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Founders Grove Wealth Partners, LLC
6802 Paragon Place, Suite 300
Richmond, VA 23230
Telephone: (804)910-0001
www.fgwp.com
November 12, 2025
Firm Contact:
Jen Thompson
Chief Compliance Officer
Form ADV Part 2A
Brochure
This brochure provides information about the qualifications and business practices of Founders
Grove Wealth Partners, LLC (hereinafter “FGWP” or the “Firm”). If you have any questions about
the contents of this brochure, please contact us at (804)910-0001. 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 FGWP is also
available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD #331352.
Please note that the use of the term “registered investment adviser” and description of our firm
and/or our associates as “registered” does not imply a certain level of skill or training.
Item 2: Material Changes
Founders Grove Wealth Partners is required to notify clients of any information that has changed
since the last annual update of the Firm Brochure (“Brochure”) that may be important to them.
Clients can request a full copy of our Brochure or contact us with any questions that they may
have about the changes.
Since the filing of the initial Form ADV Part 2A filed May 24, 2024, there have been no material
changes.
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Founders Grove Wealth Partners, LLC
Item 3: Table of Contents
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 .................................................. 9
Item 7: Types of Clients & Account Requirements .......................................................................... 9
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ............................................ 9
Item 9: Disciplinary Information.......................................................................................................... 21
Item 10: Other Financial Industry Activities & Affiliations ........................................................... 21
Item 11: Code of Ethics, Participation or Interest in ...................................................................... 22
Item 12: Brokerage Practices .............................................................................................................. 23
Item 13: Review of Accounts or Financial Plans ............................................................................. 27
Item 14: Client Referrals & Other Compensation ........................................................................... 27
Item 15: Custody ..................................................................................................................................... 28
Item 16: Investment Discretion ........................................................................................................... 28
Item 17: Voting Client Securities ........................................................................................................ 29
Item 18: Financial Information ............................................................................................................. 29
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Founders Grove Wealth Partners, LLC
Item 4: Advisory Business
FGWP offers a variety of advisory services, which include financial planning, consulting, and
investment management services. Prior to FGWP rendering any of the foregoing advisory services,
clients are required to enter into one or more written agreements with FGWP setting forth the
relevant terms and conditions of the advisory relationship (the “Advisory Agreement”).
FGWP filed for registration as an investment adviser in April 2024 and is owned by Jeremiah R.
Winters and Catherine M.C. Atwood. As of December 31, 2024, the Firm provides continuous
management services for $432,736,013 on a discretionary basis, and no client assets on a non-
discretionary basis.
While this brochure generally describes the business of FGWP, certain sections also discuss the
activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other
persons occupying a similar status or performing similar functions), employees or other persons
who provide investment advice on FGWP’s behalf and are subject to the Firm’s supervision or
control.
Wealth Management Services
FGWP provides certain clients with wealth management services which include a broad range of
financial planning and consulting services as well as discretionary and/or non-discretionary
management of investment portfolios.
The service is designed to assist clients in meeting their financial goals by ascertaining each
client’s investment objectives. Thereafter, the Firm will have the responsibility and authority to
formulate investment strategies on the client’s behalf. The Firm will conduct client meetings to
understand their current financial situation, existing resources, and tolerance for risk. Based on
what is learned, an investment approach is presented to the client, consisting primarily of
individual stocks, bonds, ETFs, options, and mutual funds. Once the appropriate portfolio has been
determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced
based upon the client’s individual needs, stated goals and objectives. Upon client request, the
Firm provides a summary of observations and recommendations for the planning or consulting
aspects of this service.
The Firm offers individualized investment advice to clients. Each client may impose reasonable
restrictions, in writing, on the types of investments to be held in the portfolio or the Firm’s services.
Restrictions on investments in certain securities or types of securities may affect the performance
of the account due to the level of difficulty of the restriction when managing the account.
In performing the financial planning services, FGWP is not required to verify any information
received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,)
and is expressly authorized to rely on such information. FGWP recommends certain clients
engage the Firm for additional related services and/or other professionals to implement its
recommendations. Clients are advised that a conflict of interest exists for the Firm to recommend
that clients engage FGWP or its affiliates to provide (or continue to provide) additional services
for compensation, including investment management services. Clients retain absolute discretion
over all decisions regarding implementation and are under no obligation to act upon any of the
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Founders Grove Wealth Partners, LLC
recommendations made by FGWP under a financial planning or consulting engagement. Clients
are advised that it remains their responsibility to promptly notify the Firm of any change in their
financial situation or investment objectives for the purpose of reviewing, evaluating or revising
FGWP’s recommendations and/or services.
Use of Independent Managers
As mentioned above, FGWP selects certain Independent Managers to actively manage a portion
of its clients’ assets. The specific terms and conditions under which a client engages an
Independent Manager are set forth in a separate written agreement with the designated
Independent Manager. That agreement can be between the Firm and the Independent Manager
(often called a subadvisor) or the client and the Independent Manager (sometimes called a
separate account manager). In addition to this brochure, clients will typically also receive the
written disclosure documents of the respective Independent Managers engaged to manage their
assets.
FGWP evaluates a variety of information about Independent Managers, which includes the
Independent Managers’ public disclosure documents, materials supplied by the Independent
Managers themselves and other third-party analyses it believes are reputable. To the extent
possible, the Firm seeks to assess the Independent Managers’ investment strategies, past
performance and risk results in relation to its clients’ individual portfolio allocations and risk
exposure. FGWP also takes into consideration each Independent Manager’s management style,
returns, reputation, financial strength, reporting, pricing and research capabilities, among other
factors.
FGWP continues to provide services relative to the discretionary selection of the Independent
Managers. On an ongoing basis, the Firm monitors the performance of those accounts being
managed by Independent Managers. FGWP seeks to ensure the Independent Managers’
strategies and target allocations remain aligned with its clients’ investment objectives and overall
best interests.
Fee based Insurance:
The Firm can use a third party company to handle insurance needs of the Client. This third party
will offer fee based insurance products for Clients and the Firm will charge an annual advisory fee
on the value of the insurance product and/or the third party company will compensate the Firm
with its share of the compensation for its advisory services provided. Generally, this third party
will be the insurance agent of record on the insurance product, and our Firm will manage the
insurance product as part of our wealth management process.
