to use the IACCP designation.
• Continuing Education: Complete 12 professional continuing education (CE) credit hours
each year. Two (2) of the 12 credit hours must be earned by attending an approved ethics
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
12
program(s). The purpose of the IACCP Continuing Education Requirement is to ensure that
IACCP Designees maintain and enhance professional competence; maintain the IACCP
certification; review ethics and professional standards of conduct; remain current with
regulatory changes and trends; refresh investment adviser compliance knowledge; and
increase the level and depth of investment adviser knowledge. Credits can be earned by
attending qualified educational programs offered through COMPLY, IAA, or certain other
industry educational providers.
• Ethics: Commit to continued compliance with the IACCP Code of Ethics and Professional
Standards of Conduct.
Note: COMPLY and the Investment Adviser Association may change these requirements and will notify
candidates and designees of any changes.
D. Advisory Services
FMB Wealth Management provides wealth management services for individual and qualified
retirement plan clients. Wealth management is comprised of investment consulting, advanced
planning, and relationship management services. Investment consulting incorporates historical
portfolio performance analysis, risk evaluations, and asset allocation. Advanced planning involves
wealth enhancement (tax and cash‐flow planning), wealth transfer (transferring wealth
effectively), wealth protection (risk mitigation and transferring risk to insurance companies) and
charitable giving.
FMBWM uses passively managed index mutual funds and Exchange Traded Funds (ETF’s) from
various asset classes to achieve diversification. Many of the funds used are from Dimensional Fund
Advisors (DFA). Index funds from Vanguard, funds from PIMCO (formerly Gurtin Municipal
Bond Management), as well as listed Exchange Traded Funds (ETF’s), may also be used. These
funds are purchased and held at an institutional level custodian firm (Charles Schwab or Fidelity
Investments), or with another qualified retirement plan custodian.
For participant‐directed defined contribution pension plans held with qualified custodians,
FMBWM IARs will review and analyze all available investment options.
E. Client Needs
IARs conduct initial discovery meetings with each potential advisory client to discuss their
financial needs, personal goals, risk tolerance and overall investment objectives in depth. It is
beneficial to the client to provide accurate and candid information and promptly inform their IAR
of any material changes in their circumstances as soon as a change occurs so their IAR can re‐
evaluate their portfolio to see if adjustments to the advisory account portfolio are necessary. Clients
may impose restrictions on investing in certain securities or types of securities in most advisory
programs.
F. Wrap Programs
FMBWM and its associated IARs do not offer or participate in wrap fee programs.
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
13
G. Client Assets Under Management
As of December 31, 2025, our fiscal year end, FMB Wealth Management managed 958 accounts
representing $615,654,812 in clients regulatory assets under management on a discretionary
basis.
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
14
ITEM 5 – FEES AND COMPENSATION
A. Compensation for Advisory Services
FMBWM is compensated for advisory services by fees based on the value of the Client accounts at
the end of each calendar quarter. FMBWM’s general compensation schedule is as follows:
Value of Managed Accts
First $2.5 million
$2.5 million to $5 million
$5 million to $10 million
$10 million to $20 million
$20 million and over
Quarterly Fee
0.250%
0.200%
0.175%
0.125%
0.100%
Annualized Fee
1.00%
0.80%
0.70%
0.50%
0.40%
Advisory fees within FMBWM’s programs are negotiable.
FMBWM may provide certain fee‐based discounts, such as “family” group account discounts to
multiple accounts within a family or household. This discounted “family” rate varies and may be
based on total combined family assets under management.
B. Billing Method
Advisory Fees are payable quarterly in arrears. Payments are due and will be calculated on the
last day of each calendar quarter based on the value of the Account assets under management as
of the close of business on the last business day of that quarter as valued by the custodian.
The first payment will be assessed pro‐rata in the event the Agreement is executed at any time
other than the first day of the calendar quarter. The payment will be deducted from Clients’
accounts based on prior approval from the client as set forth in their specific client service
agreement.
In the event a client closes their account or authorizes an account transfer out, the last payment
will also be assessed pro‐rata in the event the account closing, or transfer is effected prior to the
calendar quarter end. The payment will also be deducted from clients’ accounts prior to
distribution or transfer in accordance with their executed FMB Client Agreements.
C. Other Fees and Expenses
No start‐up or account establishment fees are charged by FMBWM. The FMBWM advisory fees
are separate from any brokerage transaction fees, custodial fees, deferred sales charges, odd‐lot
differentials, transfer taxes, wire transfer and electronic fund transfer fees, and other related costs,
expenses and/or fees charged by the account’s third‐party custodians, brokers, third party money
managers and other third parties for brokerage accounts and securities transactions in non‐wrap
accounts. FMBWM and its IARs do not receive any portion of those fees.
Mutual Funds and Exchange Traded Funds (ETFs) charge internal management fees which are
disclosed in each of the individual fund’s prospectus. Program advisory fees do not include certain
charges such as 12b‐1 (marketing) fees paid by mutual funds held in clients’ account, which may
be retained by an IAR also acting as a registered representative of a broker‐dealer firm.
