Overview
- Headquarters
- Manhattan Beach, CA
- Total Firm Assets
- $763 million
- Average High-Net-Worth Client Portfolio Size
- $1.2 million
Fee Structure
Primary Fee Schedule (JEPPSON WEALTH MANAGEMENT DISCLOSURE BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | and above | 1.50% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $15,000 | 1.50% |
| $5 million | $75,000 | 1.50% |
| $10 million | $150,000 | 1.50% |
| $50 million | $750,000 | 1.50% |
| $100 million | $1,500,000 | 1.50% |
Clients
- High-Net-Worth Share of Firm Assets
- 87.38%
- Number of High-Net-Worth Clients
- 548
- Total Client Accounts
- 994
- Discretionary Accounts
- 994
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Regulatory Filings
- SEC CRD Number
- 305552
Primary Brochure: JEPPSON WEALTH MANAGEMENT DISCLOSURE BROCHURE (2026-03-24)
View Document Text
Form ADV
Disclosure Brochure
January 1, 2026
Office Location:
Manhattan Towers
1230 Rosecrans Avenue, Suite 300
Manhattan Beach, CA 90266
(424) 456-3111
www.Jeppson-Wealth.com
This brochure provides information about the qualifications and business practices of Jeppson Wealth
Management, LLC, an SEC registered investment adviser. If you have any questions about the contents of this
brochure, please contact the Firm at the telephone number listed above. For compliance specific request,
please call (971) 371-3446. The information in this brochure has not been approved or verified by the United
States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional
information about the Firm is available on the SEC’s website at www.adviserinfo.sec.gov. Registration does
not imply any level of skill or training.
ITEM 2. MATERIAL CHANGES
In this Item, Jeppson Wealth Management, LLC (hereby known as “Jeppson Wealth Management” or
the “Firm”) is required to discuss any material changes that have been made to the Brochure since the
last annual amendment. The business practices of the Firm are substantially the same as represented
in the Firm’s previous and current years’ annual updated Brochures. Any material changes are
discussed below:
Material changes since the initial filing of this brochure include:
• The Firm has amended its Form ADV to update current Assets Under Management.
We will ensure that all current clients receive a Summary of Material Changes and updated Brochure
within 120 days of the close of our business’ fiscal year. A Summary of Material Changes is also included
with our Brochure on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number
for Jeppson Wealth Management, LLC is #305552. We may further provide other ongoing disclosure
information about material changes as necessary and will provide you with a new Brochure as
necessary based on changes or new information, at any time, without charge.
Currently, our Brochure may be requested by contacting Michelle Eldridge, Chief Compliance Officer
at 971-371-3446 or michelle@tru-ind.com.
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ITEM 3. TABLE OF CONTENTS
ITEM 2. MATERIAL CHANGES ................................................................................................................................. 2
ITEM 3. TABLE OF CONTENTS ................................................................................................................................ 3
ITEM 4. ADVISORY BUSINESS .................................................................................................................................. 4
ITEM 5. FEES AND COMPENSATION ........................................................................................................................ 6
ITEM 6. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT .............................................................. 8
ITEM 7. TYPES OF CLIENTS ..................................................................................................................................... 8
ITEM 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS .................................................... 8
ITEM 9. DISCIPLINARY INFORMATION .................................................................................................................. 10
ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS .............................................................. 10
ITEM 11. CODE OF ETHICS .................................................................................................................................... 11
ITEM 12. BROKERAGE PRACTICES ........................................................................................................................ 12
ITEM 13. REIVEW OF ACCOUNTS .......................................................................................................................... 15
ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION ................................................................................. 16
ITEM 15. CUSTODY ............................................................................................................................................... 16
ITEM 16. INVESTMENT DISCRETION .................................................................................................................... 17
ITEM 17. VOTING CLIENT SECURITIES ................................................................................................................... 17
ITEM 18. FINANCIAL INFORMATION ..................................................................................................................... 18
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ITEM 4. ADVISORY BUSINESS
Jeppson Wealth Management, LLC (“Jeppson Wealth Management”, “we”, “our,” or “us”) is a privately
owned limited liability company headquartered in Manhattan Beach, California.
Jeppson Wealth Management has been registered as an investment advisor with the U.S. Securities and
Exchange Commission (“SEC”) since 2019. The Firm was formed in February 2017 and is owned by Michael
Jeppson.
As of December 31, 2025, Jeppson Wealth Management managed approximately $763,237,260 in assets
for approximately 994 accounts, all of which are on a discretionary basis and in a wrap fee program.
While this brochure generally describes the business of the Firm, 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 any other person who provides
investment advice on the Firm’s behalf and is subject to the Firm’s supervision or control.
Advisory Services Offered
Jeppson Wealth Management offers discretionary and non-discretionary investment management and
investment advisory services. Prior to the Firm rendering any of the foregoing advisory services, clients
are required to enter into one or more written agreements with the Firm setting forth the relevant terms
and conditions of the advisory relationship (the “Advisory Agreement”).
Financial Planning and Consulting Services
Jeppson Wealth Management offers clients a broad range of financial planning and consulting services,
which may include any or all of the following functions:
• Retirement Planning
• Portfolio Management
• Trust and Estate Planning
•
Investment Consulting
• Cash Flow Forecasting
• Distribution Planning
• Pension Planning
•
Insurance Planning
• Risk Management
• Charitable Giving
While each of these services is available on a stand-alone basis, certain of them may also be rendered in
conjunction with investment portfolio management as part of a comprehensive wealth management
engagement (described in more detail below).