Dynasty Network
FGWP has entered a contractual relationship with Dynasty Financial Partners, LLC ("Dynasty"),
which provides the Firm with operational and back-office support including access to a network
of service providers. Through the Dynasty network of service providers, FGWP can receive
preferred pricing on trading technology, reporting, custody, brokerage, compliance, and other
related services. Dynasty charges a "Program Fee" for different types of programs offered.
Depending on the program used or chosen by the client, this Program Fee will be included as part
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Founders Grove Wealth Partners, LLC
of the client’s annual investment management fee, as described in Item 5 below or paid by the
client. In addition, Dynasty's subsidiary, Dynasty Wealth Management, LLC ("DWM") is an SEC
registered investment adviser, that provides access to a range of investment services including:
separately managed accounts (“SMA”), mutual fund and ETF asset allocation strategies, and
unified managed accounts ("UMA") managed by external Third-Party Managers (collectively, the
"Investment Programs"). FGWP can separately engage the services of Dynasty and/or its
subsidiaries to access the Investment Programs. Under the SMA and UMA programs, the Firm
will maintain the ability to select the specific, underlying Third Party Managers that will, in turn,
have day-to-day discretionary trading authority over the requisite client assets.
DWM sponsors an investment management platform (the "Platform" or the "TAMP") that is
available to the advisers in the Dynasty Network, such as the Firm. Through the Platform, DWM
and Dynasty collectively provide certain technology, administrative, operations and advisory
support services that allow FGWP to manage our client portfolios and access Independent
Managers that provide discretionary services in the form of traditional managed accounts and
investment models. FGWP can allocate all or a portion of client assets among the different
Independent Managers via the Platform. FGWP can also use the model management feature of
the TAMP by creating the Firm’s own asset allocation model and underlying investments that
comprise the model. Through the model management feature, the Firm may be able to outsource
the implementation of trade orders and periodic rebalancing of the model when needed.
FGWP will maintain the direct contractual relationship with the client and obtain, through such
agreements, the authority to engage Independent Managers, DWM and/or Dynasty, as applicable,
for services rendered through the Platform in service to the Client. FGWP may delegate
discretionary trading authority to DWM and/or Independent Managers to effect investment and
reinvestment of client assets with the ability to buy, sell or otherwise effect investment transactions
and allocate client assets. If the client participates in certain Investment Programs, DWM or the
designated manager, as applicable, is also authorized without prior consultation with either the
Firm or the client to buy, sell, trade or allocate client assets in accordance with the client’s
designated portfolio and to deliver instructions to the designated broker-dealer and/or custodian
of the client’s assets.
Item 5: Fees & Compensation
FGWP offers services for an annual fee based on the amount of assets under the Firm’s
management. This management fee varies but will not exceed 150 basis points (1.50%),
depending upon the size and composition of a client’s portfolio, the type and amount of services
rendered and the individual(s) providing the services.
Annualized fees are billed on a pro-rata basis quarterly in advance based on the value of the
account(s) on the last day of the previous quarter. Fees will be deducted from client account(s).
Adjustments will be made for deposits and withdrawals during the quarter that are more than
$50,000. The Firm may offer direct invoicing in rare cases. If the advisory agreement is executed
at any time other than the first day of the calendar quarter, the fees will apply on a pro-rata basis,
which means that the advisory fee is payable in proportion to the number of days in the quarter
for which the individual is a client. The advisory fee is negotiable, depending on individual client
circumstances and account type.
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At FGWP’s discretion, the Firm may combine the account values of family members to determine
the applicable advisory fee. For example, the Firm can combine account values for client and
client’s minor children, joint accounts with client’s spouse, and other types of related accounts.
Combining account values can increase the asset total, which can result in the client paying a
reduced advisory fee. The Firm will deduct its fee directly from the client’s account through the
qualified custodian holding funds and securities. The Firm will deduct its advisory fee only when
client has given the Firm written authorization permitting the fees to be paid directly from the
account. Further, the qualified custodian will deliver an account statement to clients at least
quarterly. These account statements will show all disbursements from the account. Clients should
review all statements for accuracy.
Dynasty Network
As discussed above in Item 4, the Firm uses Dynasty's TAMP services. Depending on the program
used or chosen by the client, the Dynasty Program Fee is included in the annual investment
management fee or paid by the client. The Independent Manager related charges are not included
in the investment management fee client pays to the Firm. Clients will be charged, separate from
and in addition to their investment management fee, any applicable Independent Manager fees.
The Firm does not receive any portion of the fees paid directly to Dynasty or the service providers
made available through its platform, including the Independent Managers.
The Dynasty Program fees that are allocated to the client will be as follows:
Program
UMA
SMA – Equity
SMA – Taxable FI
SMA – Muni
Maximum Fee
.19%
.16%
.10%
.08%
Minimum Account Fee
$120
$120
$120
$120
All other Program Fees will be absorbed by the Firm. Clients should note that the total fee reflected
on their custodial statement will represent the sum of the Firm’s investment management fee,
Platform Fee(s), and Independent Manager fee(s), accordingly. The client should review such
statements to determine the total amount of fees associated with their requisite investments, and
clients should review their Advisory Agreement with the Firm to determine the investment
management fee the client pays to the Firm.
Under the Dynasty TAMP, the Firm can use mutual fund and ETF asset allocation strategies. The
Platform Fee for these strategies/models will be up to .04%. This Platform Fee will be separate
from the investment management fee. The client should be aware that the underlying securities
have internal expenses and/or management fees associated with them, however the Firm does
not participate in any of Dynasty’s or other third-party fees.
Fee Discretion
FGWP may, in rare occasions, negotiate to charge a lesser fee based upon certain criteria, such
as anticipated future earning capacity, anticipated future additional assets, dollar amount of assets
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Founders Grove Wealth Partners, LLC
to be managed, related accounts, account composition, pre-existing/legacy client relationship,
account retention, pro bono activities, or competitive purposes.