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
15
FMBWM IARs do not also act as registered representatives of a broker‐dealer firm. Therefore, no
12b‐1 fees may be received by an associated IAR with respect to any assets in a client account,
subject to the prohibited transaction rules of the Internal Revenue Code which are substantially
the same as ERISA. The 12b‐1 fees are included among normal mutual fund expenses and are fully
described and explained in the respective mutual fund prospectus.
D. Termination
In the event a client closes their account or authorizes an account transfer out, thereby terminating
their account, the last payment will be assessed pro‐rata, in arrears, in the event the account closing,
or transfer is effected prior to the calendar quarter end. The payment will be deducted from clients’
account prior to distribution or transfer, in accordance with their executed FMB Client
Agreements. The account custodian may charge a termination fee.
E. Additional Compensation
IARs/Supervised Persons registered with FMBWM may also be IARs/Supervised Persons with our
affiliated RIA, FMB Retirement Services (“FMBRS”). If IAR/Supervised Persons are registered with
one or both advisors, they may receive investment advisory fee compensation from that advisor.
Additionally, FMBWM IARs may receive insurance commissions when clients purchase insurance
products through them as independent insurance agents. Such insurance transactions are placed
directly through individual insurance companies, and compensation may be paid either directly
to insurance agent/IAR, or may be paid to FMBWM’s affiliated insurance agency, FMB Insurance
Services. In rare cases where an FMBWM IAR makes a recommendation to a FMBWM client to
purchase an insurance policy in the IAR’s capacity as an insurance agent, and the client accepts
the recommendation resulting in an insurance commission being paid to the IAR, the IAR will
waive offsetting advisory fees in the client’s FMBWM advisory account in the amount received
from the insurance company for the policy placement. This is done voluntarily by FMBWM to
minimize or eliminate the conflict of interest that exists when the IAR is acting in a dual capacity
of IAR with FMBWM and independent insurance agent. In no case will the IAR be compensated
for a commissionable transaction and also receive a fee for the same asset.
IF APPLICABLE:
ERISA Accounts: FMBWM is deemed to be a fiduciary to advisory clients that are employee
benefit plans or individual retirement accounts (IRAs) pursuant to the Employee Retirement
Income and Securities Act (“ERISA”). As such, our firm is subject to specific duties and obligations
under ERISA and the Internal Revenue Code that include among other things, restrictions
concerning certain forms of compensation. To avoid engaging in prohibited transactions, FMBWM
may only charge fees for investment advice about products for which our firm and/or our related
persons do not also receive any commissions or 12b‐1 fees.
Advisory Fees in General: Clients should note that similar advisory services may be available
from other registered (or unregistered) investment Advisors for similar or lower fees.
Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of fees in
excess of $500 more than six months in advance of services rendered.
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
16
ITEM 6 – PERFORMANCE FEES
FMBWM does not charge performance‐based fees or fees based on capital gains or capital
appreciation of client assets.
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
17
ITEM 7 ‐ TYPES OF CLIENTS
FMBWM provides wealth management services to individuals, high net worth individuals, trusts,
business owners, charitable organizations, and corporations. The minimum initial account size
managed by IARs through FMBWM is $1,000,000. The minimum account size requirement can be
waived by FMBWM at their discretion.
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
18
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES & RISK OF LOSS
A. Methods of Analysis
We use the following methods of analysis in formulating our investment advice and/or managing
client assets:
Long Term Diversified Asset Allocation. Rather than focusing primarily on securities selection, we
attempt to create an appropriate ratio of securities suitable to the client’s investment goals and risk
tolerance based on a modern portfolio theory funded primarily with passive index funds.
A risk of a long‐term diversified asset allocation is that the client may not participate in sharp
increases in a particular security, industry, or market sector. Another risk is that the ratio of
equities, fixed income, and cash will change over time due to stock and market movements and, if
not corrected, will no longer be appropriate for the client’s goals.
Passive Index Mutual Fund Analysis. We monitor the funds or ETFs to determine if they are
continuing to follow their stated investment strategy and to ensure that there has been no style
drift.
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 we do 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.
Risks for all forms of analysis. Our securities analysis methods rely on the assumption that the
companies whose securities we purchase and sell, the rating agencies that review these securities,
and other publicly available sources of information about these securities, are providing accurate
and unbiased data. While we are alert to indications that data may be incorrect, there is always a
risk that our analysis may be compromised by inaccurate or misleading information.
B. Investment Strategies
We use the following strategy(ies) in managing client accounts, provided that such strategy(ies)
are appropriately matched to the needs of the client and consistent with the clientʹs investment
objectives, risk tolerance, and time horizons, among other considerations:
Long‐term purchases. We purchase securities, including index funds, with the idea of holding
them in the clients’ account for a year or longer. Typically, we employ this strategy when we want
exposure to a particular asset class over time, regardless of the current projection for this class.
A risk in a long‐term purchase strategy is that by holding the security for this length of time, we
may not take advantages of short‐term gains that could be profitable to a client. Moreover, a
security may decline sharply in value before we make the decision to sell.