Additional Fees and Expenses
The Firm can invest in mutual funds and exchange traded funds. The fees that clients pay to the
Firm for investment advisory services are separate and distinct from the fees and expenses
charged by mutual funds or exchange traded funds (described in each fund's prospectus) to their
shareholders. These fees will generally include a management fee and other fund expenses.
Clients will also incur transaction charges and/or brokerage fees when purchasing or selling
securities. The Firm, at its discretion, reimburses clients for reasonable custodian related
transaction charges.
Clients may also pay holdings charges imposed by the chosen custodian for certain investments,
charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be
disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses),
distribution fees, surrender charges, variable annuity fees, IRA and qualified retirement plan fees,
mark-ups and mark-downs, spreads paid to market makers, fees for trades executed away from
custodian, wire transfer fees and other fees and taxes on brokerage accounts and securities
transactions. The Firm does not receive a portion of these fees.
Margin Balance and Margin Interest
If suitable for you, our firm may use margin on your account(s) for the purpose of borrowing funds
and/or securities purchases. If a margin account is opened, you will be charged interest on any
credit balance extended to or maintained on your behalf at the broker-dealer. While the value of
the margined security will appear as a debit on your statement, the margin balance in an
account(s) will be assessed an asset-based advisory fee based on the net value of the account(s),
after deducting margin or debit balances. With respect to short sales, the client will be assessed
an asset-based advisory fee based on the value of the security sold short, but not on the proceeds
received upon initiation of the short sale. If you purchase securities on margin you should
understand: 1) the use of borrowed money will result in greater gains or losses than otherwise
would be the case without the use of margin, and 2) there will be no benefit from using margin if
the performance of your account does not exceed the interest expense being charged on the
margin balance plus the additional advisory fees assessed on the securities purchased using
margin. This creates a conflict of interest where we have an incentive to encourage the use of
margin to create a higher market value and therefore receive a higher fee.
Either party may terminate the advisory agreement signed with our firm for Portfolio Management
services at any time. Upon notice of termination, our firm will process a pro-rata refund by
calculating the amount of the unearned portion of the advisory fees based on the number of days
left in the current quarter.
Terminations and Refunds
There may be immaterial differences between the quarter end market value reflected on the
client’s custodial statement and the valuation as of the last business day of the calendar quarter
used for billing purposes, given timing and account activity. As described above, if assets more
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than $50,000 are deposited into or withdrawn from an account after the inception of a billing
period, the fee payable with respect to such assets is adjusted to reflect the interim change in
portfolio value.
Direct Fee Debit
Clients provide FGWP and/or certain Independent Managers with the authority to directly debit
their accounts for payment of the investment advisory fees. The Financial Institutions that act as
the qualified custodian for client accounts, from which the Firm retains the authority to directly
deduct fees, have agreed to send statements to clients not less than quarterly detailing all account
transactions, including any amounts paid to FGWP.
Account Additions and Withdrawals
Clients can make additions to and withdrawals from their account at any time, subject to FGWP’s
right to terminate an account. Additions can be in cash or securities provided that the Firm
reserves the right to liquidate any transferred securities or declines to accept particular securities
into a client’s account. Clients can withdraw account assets on notice to FGWP, subject to the
usual and customary securities settlement procedures. However, the Firm designs its portfolios
as long-term investments, and the withdrawal of assets may impair the achievement of a client’s
investment objectives. FGWP may consult with its clients about the options and implications of
transferring securities. Clients are advised that when transferred securities are liquidated, they
may be subject to transaction fees, short-term redemption fees, fees assessed at the mutual fund
level (e.g., contingent deferred sales charges) and/or tax ramifications.
Commissions and Sales Charges for Recommendations of Securities
Neither the Firm nor its representatives sell securities for a commissions for clients.
Item 6: Performance-Based Fees & Side-By-Side Management
FGWP does not provide any services for a performance-based fee (i.e., a fee based on a share of
capital gains or capital appreciation of a client’s assets).
Item 7: Types of Clients & Account Requirements
FGWP offers services to individuals and high net worth individuals; trusts, estates, retirement
plans, and profit sharing plans; corporations, Limited Liability Companies and/or other business
types.
Minimum Account Requirements
The Firm generally requires a minimum account balance of $2,500,000 for portfolio management
services. However, exceptions may be made on a case-by-case basis at the Firm’s discretion.
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
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Founders Grove Wealth Partners, LLC
Methods of Analysis
FGWP utilizes the following methods of analysis in formulating our investment advice and/or
managing client assets:
Charting: Involves the gathering and processing of price and volume pattern information for a
particular security, sector, broad index, or commodity. This price and volume pattern information
is analyzed. The resulting pattern and correlation data is used to detect departures from expected
performance and diversification and predict future price movements and trends.
Risk: Charting analysis may not accurately detect anomalies or predict future price movements.
Current prices of securities may reflect all information known about the security and day-to-day
changes in market prices of securities may follow random patterns and may not be predictable
with any reliable degree of accuracy.
Cyclical: A type of technical analysis that involves evaluating recurring price patterns and trends.
Economic/business cycles may not be predictable and may have many fluctuations between long-
term expansions and contractions
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.
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.
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 the Firm’s overall periodic risk assessment.
Additionally, as part of the due-diligence process, the manager’s compliance and business
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Founders Grove Wealth Partners, LLC
enterprise risks are surveyed and reviewed. A 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 the 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 clients. Moreover, as the Firm
does not control the manager’s daily business and compliance operations, the Firm may be
unaware of the lack of internal controls necessary to prevent business, regulatory or reputational
deficiencies.
Modern Portfolio Theory: A theory of investment which attempts to maximize portfolio expected
return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected
return, by carefully diversifying the proportions of various assets.
Security Analysis: Analysis of tradeable financial instruments called securities. These can be
classified into debt securities, equities, or some hybrid of the two. More broadly, futures contracts
and tradeable credit derivatives are sometimes included. Security analysis is typically divided into
fundamental analysis, which relies upon the examination of fundamental business factors such as
financial statements, and technical analysis, which focuses upon price trends and momentum.
Quantitative analysis may use indicators from both areas.
Sector Analysis: Sector analysis involves identification and analysis of various industries or
economic sectors that are likely to exhibit superior performance. Academic studies indicate that
the health of a stock's sector is as important as the performance of the individual stock itself. In
other words, even the best stock located in a weak sector will often perform poorly because that
sector is out of favor. Each industry has differences in terms of its customer base, market share
among firms, industry growth, competition, regulation, and business cycles. Learning how the
industry operates provides a deeper understanding of a company's financial health. One method
of analyzing a company's growth potential is examining whether the number of customers in the
overall market is expected to grow. In some markets, there is zero or negative growth, a factor
demanding careful consideration. Additionally, market analysts recommend that investors should
monitor sectors that are nearing the bottom of performance rankings for possible signs of an
impending turnaround.
Investment Strategies
The Firm uses the following strategies and asset classes in managing client accounts, provided
that such 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:
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
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Founders Grove Wealth Partners, LLC
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.
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, investors 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 are 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.
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 or dispose of small company stocks, more difficult to obtain
information about smaller companies, and the prices of their stocks 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.
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Founders Grove Wealth Partners, LLC
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 his 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.
Index Fund: A mutual fund or exchange-traded fund (“ETF”) designed to follow certain preset
rules so that the fund can track specified basket of underlying investments. Those rules may
include tracking prominent indexes like the S&P 500 or the Dow Jones Industrial Average or
implementation rules, such as tax-management, tracking error minimization, large block trading
or patient/flexible trading strategies that allows for greater tracking error, but lower market impact
costs. Index funds may also have rules that screen for social and sustainable criteria. An index
fund’s rules of construction clearly identify the type of companies suitable for the fund. The most
commonly known index fund, the S&P 500 Index Fund, is based on the rules established by S&P
Dow Jones Indices for their S&P 500 Index. Equity index funds would include groups of stocks
with similar characteristics such as the size, value, profitability and/or the geographic location of
the companies. A group of stocks may include companies from the United States, Non-US
Developed, emerging markets or Frontier Market countries. Additional index funds within these
geographic markets may include indexes of companies that include rules based on company
characteristics or factors, such as companies that are small, mid-sized, large, small value, large
value, small growth, large growth, the level of gross profitability or investment capital, real estate,
or indexes based on commodities and fixed-income. Companies are purchased and held within
the index fund when they meet the specific index rules or parameters and are sold when they
move outside of those rules or parameters. Think of an index fund as an investment utilizing rules-
based investing. Some index providers announce changes of the companies in their index before
the change date and other index providers do not make such announcements.
Index funds must periodically "rebalance" or adjust their portfolios to match the new prices and
market capitalization of the underlying securities in the stock or other indexes that they track. This
allows algorithmic traders to perform index arbitrage by anticipating and trading ahead of stock
price movements caused by mutual fund rebalancing, making a profit on foreknowledge of the
large institutional block orders. This results in profits transferred from investors to algorithmic
traders. One problem occurs when a large amount of money tracks the same index. According to
theory, a company should not be worth more when it is in an index. But due to supply and demand,
a company being added can have a demand shock, and a company being deleted can have a
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supply shock, and this will change the price. This does not show up in tracking error since the
index is also affected. A fund may experience less impact by tracking a less popular index.
Long-Term Purchases: The Firm can 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 the Firm could miss out on potential short-term
gains that could have been profitable to the client’s account, or it’s possible that the security’s
value may decline sharply before the Firm makes a decision to sell.
Mutual Funds: A mutual fund is a company that pools money from many investors and invests
that money in a variety of differing security types based on 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 are the fund’s 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 generally sums 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 distributions they receive. This includes instances where the fund performed 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
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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, however,
are different. When an investor buys and holds mutual fund shares, the investor will owe income
tax on any ordinary 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.
Options: An option is a financial derivative that represents a contract sold by one party
(the option writer) to another party (the option holder, or option buyer). The contract
offers the buyer the right, but not the obligation, to buy or sell a security or other financial
asset at an agreed-upon price (the strike price) during a certain period of time or on a
specific date (exercise date). Options are extremely versatile securities. Traders use
options to speculate, which is a relatively risky practice, while hedgers use options to
reduce the risk of holding an asset. In terms of speculation, option buyers and writers
have conflicting views regarding the outlook on the performance of a:
• Call Option: Call options give the option to buy at certain price, so the buyer would want
the stock to go up. Conversely, the option writer needs to provide the underlying shares
in the event that the stock's market price exceeds the strike due to the contractual
obligation. An option writer who sells a call option believes that the underlying stock's price
will drop relative to the option's strike price during the life of the option, as that is how he
will reap maximum profit. This is exactly the opposite outlook of the option buyer. The
buyer believes that the underlying stock will rise; if this happens, the buyer will be able to
acquire the stock for a lower price and then sell it for a profit. However, if the underlying
stock does not close above the strike price on the expiration date, the option buyer would
lose the premium paid for the call option.
• Put Option: Put options give the option to sell at a certain price, so the buyer would want
the stock to go down. The opposite is true for put option writers. For example, a put option
buyer is bearish on the underlying stock and believes its market price will fall below the
specified strike price on or before a specified date. On the other hand, an option writer
who sells a put option believes the underlying stock's price will increase about a specified
price on or before the expiration date. If the underlying stock's price closes above the
specified strike price on the expiration date, the put option writer's maximum profit is
achieved. Conversely, a put option holder would only benefit from a fall in the underlying
stock's price below the strike price. If the underlying stock's price falls below the strike
price, the put option writer is obligated to purchase shares of the underlying stock at the
strike price.
The potential risks associated with these transactions are that (1) All options expire. The closer
the option gets to expiration, the quicker the premium in the option deteriorates; and (2) Prices
can move very quickly. Depending on factors such as time until expiration and the relationship of
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the stock price to the option’s strike price, small movements in a stock can translate into big
movements in the underlying options.
Passive Investment Management: Passive investing involves building portfolios that are
comprised of various distinct asset classes. The asset classes are weighted in a manner to achieve
a desired relationship between correlation, risk and return. Funds that passively capture the
returns of the desired asset classes are placed in the portfolio. The funds that are used to build
passive portfolios are typically index mutual funds or exchange traded funds. Passive investment
management is characterized by low portfolio expenses (i.e. the funds inside the portfolio have
low internal costs), minimal trading costs (due to infrequent trading activity), and relative tax
efficiency (because the funds inside the portfolio are tax efficient and turnover inside the portfolio
is minimal).