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
19
By using index funds, FMBWM can place the clients’ money in the desired asset classes. These
funds remove the managers’ discretion in choosing the securities that are purchased. The fund
investments are determined by the definition of the index or asset class and the managers simply
purchase securities to match the index. For example, instead of finding a fund manager that buys
large cap U.S. stocks to outperform the S&P 500 Index, FMBWM buys a fund with the identical
stocks to the S&P 500 index. This style can avoid the risk of exposing the client to a fund manager
that is out of phase or simply picks the wrong securities as well as generating excessive trading
costs. For taxable investors index funds and tax‐managed index funds also produce exceptionally
low capital gain distributions due to the low fund turnover.
The general asset classes used are short‐term U.S. bonds (1–2‐year average maturity), large U.S.
stocks, small U.S. stocks, large international stocks, small international stocks and a real estate
index. The portfolios may also be invested with value index funds that match the “value” (high
book to market value) component of each equity class. Unless otherwise requested by the client,
their portfolio is balanced using 15% to 40% short‐term bonds. The remainder is spread among
the previously listed equity asset classes. All portfolios assume that the investor has a minimum
3‐year commitment for the conservative balance, 3‐5 years for the aggressive balance. The client
can request that a limited amount of selected individually listed securities, actively managed
mutual funds or mortgages be placed in the account, but even these will be assumed to be held for
the long term.
Most of the funds are from Dimensional Funds Advisors (DFA), which specializes in no load asset
class funds. DFA is an Institutional index fund company known for its exceptionally low turnover
and management fees. To purchase a fund directly from DFA prior approval is needed, along with
a $2 million minimum investment. Because FMBWM has received approval from DFA, we are able
to invest clients’ assets with DFA through Charles Schwab or Fidelity.
Index funds from Vanguard, PIMCO (formerly Gurtin Municipal Bond Management), as well as
listed Exchange Traded Funds (ETF’s), may also be used. Clients’ accounts are opened and run
through an institutional level custodian (Charles Schwab or Fidelity) with daily price and
transaction activity downloaded to FMBWM’s office. Portfolio management software is used to
track the investments, produce reports, and reconcile accounts. These reports show the asset class
weighting, the investment performance of portfolios is reviewed, and the asset class balance is
analyzed. If warranted by clients’ objectives and transaction costs, the portfolio will be either
rebalanced or continued without changes.
C. Risk of Loss
Securities investments are not guaranteed, and you may lose money on your investments. We ask
that you work with us to help us understand your tolerance for risk.
IARs work with advisory clients to determine appropriate allocation models and overall
investment strategies during an initial in‐depth discovery meeting. Clients are asked questions
related to their values, interests, relationships, goals, current advisors, and assets. Clients should
discuss their objectives and risk tolerance with their IAR thoroughly. No assumption can be made
that any particular strategy will provide better returns than other investment strategies.
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
20
D. Using Sub‐Advisors
There are also risks associated with utilizing Sub‐Advisors, and those risks include:
Manager Risk
o Sub‐Advisor may fail to execute the stated investment strategy
Business Risk
o Sub‐Advisor may have financial or regulatory problems
The specific risks associated with the portfolios of the Sub‐Advisors which is disclosed
in the Sub‐Advisor’s Form ADV Part 2A Brochure.
E. Sources of Information
To help develop its strategies and recommendations, FMBWM uses commercially available
services, specifically financial publications and information services dealing with investment
research and taxation. Such information may be obtainable in print, on computer media, via the
internet, or via some other electronic means. Company prepared materials (particularly
prospectuses) and research releases prepared by others are also utilized. As an investment advisor,
FMBWM also has the opportunity to access information from a variety of experts, whether through
personal visits, telephone calls, or at industry or related meetings.
Independent, third‐party registered investment advisors may also be employed to provide
additional expertise in unique situations.
Before participating in any investment, clients should carefully consider the risks associated with
each investment by reviewing the respective prospectus, offering memorandum or disclosure
brochure prepared by the issuing company. The various applicable mutual fund, annuity and
private fund prospectuses serve as important sources of risk disclosure that should be read
carefully. Investing in securities involves risk of loss that clients should be prepared to bear.
The following describes common characteristics of risk associated with specific types of
investments that may be recommended by FMBWM in client accounts.
F. Risks of Specific Securities Utilized
Mutual Funds: Each mutual fund has different risks and rewards. Generally, the higher the
potential return, the higher the risk of loss. Investors may have to pay taxes on capital gains
distributions received even if the fund goes on to perform poorly after the investor bought shares.
Money Market Funds: Although Money Market Funds have traditionally low risk, the net asset
value (“NAV”) can fall below $1.00 if the fund performs poorly, therefore, losses are possible.
Fixed Income Securities: Fixed income investments tend to be more conservative than stocks.
However, clients should be aware that bonds and bond funds do carry some degree of risk
including but not limited to interest rate, credit, inflation, pre‐payment and reinvestment risks.