In contrast, active management involves a single manager or managers who employ some
method, strategy or technique to construct a portfolio that is intended to generate returns that are
greater than the broader market or a designated benchmark. Academic research indicates most
active managers underperform the market.
Sector Allocation: The Firm allocates client assets to various sectors of the fixed income market,
including US Treasury obligations, federal agency securities, corporate notes, mortgage-backed
securities and others, based on the Firm’s quantitative and qualitative analysis in order to manage
client exposure to a given sector and to provide exposure to sectors the Firm believes to have
good value. The risk of sector allocation is that clients may not participate fully in an increase in
value in any specific sector.
Short-Term Purchases: When utilizing this strategy, the Firm may also purchase securities with
the idea of selling them within a relatively short time (typically a year or less). The Firm does this
in an attempt to take advantage of conditions that the Firm believes will soon result in a price
swing in the securities our firm purchase.
Variable Annuities (“VA”): A variable annuity is a type of annuity contract that allows for the
accumulation of capital on a tax-deferred basis. As opposed to a fixed annuity that offers a
guaranteed interest rate and a minimum payment at annuitization, variable annuities offer
investors the opportunity to generate higher rates of returns by investing in equity and bond
subaccounts. If a variable annuity is annuitized for income, the income payments can vary based
on the performance of the subaccounts. Risks associated with VAs may include:
Investment losses
• Taxes and federal penalties for early withdrawal
• Surrender charges for early withdrawal can last for years
• Earnings taxed at ordinary income tax rates
• Mortality expense to compensate the insurance company for insurance risks
• Fees and expenses imposed for the subaccounts
• Other features with additional fees and charges
•
Risk of Loss
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The following list of risk factors does not purport to be a complete enumeration or explanation of
the risks involved with respect to the Firm’s investment management activities. Clients should
consult with their legal, tax, and other advisors before engaging the Firm to provide investment
management services on their behalf.
Market Risks
Investing involves risk, including the potential loss of principal, and all investors should be guided
accordingly. The profitability of a significant portion of FGWP’s recommendations and/or
investment decisions may depend to a great extent upon correctly assessing the future course of
price movements of stocks, bonds and other asset classes. In addition, investments may be
adversely affected by financial markets and economic conditions throughout the world. There can
be no assurance that FGWP will be able to predict these price movements accurately or capitalize
on any such assumptions.
Volatility Risks
The prices and values of investments can be highly volatile, and are influenced by, among other
things, interest rates, general economic conditions, the condition of the financial markets, the
financial condition of the issuers of such assets, changing supply and demand relationships, and
programs and policies of governments.
Cash Management Risks
The Firm may invest some of a client’s assets temporarily in money market funds or other similar
types of investments, during which time an advisory account may be prevented from achieving its
investment objective.
The Firm generally invests client cash balances in money market funds, FDIC Insured Certificates
of Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately,
the Firm tries to achieve the highest return on client 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 the Firm may debit advisory fees for our services related to the
Firm’s services.
Equity-Related Securities and Instruments
The Firm may take long positions in common stocks of U.S. and non-U.S. issuers traded on
national securities exchanges and over-the-counter markets. The value of equity securities varies
in response to many factors. These factors include, without limitation, factors specific to an issuer
and factors specific to the industry in which the issuer participates. Individual companies may
report poor results or be negatively affected by industry and/or economic trends and
developments, and the stock prices of such companies may suffer a decline in response. In
addition, equity securities are subject to stock risk, which is the risk that stock prices historically
rise and fall in periodic cycles. U.S. and non-U.S. stock markets have experienced periods of
substantial price volatility in the past and may do so again in the future. In addition, investments
in small-capitalization, midcapitalization and financially distressed companies may be subject to
more abrupt or erratic price movements and may lack sufficient market liquidity, and these issuers
often face greater business risks.
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Fixed Income Securities
While the Firm emphasizes risk-averse management and capital preservation in its fixed-income
bond portfolios, clients who invest in this product can lose money, including losing a portion of
their original investment. The prices of the securities in our portfolios fluctuate. The Firm does not
guarantee any particular level of performance. Below is a representative list of the types of risks
clients should consider before investing in this product.
•
Interest rate risk. Prices of bonds tend to move in the opposite direction to
interest rate changes. Typically, a rise in interest rates will negatively affect bond
prices. The longer the duration and average maturity of a portfolio, the greater
the likely reaction to interest rate moves.
• Credit (or default) risk. A bond’s price will generally fall if the issuer fails to make
a scheduled interest or principal payment, if the credit rating of the security is
downgraded, or if the perceived creditworthiness of the issuer deteriorates.
• Liquidity risk. Sectors of the bond market can experience a sudden downturn in
trading activity. When there is little or no trading activity in a security, it can be
difficult to sell the security at or near its perceived value. In such a market, bond
prices may fall.
• Call risk. Some bonds give the issuer the option to call or redeem the bond
before the maturity date. If an issuer calls a bond when interest rates are
declining, the proceeds may have to be reinvested at a lower yield. During
periods of market illiquidity or rising rates, prices of callable securities may be
subject to increased volatility.
• Prepayment risk. When interest rates fall, the principal of mortgage-backed
securities may be prepaid. These prepayments can reduce the portfolio’s yield
because proceeds may have to be reinvested at a lower yield.
• Extension risk. When interest rates rise or there is a lack of refinancing
opportunities, prepayments of mortgage-backed securities or callable bonds
may be less than expected. This would lengthen the portfolio’s duration and
average maturity and increase its sensitivity to rising rates and its potential for
price declines.
Mutual Funds and ETFs
An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund
and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of
the fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any fund-
level capital gains, as mutual funds and ETFs are required by law to distribute capital gains in the
event they sell securities for a profit that cannot be offset by a corresponding loss.
Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund
itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to
a fund’s stated daily per share net asset value (“NAV”), plus any shareholders fees (e.g., sales
loads, purchase fees, redemption fees). The per share NAV of a mutual fund is calculated at the
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end of each business day, although the actual NAV fluctuates with intraday changes to the market
value of the fund’s holdings. The trading prices of a mutual fund’s shares may differ from the NAV
during periods of market volatility, which may, among other factors, lead to the mutual fund’s
shares trading at a premium or discount to actual NAV.
Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the
secondary market. Generally, ETF shares trade at or near their most recent NAV, which is
generally calculated at least once daily for index-based ETFs and potentially more frequently for
actively managed ETFs. However, certain inefficiencies may cause the shares to trade at a
premium or discount to their pro rata NAV. There is also no guarantee that an active secondary
market for such shares will develop or continue to exist. Generally, an ETF only redeems shares
when aggregated as creation units (usually 20,000 shares or more). Therefore, if a liquid
secondary market ceases to exist for shares of a particular ETF, a shareholder may have no way
to dispose of such shares.
Finally, some mutual funds and ETFs may have lock-up periods that restrict an investor from
selling their position for a period of time. Other mutual funds and ETFs could also have early
redemption fees that are taken if the investor sells their position before a certain amount of time.
Use of Independent Managers
As stated above, FGWP selects certain Independent Managers to manage a portion of its clients’
assets. In these situations, FGWP continues to conduct ongoing due diligence of such managers,
but such recommendations rely to a great extent on the Independent Managers’ ability to
successfully implement their investment strategies. In addition, FGWP does not have the ability to
supervise the Independent Managers on a day-to-day basis.
Options
Options allow investors to buy or sell a security at a contracted “strike” price at or within a specific
period of time. Clients may pay or collect a premium for buying or selling an option. Investors
transact in options to either hedge (i.e., limit) losses in an attempt to reduce risk or to speculate
on the performance of the underlying securities. Options transactions contain a number of
inherent risks, including the partial or total loss of principal in the event that the value of the
underlying security or index does not increase/decrease to the level of the respective strike price.
Holders of options contracts are also subject to default by the option writer, which may be unwilling
or unable to perform its contractual obligations.
Real Estate Investment Trusts (REITs)
FGWP recommends an investment in, or allocate assets among, various real estate investment
trusts (“REITs”), the shares of which exist in the form of either publicly traded or privately placed
securities. REITs are collective investment vehicles with portfolios comprised primarily of real
estate and mortgage related holdings. Many REITs hold heavy concentrations of investments tied
to commercial and/or residential developments, which inherently subject REIT investors to the
risks associated with a downturn in the real estate market. Investments linked to certain regions
that experience greater volatility in the local real estate market may give rise to large fluctuations
in the value of the vehicle’s shares. Mortgage related holdings may give rise to additional concerns
pertaining to interest rates, inflation, liquidity and counterparty risk.
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Currency Risks
An advisory account that holds investments denominated in currencies other than the currency
in which the advisory account is denominated may be adversely affected by the volatility of
currency exchange rates.
Cyber Security
With the increased use of technologies such as the internet to conduct business, the Firm and
other service providers used by the Firm, of as well as the underlying investments made by clients
are susceptible to operational, information security and related risks. In general, cyber incidents
can result from deliberate attacks or unintentional events and may arise from external or internal
sources. Cyber incidents have the ability to cause disruptions and impact business operations,
potentially resulting in financial losses, the release of investor information or confidential business
information, interference with the ability to calculate the value of client investments, destruction to
equipment and systems, violations of applicable privacy and other laws, regulatory fines or
penalties, reputation damage, or additional compliance costs. The Firm will seek to implement
safeguards to protect clients against cyber-attacks. However, there can be no assurance that the
Firm will be successful in preventing the occurrence of cyber-attacks or mitigating the impact of
cyber-attacks.
Interest Rate Risks
Interest rates may fluctuate significantly, causing price volatility with respect to securities or
instruments held by clients.
Inflation Risk
Inflation risk involves the concern that in the future, investments or proceeds from 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 the investor less than what it can today.
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. This can create a substantial delay in the receipt of proceeds from an 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 price drops significantly) a particular investment and therefore,
can have a negative impact on investment returns.
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Past Performance
Charting and technical analysis are often used interchangeably. Technical analysis generally
attempts to forecast an investment’s future potential by analyzing its past performance and other
related statistics. In particular, technical analysis often involves an evaluation of historical pricing
and volume of a particular security for the purpose of forecasting where future price and volume
figures may go. As with any investment analysis method, technical analysis runs the risk of not
knowing the future and thus, investors should realize that even the most diligent and thorough
technical analysis cannot predict or guarantee the future performance of any particular investment
instrument or issuer thereof.
Strategy Risk
There is no guarantee that the investment strategies discussed herein will work under all market
conditions and each investor should evaluate his/her ability to maintain any investment he/she is
considering in light of his/her own investment time horizon. Investments are subject to risk,
including possible loss of principal.
Item 9: Disciplinary Information
FGWP has not been involved in any legal or disciplinary events that are material to a client’s
evaluation of its advisory business or the integrity of its management.
Item 10: Other Financial Industry Activities & Affiliations
This item requires investment advisers to disclose certain financial industry activities and
affiliations.
Relationship with Dynasty Financial Partners, LLC
The Firm maintains a business relationship with Dynasty Financial Partners, LLC (“Dynasty”).
Dynasty offers operational and back-office core service support including access to a network of
service providers. Through the Dynasty network of service providers, the Firm may receive
preferred pricing on trading technology, transition support, reporting, custody, brokerage,
compliance, and other related consulting services.
While the Firm believes this open architecture structure for operational services best serves the
interest of its clients, this relationship presents certain conflicts of interest due to the fact that
Dynasty is paid by the Firm or clients for the services referenced above. In light of the foregoing,
the Firm seeks at all times to ensure that any material conflicts are addressed on a fully-disclosed
basis and handled in a manner that is aligned with the client’s best interest. The Firm does not
receive any portion of the fees paid directly to Dynasty, its affiliates or the service providers made
available through Dynasty’s platform. In addition, the Firm reviews such relationships, including
the service providers engaged through Dynasty, on a periodic basis in an effort to ensure clients
are receiving competitive rates in relation to the quality and scope of the services provided.