ETFs: Exchange Traded Funds (ETFs), like stocks and index funds can carry a significant amount
of market risk. The appeal of an ETF is that it represents many assets or companies, like an indexed
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
21
mutual fund, but unlike a mutual fund that prices NAV on a daily basis, ETFs can be traded at any
time during trading hours, like a stock. Investing in ETFs involves volatility and risk of losses that
Clients should be prepared to withstand.
Use of Margin: Securities purchased on margin are used as the account custodianʹs collateral for
the margin loan made to an advisory clients’ account. If the securities in an account declines in
value, so does the value of the collateral supporting the margin loan, and, as a result, the account
custodian can act, such as issue a margin call and/or sell securities or other assets in any of the
accounts held with that custodian firm, in order to maintain the required equity in the account. It
is important that Clients fully understand the risks involved in trading securities on margin.
G. Margin Disclosure Statement
Margin risk includes the following:
You can lose more funds than you deposit in the margin account.
The account custodian can force the sale of securities or other assets in your account(s).
The firm can sell your securities or other assets without contacting you.
You are not entitled to choose which securities or other assets in your account(s) are
liquidated or sold to meet a margin call.
The account custodian can increase its ʺhouseʺ margin maintenance requirements at any
time and is not required to provide you advance written notice.
You are not entitled to an extension of time on a margin call.
When clients execute transactions using margin, they must keep these important rules and
conditions in mind. Clients with any questions or concerns are advised to contact your IAR, or
FMBWM’s Chief Compliance Officer, David Howerton.
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
22
ITEM 9 – DISCIPLINARY ACTION
Registered Investment Advisors are required to disclose all material facts regarding any legal or
disciplinary events that would be considered material to clients’ or prospective clients’
evaluation and/or selection of an Advisor. FMBWM has no disciplinary history applicable to this
item.
The details of FMBWM’s status, or any Advisor’s status, can be found on the SEC’s Investment
Advisor’s Public Disclosure site (IAPD) www.Adviserinfo.sec.gov. Clients can access the Firm’s
or any IAR disciplinary history by clicking on this link.
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
23
ITEM 10 ‐ OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
FMBWM’s sole business is as a Registered Investment Advisor.
IARs of FMBWM may also be independently licensed insurance agents in the State of California.
IARs will receive insurance commissions if they sell an insurance policy through an insurance
company. If a client chooses to make a commission‐based insurance purchase through an
insurance broker or agency recommended by an FMBWM IAR this presents a conflict of interest
since the IAR‐insurance agent has a financial incentive to recommend certain products and
services through that insurance broker or agency in lieu of other financial institutions.
In cases where an FMBWM IAR makes a recommendation to a client to purchase an insurance
policy in the IAR’s capacity as an insurance agent, and the client accepts the recommendation,
resulting in an insurance commission being paid to the IAR, again outside of the FMBWM account,
the IAR will waive advisory fees in the client’s FMBWM advisory account in the amount of the
insurance commission received from the insurance company for the policy placement. This is done
to minimize or eliminate the conflict of interest that exists when the IAR is acting in a dual capacity
of IAR with FMBWM and independent insurance agent. In no case will the IAR be compensated
for a commissionable transaction and receive a fee for the same asset.
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
24
ITEM 11 – CODE OF ETHICS: PARTICIPATION OR INTEREST IN CLIENT TRANS‐
ACTIONS AND PERSONAL TRADING
FMBWM has adopted a Code of Ethics that is designed to comply with the Investment Advisors
Act of 1940, SEC Rule 204A‐1 and federal securities laws. The Code of Ethics requires certain
covered persons, including IARs, to adhere to the highest business standards and conduct their
affairs with integrity and competence when dealing with the public, clients, prospects, and
employees. The Code of Ethics outlines acceptable and unacceptable activities for IARs. The Code
of Ethics also requires IARs to report personal securities transactions to FMBWM on a quarterly
basis and contains guidelines for how client transactions must be given preference over personal
transactions by the IAR. A copy of the Code of Ethics is available to clients and prospects upon
request.
FMBWM and its IARs may invest in or otherwise own an interest in the same securities that are
recommended to clients. This creates a potential conflict of interest. All IARs are required to place
the interests of clients ahead of their own when making personal investments. In addition,
FMBWM requires that client transactions be placed before IAR personal transactions. Personal
trading by IARs is monitored by FMBWM. IARs may also buy or sell a specific security for their
own account based on personal investment considerations, which the IAR does not deem
appropriate to buy or sell for clients.
FMBWM does not make a market in any securities and does not buy or sell securities for its own
account. No principal transactions with FMBWM shall be affected in the accounts by FMBWM. No
agency‐cross transactions (as such term is defined in Advisors Act Rule 206(3)‐ 2(b)) for Client
transactions will be executed by FMBWM.
CODE OF ETHICS
FMBWM’s Code of Ethics is based upon the principle that FMBWM and its employees and
advisors owe a fiduciary duty to clients to conduct their affairs, including their personal securities
transactions, in such a manner as to avoid (i) serving their own personal interests ahead of clients,
(ii) taking inappropriate advantage of their position with the firm, and (iii) any actual or potential
conflicts of interest or any abuse of their position of trust and responsibility.