FGWP has entered into an agreement with Dynasty Capital Strategies, LLC – Series Steadmont,
LLC , a wholly-owned subsidiary of Dynasty and an affiliate of Dynasty Wealth Management, LLC,
to sell an agreed percentage of the revenue generated by FGWP, and in return receives a variable
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Founders Grove Wealth Partners, LLC
amount of revenue of FGWP on an annual basis, which is based on the gross earnings of FGWP
which has a minimum and a maximum payment. FGWP shall also receive an upfront payment of
funds which shall be payable on a schedule which is based upon FGWP attaining specified
amounts of revenue. Such funds may be used for business transition expenses and other costs
associated with launching operations and for business expansion. FGWP is not obligated to enter
into and become a member of the Dynasty Network. As a member of the Dynasty Network, they
are eligible to obtain other services from Dynasty, and such interests are only made available to
advisers who remain members of the Dynasty Network of registered investment advisers. The
interests are subject to standard financial underwriting practices by Dynasty and are based on
commercially reasonable terms. FGWP does have the right to terminate the agreement in the sixth
(6th) year and repay the revenue purchase investment amount. These arrangements present a
conflict of interest due to the fact that FGWP is incentivized to use the services of Dynasty in order
not to trigger a repayment of the upfront payments.
In light of the foregoing, FGWP seeks at all times to ensure that any material conflicts are
addressed on a fully-disclosed basis and handled in a manner that is aligned with its clients’ best
interests.
Item 11: Code of Ethics, Participation, or Interest in
Client Transactions & Personal Trading
Description of Our Code of Ethics:
The Firm strives to comply with applicable laws and regulations governing our practices. Therefore,
the Firm’s Code of Ethics includes guidelines for professional standards of conduct for persons
associated with the Firm. The goal is to protect client interests at all times and to demonstrate the
Firm’s commitment to its fiduciary duties of honesty, good faith, and fair dealing with clients. All
persons associated with the Firm are expected to adhere strictly to these guidelines. Persons
associated with the Firm are also required to report any violations of the Code of Ethics. Additionally,
the Firm maintains and enforces written policies reasonably designed to prevent the misuse or
dissemination of material, non-public information about clients or their account holdings by persons
associated with the Firm.
Clients or prospective clients may obtain a copy of the Code of Ethics by contacting the Firm at the
telephone number on the cover page of this brochure.
Participation or Interest in Client Transactions:
Neither our Firm nor any persons associated with our firm has any material financial interest in client
transactions beyond the provision of investment advisory services as disclosed in this brochure.
Personal Trading Practices:
Our Firm or persons associated with our firm can buy or sell the same securities that we recommend
to you or securities in which you are already invested. A conflict of interest exists in such cases
because we have the ability to trade ahead of you and potentially receive more favorable prices than
you will receive. To mitigate this conflict of interest, it is our policy that neither our firm nor persons
associated with our firm shall have priority over your account in the purchase or sale of securities.
Aggregated Trading:
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Founders Grove Wealth Partners, LLC
Our firm or persons associated with our firm can buy or sell securities for you at the same time we
or persons associated with our firm buy or sell such securities for our own account. We can also
combine our orders to purchase securities with your orders to purchase securities ("aggregated
trading"). Refer to the Brokerage Practices section in this brochure for information on our aggregated
trading practices.
A conflict of interest exists in such cases because we have the ability to trade ahead of you and
potentially receive more favorable prices than you will receive. To mitigate this conflict of interest, it
is our policy that neither our firm nor persons associated with our firm shall have priority over your
account in the purchase or sale of securities.
Item 12: Brokerage Practices
Recommendation of Broker-Dealers for Client Transactions
FGWP recommends that clients utilize the custody, brokerage and clearing services of Charles
Schwab & Co, Inc. through its Schwab Advisor Services division (“Schwab”) for investment
management accounts. The final decision to custody assets with Schwab is at the discretion of the
client, including those accounts under ERISA or IRA rules and regulations, in which case the client is
acting as either the plan sponsor or IRA accountholder. FGWP is independently owned and operated
and not affiliated with Schwab. Schwab provides FGWP with access to its institutional trading and
custody services, which are typically not available to retail investors.
While the 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.
The Firm does not open the account. Even though the account is maintained at Schwab, the 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 those 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
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• 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 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. In addition to commissions, 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.
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;
•
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Founders Grove Wealth Partners, LLC
• 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. 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.
The Firm’s 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 conflict of interest and may indirectly influence our firm’s choice of
Schwab as a custodial recommendation. Our firm examined this conflict of interest when our firm
chose to recommend Schwab and have determined that the recommendation is in the best interest
of our firm’s clients and satisfies our fiduciary obligations, including our duty to seek best execution.
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 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.
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Founders Grove Wealth Partners, LLC
Brokerage for Client Referrals
FGWP does not consider, in selecting or recommending broker-dealers, whether the Firm
receives client referrals from the Financial Institutions or other third party.
Directed Brokerage
The client may direct FGWP in writing to use a particular Financial Institution to execute some or
all transactions for the client. In that case, the client will negotiate terms and arrangements for the
account with that Financial Institution, and the Firm will not seek better execution services or
prices from other Financial Institutions or be able to “batch” client transactions for execution
through other Financial Institutions with orders for other accounts managed by FGWP (as
described above). As a result, the client may pay higher commissions or other transaction costs,
greater spreads or may receive less favorable net prices, on transactions for the account than
would otherwise be the case. Subject to its duty of best execution, FGWP may decline a client’s
request to direct brokerage if, in the Firm’s sole discretion, such directed brokerage arrangements
would result in additional operational difficulties.
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, the Firm will
request that plan sponsors who direct plan brokerage provide the Firm with a letter documenting
that this arrangement will be for the exclusive benefit of the plan.
Trade Aggregation
Our firm provides 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 our firm believes that doing so will be in the best interest of the effected 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, our firm attempts 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.