The purpose of FMBWM’s Code of Ethics is to preclude activities which may lead to or give the
appearance of conflicts of interest, insider trading, and other forms of prohibited or unethical
business conduct. As such, FMBWM and its employees are prohibited from engaging in
fraudulent, deceptive, or manipulative conduct. FMBWM and its employees have an affirmative
duty of utmost good faith to act solely in the best interests of its clients.
FMBWM has adopted the following Code of Ethics in accordance with applicable state and federal
requirements:
• Fiduciary Responsibility ‐ FMBWM and its associated persons shall exercise the highest
standard of care in protecting and promoting the interests of its clients and will provide a
written disclosure statement containing any conflicts of interest that may compromise their
impartiality or independence. As a fiduciary, FMBWM shall only accept fees or
compensation in accordance with the professional investment advisory services engaged to
provide by customer‐executed agreement.
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
25
Integrity ‐ All professional services shall be rendered with the highest level of integrity.
Objectivity ‐ FMBWM and its staff shall provide advice that is objective and in the best
interest of the client and without conflicts of interest.
Competence ‐ FMBWM and its staff shall maintain the necessary knowledge and skills to
provide our clients with competent advice and services.
Fairness ‐ All professional services shall be performed by FMBWM and its staff in a manner
that is fair and reasonable to its clients.
Confidentiality ‐ FMBWM and its staff shall maintain and safeguard all confidential client
information in accordance with applicable laws.
Diligence ‐ FMBWM and its staff shall ensure the accuracy and completeness of records,
information, and data collected, used and managed, and will take necessary steps to correct
any discrepancies.
Regulatory Compliance ‐ FMBWM and its staff shall comply fully with appropriate laws
and internal regulations.
A. Participation/Interest in Client Transactions
On occasion, FMBWM and its management persons may own securities or securities products that
are managed and in the custody of institutional, third‐party money managers that are also
recommended to clients which may present a potential conflict of interest. Such securities are kept
in separate accounts by said money managers and are not commingled. Additionally, as a
preventative measure, all client transactions will be conducted and implemented before any such
transaction relating to any personal accounts of any affiliated persons of FMBWM. In addition to
this measure, all the management persons of FMBWM will act in accordance with applicable
securities laws and conduct their business to ensure overall compliance with insider trading rules
and the Securities Fraud Enforcement Act of 1988.
B. Insider Trading Policy
FMBWM has adopted an “Insider Trading Policy” that prohibits FMBWM and its personnel from
trading for Clients or for us, or themselves, or recommending trading in securities of a company
while in possession of material nonpublic information (“inside information”) and from disclosing
such information to any person not entitled to receive it, in either case in contravention of
applicable securities laws. Because of our various activities, we may have access to inside
information or be restricted from effecting transactions in certain investments that might otherwise
have been initiated. We have adopted policies and procedures reasonably designed to, among
other things, control and monitor the flow of inside information to and within our organization as
well as prevent trading based on inside information.
We believe monitoring and restricting our employee’s personal trading in certain instances is one
way of avoiding conflicts of interest between our Clients and such personnel. Our personal trading
policies are part of our Code of Ethics.
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
26
In addition, firm personnel must provide our CCO with (i) their and their immediate family
members’ securities holdings at the commencement of employment and annually thereafter, and
(ii) monthly transaction statements so that the CCO can monitor the employee’s trading for
potential conflicts of interest.
Clients of FMBWM are under no obligation to act upon the recommendations made by IARs of
FMBWM. Lower fees for comparable services may be available from other sources.
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
27
ITEM 12 – BROKERAGE PRACTICES
FMBWM requires its clients to appoint a custodian for their accounts. Generally, FMBWM
manages client accounts through Fidelity Investments (“Fidelity”), or Charles Schwab Institutional
(“Schwab”) as a custodian broker‐dealer for their advisory accounts, but clients are under no
obligation to choose one of these firms as their account custodian. Both firms are SEC registered
broker‐dealers, FINRA (www.finra.org) and SIPC (www.sipc.org) members, and are not affiliated
with FMBWM.
They offer independent investment advisors services which include custody of client securities,
trade execution, clearance, and settlement of transactions for client accounts. FMBWM receives
some benefits from them through participation in their custodial program (please see Item 14 for
details).
FMBWM relies on these qualified custodians to provide execution services to our clients at the best
prices available. Lower fees for comparable services may be available from other sources. Clients
pay for all custodial fees in addition to the advisory fee charged by FMBWM.
Any FMBWM account maintained on one of these custodian’s Institutional platforms that is under
transactional based pricing is subject to the same zero commissions as retail clients. These
custodian broker‐dealers charge a per contract fee for options trades and transaction fees for
Mutual Funds which are charged directly to clients in addition to the FMBWM advisory fee.
FMBWM does not direct trades to any custodian, broker, or firm. Trades are not aggregated.
Trades are done on an individual basis to help ensure proper execution.
A. Best Execution
FMBWM has a duty to seek “best execution” for our clients, which is the obligation to seek
execution of securities transactions for a client on the most favorable terms for the client under the
circumstances. Clients will not necessarily pay the lowest commission or commission equivalent.
FMBWM also considers the market expertise and research access provided by the broker‐
dealer/custodian, including but not limited to access to written research, oral communication with
analysts, admittance to research conferences and other tools and resources provided by the broker‐
dealer/custodian that may aid in FMBWM ʹs research and service efforts. FMBWM will never
charge a premium or commission on transactions, beyond the actual cost imposed by the broker‐
dealer/custodian.
It is the practice of FMBWM to verify the overall execution quality and order routing practices of
broker‐dealer/custodians we use with our clients on a regular basis, rather than verifying the
individual transaction executions. This process provides us with a big picture analysis of each
firm’s execution service performance against other executing broker dealers.
B. Research and Other Soft‐Dollar Benefits
FMBWM has no formal soft dollar program in which soft dollars are used to pay for third party
services. However, FMBWM may receive research, products, or other services from custodians
and broker‐dealers in connection with client securities transactions (“soft dollar benefits”).
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
28
FMBWM may enter soft‐dollar arrangements consistent with (and not outside of) the safe harbor
contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no
assurance that any client will benefit from soft dollar research, whether or not the client’s
transactions paid for it. FMBWM benefits by not having to produce or pay for the research,
products, or services, and FMBWM may have an incentive to recommend a broker‐dealer
custodian based on receiving research or other services. Clients should be aware that FMBWM’s
acceptance of soft dollar benefits may result in higher commissions charged to the client.
C. Brokerage for Client Referrals
FMBWM receives no referrals from a broker‐dealer, custodian or third party in exchange for
using that broker‐dealer, custodian or third party.
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
29
ITEM 13 – REVIEW OF ACCOUNTS
FMBWM IARs are responsible for reviewing their clients’ advisory accounts at least quarterly and
conducting a complete account annual review. Additional triggering events resulting in additional
reviews may include responses to or requests by clients, market events, or specific target dates.
More frequent account reviews may occur as IAR or FMBWM may deem appropriate based on,
but not limited to, size or value of account, portfolio positions or holdings, economic conditions,
and market conditions.
Clients will receive trade confirmations and periodic account statements from the custodian of
their accounts. In addition, clients will receive quarterly portfolio performance reports from
FMBWM. FMBWM prepares these pre‐approved, pre‐formatted reports directly from information
received from the account custodian. Clients are encouraged to review and compare the account
information (for example, market values, transactions, and advisory fees) in the reports and
additional reporting to the account statements received from the custodian.
Individual Portfolio Management
While the underlying securities within the advisory accounts are continually monitored, these
accounts are reviewed at least annually. Accounts are reviewed in the context of each clientʹs stated
investment objectives, risk tolerance, financial needs, investment timeline, and other guidelines
established. These accounts are reviewed by the client’s IAR periodically and may be reviewed
and spot‐checked as part of the firm’s overall surveillance program by FMBWM’s Compliance
Department.
More frequent reviews may be triggered by material changes in variables such as the clientʹs
individual circumstances, or the market, political or economic environment.
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
30
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION
FMBWM does not receive economic benefits from anyone who is not a client, including sales
awards or other benefits for providing investment advice or other advisory services to clients.
A. Referrals, Endorsements and Promoters
FMBWM may receive endorser or promoter referrals from third parties that are not affiliated
with FMBWM. The third parties could be paid a percentage of the fees that the Client pays to
FMBWM. In these situations, in accordance with SEC’s Marketing Rules under the Investment
Advisers Act of 1940, a Referral or Endorser Agreement is executed between FMBWM and the
third party. FMBWM or the Endorser will provide a separate written disclosure statement to the
Clients at the time of the referral or endorsement disclosing the nature of their relationship with
FMBWM and the amount of referral fees they will be paid.
Referral arrangements between FMBWM and third‐party non‐employee Endorsers will be in
writing and include all provisions related to (a) the scope of the endorser’s activities; (b) a
covenant by the endorser to perform such activities consistent with instructions of FMBWM and
in compliance with the Investment Advisors Act of 1940 and associated marketing rules; and (c)
a covenant by the endorser to provide the client with a copy of FMBWM’s Form ADV Part 2A
disclosure brochure and a separate written endorser disclosure.
Fee arrangements described above do not increase the fee that the client pays to FMBWM. While
these relationships allow for access to potential clients who may not have otherwise been found,
it also creates a conflict of interest because of the financial incentives for the party referring those
prospective clients to FMBWM. In other words, when a referral is made to FMBWM resulting in
the payment of a fee, this presents a conflict of interest because FMBWM, the IAR, and the
endorser may prefer to refer business to each other over other investment advisors due to the
compensation incentives offered through the referral.
FMBWM addresses this conflict by making full disclosure of all potential payment scenarios and
relationships with third‐party endorsers to clients and completing periodic reviews of endorser
relationships and referral agreements.