Mutual Fund Share Classes
Mutual funds are sold with different share classes, which carry different cost structures. Each
available share class is described in the mutual fund's prospectus. When we purchase, or
recommend the purchase of, mutual funds for a client, we select the share class that is deemed to
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Founders Grove Wealth Partners, LLC
be in the client's best interest, taking into consideration the availability of advisory, institutional or
retirement plan share classes, initial and ongoing share class costs, transaction costs (if any), tax
implications, cost basis and other factors. We also review the mutual funds held in accounts that
come under our management to determine whether a more beneficial share class is available,
considering cost, tax implications, and the impact of contingent or deferred sales charges.
Item 13: Review of Accounts and Reports
The Firm’s management personnel or financial advisors review accounts on at least an annual
basis for Portfolio Management Services clients. The nature of these reviews is to learn whether
client accounts are in line with their investment objectives, appropriately positioned based on
market conditions, and investment policies, if applicable. The Firm does not provide written
reports to clients, unless asked to do so. Verbal reports to clients take place on at least an annual
basis when the Firm’s Comprehensive Portfolio Management clients are contacted.
The Firm 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.
Item 14: Client Referrals & Other Compensation
Referral Fees
Our firm directly compensates non-employee (outside) consultants, individuals, and/or entities
(promoters) for client referrals. Our firm also participates in Dynasty Connect, a referral program
offered through Dynasty Wealth Management, LLC., an affiliate of Dynasty Financial Partners,
LLC.
In order to receive a cash referral fee from us, promoters, such as Dynasty Connect, must comply
with the requirements of the jurisdictions in which they operate. If you become a client, the
promoter that referred you to our firm will receive a percentage of the advisory fee you pay our
firm for as ling as you are our client, or until such time as our agreement with the promoter expires.
You will not pay additional fees because of this referral arrangement. Referral fees paid to a
promoter are contingent upon your entering into an advisory agreement with our firm. Therefore,
a promoter has a financial incentive to recommend our firm to you for advisory services. This
creates a conflict of interest; however, you are not obligated to retain our firm for advisory services.
Comparable services and/or lower fees may be available through other firms.
Other Compensation
The Firm receives economic benefits from Schwab in the form of the support products and
services made available to the Firm. These products and services, how they benefit the 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 the Firm giving particular
investment advice, such as buying particular securities for clients.
Dynasty Securities, LLC (“Dynasty Securities”), which is a wholly owned subsidiary of Dynasty
Financial Partners, LLC, and an affiliate of Dynasty Wealth Management, LLC (“Dynasty Wealth
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Founders Grove Wealth Partners, LLC
Management”) (collectively “Dynasty”) has entered into a Marketing and Business Development
Agreement (“Agreement”) with Charles Schwab & Co., Inc. (“Schwab”) whereby Dynasty
Securities and Schwab collaborate to identify financial advisor candidates that establish a
custodial relationship with Schwab and to use Dynasty’s integrated platform services. Dynasty
Securities receives payment from Schwab each quarter in connection with the Agreement. The
Agreement creates an incentive for Dynasty to encourage its network advisors to custody clients’
assets with Schwab due to the economic benefit it may receive which is a conflict of interest.
There may be other entities available to supply similar custody services at a lower fee. Financial
advisors joining the Dynasty network of registered investment advisers are not required to select
Schwab as their custodian in order to receive services from Dynasty.
Product Sponsors
The Firm occasionally sponsors events in conjunction with our product providers in an effort to
keep its clients informed as to the services the Firm offers and the various financial products it
utilizes. These events are educational in nature and are not dependent upon the use of any
specific product. While a conflict of interest may exist because these events are at least partially
funded by product sponsors, all funds received from product sponsors are used for the education
of our clients. The Firm will always adhere to its fiduciary duty in recommending appropriate
investments for clients.
Item 15: Custody
FGWP is deemed to have custody of client funds and securities because the Firm is given the
ability to debit client accounts for payment of the Firm’s fees. As such, client funds and securities
are maintained at one or more Financial Institutions that serve as the qualified custodian with
respect to such assets. Such qualified custodians will send account statements to clients at least
once per calendar quarter that typically detail any transactions in such account for the relevant
period.
Standing Letters of Authorization:
FGWP also has custody due to clients giving the Firm limited power of attorney in a standing letter
of authorization (“SLOA”) to disburse funds to one or more third parties as specifically designated
by the client. In such circumstances, the Firm will implement the steps in the SEC’s no-action
letter on February 21, 2017 which includes (in summary): i) client will provide instruction for the
SLOA to the custodian; ii) client will authorize the Firm to direct transfers to the specific third party;
iii) the custodian will perform appropriate verification of the instruction and provide a transfer of
funds notice to the client promptly after each transfer; iv) the client will have the ability to terminate
or change the instruction; v) the Firm will have no authority or ability to designate or change the
identity or any information about the third party; vi) the Firm will keep records showing that the
third party is not a related party of the Firm or located at the same address as the Firm; and vii)
the custodian will send the client an initial and annual notice confirming the SLOA instructions.
Item 16: Investment Discretion
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Founders Grove Wealth Partners, LLC
FGWP is given the authority to exercise discretion on behalf of clients. FGWP is considered to
exercise investment discretion over a client’s account if it can effect and/or direct transactions in
client accounts without first seeking their consent. FGWP is given this authority through a power-
of-attorney included in the agreement between FGWP and the client. Clients may request a
limitation on this authority (such as certain securities not to be bought or sold). FGWP takes
discretion over the following activities:
• The securities to be purchased or sold;
• The amount of securities to be purchased or sold;
• When transactions are made; and
• The Independent Managers to be hired or fired.
Item 17: Voting Client Securities
FGWP does not accept the authority to vote a client’s securities (i.e., proxies) on their behalf.
Clients receive proxies directly from the Financial Institutions where their assets are custodied and
may contact the Firm at the contact information on the cover of this brochure with questions about
any such issuer solicitations.
Item 18: Financial Information
FGWP is not required to disclose any financial information listed in the instructions to Item 18
because:
• The Firm does not require or solicit the prepayment of more than $1,200 in
fees six months or more in advance of services rendered;
• The Firm does not have a financial condition that is reasonably likely to impair
its ability to meet contractual commitments to clients; and
• The Firm has not been the subject of a bankruptcy petition at any time during
the past ten years.
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Founders Grove Wealth Partners, LLC