The SEC has rules governing these relationships under the Investment Advisors Act for firms
registered with the SEC, like FMBWM. Pursuant to the Rule, a federally registered investment
advisor is prohibited from paying a cash fee directly or indirectly to a referring party with respect
to endorsement activities, unless certain conditions are observed. FMBWM monitors all endorser
and referral activities to ensure they observe all required conditions, and FMBWM remains in
compliance with the above referenced rules and regulations.
B. Employee Bonus Compensation
FMBWM provides bonus compensation to its employees, in addition to any regular salary, for
referring new clients to the firm. FMBWM will pay the advisory employee 50% of the first year’s
total management/advisory fee paid by the new client as a bonus.
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
31
C. Client Gifts
FMBWM may at times give a small gift to Clients and third parties, some of whom may be
referring Clients to it (“thank‐you gifts”). These gifts are typically of nominal value and are not
based on a percentage of the actual or anticipated earnings that FMBWM would generate or
expect to generate from any new Clients referred or gained.
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
32
ITEM 15 ‐ CUSTODY
Custody, as it applies to investment advisors, has been defined as having access or control over
client funds and/or securities, but does not include the ability to execute transactions in client
accounts. Custody is not limited to physically holding client funds and securities. If an investment
advisor can access or control client funds or securities, the investment advisor is deemed to have
custody for purposes of the Investment Advisers Act of 1940 and must ensure proper procedures are
implemented.
Please note that regulators have deemed the authorization to trade in client accounts to not be
custody. However, we are deemed to have limited custody of client funds whenever we are given
the authority to have fees deducted directly from client accounts or accept clients’ instructions to
send funds upon client requests. Our procedures do not include or allow the use of standing third
party letter of authorizations (“SLOAs”), but we do require and allow first party letters from clients
requesting funds from and to their own accounts.
For accounts where we are deemed to have limited custody, based on the description above, we
have established procedures to ensure all client funds and securities are held at a qualified
custodian in a separate account for each client under that client’s name. Clients or an independent
representative of the client will direct, in writing, the creation of all accounts and therefore are
aware of the qualified custodian’s name, address and the way the funds or securities are
maintained.
Finally, account statements are delivered directly from the qualified custodian to each client, or
the client’s independent representative, at least quarterly. Clients should carefully review those
statements and are urged to compare the statements against reports received from us. When clients
have questions about their account statements, they should contact us or the qualified custodian
preparing the statement.
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
33
ITEM 16 ‐ INVESTMENT DISCRETION
IARs have the authority to manage investments on a discretionary basis as set forth in the advisory
agreement. FMBWM and its IARs do not have the authority to withdraw funds or take custody of
client funds or securities under any circumstance.
Clients may grant IAR discretionary authority to determine the securities and/or amount of
securities to be bought or sold as set forth in the account agreement.
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
34
ITEM 17 – VOTING CLIENT SECURITIES
As a matter of firm policy, FMBWM and its IARs do not vote proxies on behalf of clients.
Therefore, although our firm may provide investment advisory services relative to client
investment assets, clients maintain exclusive responsibility for: (1) directing the way 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
types of events pertaining to the client’s investment assets. Clients are responsible for instructing
each custodian of the assets to forward to the client copies of all proxies and shareholder
communications relating to the client’s investment assets.
Clients retain the right and responsibility to vote all proxies solicited for securities held in their
account. FMBWM and its IARs are precluded from voting proxies on behalf of a client, and do not
offer any consulting assistance regarding proxy issues to clients.
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
35
ITEM 18 – FINANCIAL INFORMATION
Investment Advisors are required to provide certain financial information or disclosures about
their financial condition. FMBWM and its management persons have no financial circumstances
to report, have no financial commitment that would impair its ability to meet contractual and
fiduciary commitments to clients, and have not been the subject of any bankruptcy petition or
proceeding at any time.
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
36
PRIVACY POLICY NOTICE
Your relationship with FMB Wealth Management and FMB Retirement Services (collectively
“FMB”) is based on trust and confidence. Protecting your privacy is very important to us. Our goal
is to treat the personal information you furnish to us with the utmost respect and in accordance with
state and federal laws, as well as this Privacy Policy (“Policy”). We request that you read this Policy
carefully. By doing business with FMB you understand and are agreeing to the terms set forth in
this Policy.
This Policy describes the types of personally identifiable information we may collect from you or
that you may provide, and our practices for collecting, using, maintaining, protecting, and
disclosing that information.
Personal Information We Collect and How We Collect It
To fulfill its responsibilities to you, FMB requires that you provide current and accurate financial
and personal nonpublic information. In providing you with wealth management services, we collect
certain non‐public personal data in checklists, forms, in written notations, and in documentation
provided to us by our clients for evaluation, registration, or related consulting services. We also
create internal lists of such data. Nonpublic personal information we collect includes information
such as your name, address, phone number, ZIP code, email address, age, social security number,
employment information, investment objectives, account transactions and holdings, and similar
information.
Our policy is to keep this information strictly confidential, and to use or disclose it only as needed
to provide services to you, or as permitted by law. Our privacy policy applies equally to our former
clients, as well as individuals who simply inquire about the services we offer.
The nonpublic personal information we have about you includes what you give us when you open
an account or communicate with us about your account.
Please note that we do not knowingly solicit information from minors, and we do not knowingly
market our products or services to minors. We are required to conduct due diligence on all clients
prior to providing our services.
Protecting Client Information
You deserve to expect that FMB will protect the information you have provided in a manner that
is safe, secure and professional. FMB and its employees are committed to protecting your privacy
and to safeguarding that information.
We restrict access to nonpublic personal information about you to those persons who need to know
it or who are permitted by law to receive it. We use a variety of security measures to protect against
the access, loss, misuse, and alteration of information under our control by maintaining physical,
electronic, and procedural safeguards to protect the confidentiality of your information.
Although we make good‐faith efforts to maintain the security of such information, we cannot
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
37
guarantee that it will remain free from unauthorized access, use, disclosure, or alteration or that our
security measures will prevent unauthorized persons from accessing or obtaining this information.
We assume no liability to you or any other party in relation to the unauthorized access, use or
alteration of any information provided to us.
Notification in the Event of Data Breach
FMB has adopted an incident response program in the event of a potential data breach event. If
your sensitive non‐public information is breached by an unauthorized party, we will comply with
applicable laws in notifying you of the breach as soon as possible, within 30 days of discovery. This
includes critical third parties we do business with that may experience a breach affecting
information about you that could be used to harm you.
Accessing or Correcting Your Information
You may access the data collected by us about you by contacting us. If you believe that an error has
been made in the accuracy of the information collected from you, we will correct such error upon
adequate verification of the error and the identity of the person seeking the correction.
If you wish to access, remove, or correct any personally identifying information you have supplied
to us we invite you to contact us. Please understand that to protect your privacy and security, we
may also need to take reasonable steps to verify your identity before opening an account, granting
access to your account(s), or making corrections to your information.
Sharing Nonpublic Personal and Financial Information
FMB is committed to the protection and privacy of its clients’ and consumers’ personal and financial
information. FMB will not sell any client information or share such information with any non‐
affiliated third party except:
When necessary to complete a transaction in a client account, such as with the clearing firm
or account custodians;
In connection with a sale or merger of FMB’s business;
When required to maintain or service a client account;
To resolve client disputes or inquiries;
With persons acting in a fiduciary or representative capacity on behalf of the client;
To protect against or prevent actual or potential fraud, identity theft, unauthorized
transactions, claims or other liability;
To comply with federal, state or local laws, rules and other applicable legal requirements;
In connection with a written agreement to provide investment management or advisory
services when the information is released for the sole purpose of providing the products or
services covered by the agreement;
In any circumstances with the client’s instruction or consent; or
Pursuant to any other exceptions enumerated in the California Privacy Rights Act (CPRA)
and the California Consumer Privacy Act (CCPA).
Opt‐Out Provisions
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
38
FMB does not sell client nonpublic personal and financial information, ever. FMB does not share
nonpublic personal and financial information with affiliated or unaffiliated third parties except
under the circumstances noted above. Since sharing under the circumstances noted above is
necessary to service client accounts or is mandated by law, there are no allowances made for clients
to “opt out.”
Changes to this Privacy Policy
We reserve the right to modify or supplement this Policy statement at any time. If we make any
material change, we will update our website to include such changes. We ask that you periodically
visit our website and this privacy policy to check for any changes.
If You Close Your Account
If you decide to close your account(s) or become an inactive client, we will continue to adhere to the
privacy policies and practices as described in this notice. We reserve the right to change this policy
at any time and you will be notified if any changes occur.
Contact Information
If you have any questions after reading this Privacy Policy, please contact us by writing to:
FMB Wealth Management
100 N. Westlake Blvd., Ste. 201
Westlake Village, CA 91362
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
39
Business Continuity and Disaster Recovery Plan
Client Disclosure Notice
FMB Wealth Management maintains a written Business Continuity and Disaster Recovery Plan
to safeguard client data and other information and records from significant business
disruptions, such as data breaches, natural disasters, and varying other unforeseen
circumstances.
We plan to quickly recover and resume business operations after a significant business
disruption and respond by safeguarding our employees and property, making a financial and
operational assessment, protecting the firm’s books and records. In short, our disaster
recovery and business continuity plan is designed to permit our firm to resume operations as
quickly as possible, given the scope and severity of the significant business disruption.
Our Plan addresses:
financial and operational assessments;
critical supplier, contractor, bank and counter‐party impact;
regulatory reporting, when necessary;
training of all FMB employees,
testing our Plan on an annual basis, at a minimum, and
Cyber‐attacks, data backup and recovery; all mission critical systems;
alternative communications with clients, employees, and regulators;
alternate physical location of employees;
assuring our contacts have prompt communications with FMB personnel.
While every emergency situation may pose unique challenges based on external factors, such
as time of day and the severity of the disruption, we have been advised and assured by our
custodial firms that their objectives are to restore operations within the same business day.
You can access our full Client BCP Notice on our website, www.fmbwealth.com.
Rev. February 12, 2026
FMB Wealth Management, Form ADV Part 2A
40