In performing these services, Jeppson Wealth Management is not required to verify any information
received from the client or from the client’s other professionals (e.g., attorneys, accounts, etc.) and is
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expressly authorized to rely on such information. The Firm may recommend clients engage the Firm for
additional related services, its Supervised Persons in their individual capacities as insurance agents or
register representatives of a broker-dealer and/or other professionals to implement its recommendations.
Clients are advised that a conflict of interest exists if client engages Firm or its affiliates to provide
additional services for compensation. Clients retain absolute discretion over all decisions regarding
implementation and are under no obligation to act upon any of the recommendations made by the Firm
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 the Firm’s recommendations and/or
services.
Wealth Management Services
Jeppson Wealth Management provides clients with wealth management services which may include a
broad range of comprehensive financial planning and consulting services as well as discretionary and/or
non-discretionary management of investment portfolios.
Under an investment management engagement, the Firm primarily allocates client assets among various
individual equity and debt securities, fixed income, mutual funds, and exchange-traded funds (“ETFs”) in
accordance with their stated investment objectives.
Where appropriate, Jeppson Wealth Management may also provide advice about any type of legacy
position or other investments held in client portfolios. Clients may engage the Firm to manage and/or
advice on certain investment products that are not maintained at their primary custodian, such as variable
life insurance and annuity contracts and assets held in employer sponsored retirement plans. In these
situations, Jeppson Wealth Management directs or recommends the allocation of client assets among the
various investment options available with the product. These assets are generally maintained at the
underwriting insurance company or the custodian designated by the product’s provider.
Jeppson Wealth Management tailors its advisory services to meet the needs of its individual clients and
seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with
those needs and objectives. The Firm consults with clients on an initial and ongoing basis to assess their
specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the
management of their portfolios. Clients are advised to promptly notify Jeppson Wealth Management if
there are changes in their financial situation or if they wish to place any limitations on the management
of their portfolios. Clients may impose reasonable restrictions or mandates on the management if the
Firm determines, in its sole discretion, the conditions would not materially impact the performance of a
management strategy or prove overly burdensome to the Firm’s management efforts.
Use of Independent Managers
As mentioned above, Jeppson Wealth Management may select certain Independent Managers or Sub-
Advisors to actively manage a portion of its clients’ assets. The specific terms and conditions under which
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a client engages an Independent Manager may be set forth in a separate written agreement with the
designated Independent Manager. In addition to this brochure, clients may also receive the written
disclosure documents of the respective Independent Managers engaged to manage their assets.
Jeppson Wealth Management evaluates a variety of information about Independent Managers, which
may include the Independent Managers’ public disclosure documents, materials supplied by the
Independent Managers themselves and other third-party analysis 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. The Firm also
takes into consideration each Independent Manager’s management style, returns, reputation, financial
strength, reporting, pricing, and research capabilities, among other factors.
Jeppson Wealth Management continues to provide services relative to the discretionary or non-
discretionary selection of Independent Managers. On an ongoing basis, the Firm monitors the
performance of those accounts being managed by Independent Manager. The Firm seeks to ensure the
Independent Mangers’ strategies and target allocations remain aligned with its clients’ investment
objectives and overall best interests.
Sponsor and Manager of Wrap Program
Jeppson Wealth Management provides substantially all investment management services as the sponsor
and manager of the Jeppson Wealth Management Wrap Program (the “Wrap Program”), a wrap fee
program where transactional, custodial, independent manager, and other similar fees are absorbed by
the Firm. Accounts managed through the Wrap Program are done so in substantially the same manner as
those that may be managed under a non-wrap arrangement. Additional information about the Wrap
Program is available in Jeppson Wealth Management’s Wrap Brochure, which appears as Part 2A
Appendix 1 of the Firm’s Form ADV.
ITEM 5. FEES AND COMPENSATION
Jeppson Wealth Management offers services on a fee basis, which may include fixed and/or hourly fees,
as well as fees based upon assets under management or advisement.
Wealth Management Fees
Jeppson Wealth Management offers investment management for an annual fee based on the amount of
assets under management. This management fee generally varies between 25 and 150 basis points
(0.25% - 1.50%), depending on the size and composition of a client’s portfolio and the type of services
rendered.
The annual fee is prorated and charged monthly, in advance, based upon the market value of the assets
being managed by the Firm on the last day of the previous billing period.
If assets in excess of $10,000 are deposited into or withdrawn from an account after the inception of a
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billing period, the fee payable with respect to such assets is adjusted to reflect the interim change in
portfolio value. For the initial period of an engagement, the fee is calculated on a pro rata basis. In the
event the advisory agreement is terminated, the fee for the final billing period is prorated through the
effective date of the termination and the outstanding or unearned portion of the fee is charged or
refunded to the client, as appropriate.
Additionally, for asset management services the Firm provides with respect to certain client holdings (e.g.,
held-away assets, accommodation accounts, alternative investments, etc.), Jeppson Wealth Management
may negotiate a fee rate that differs from the range set forth above.
Fee Discretion
Jeppson Wealth Management may, in its sole discretion, negotiate to charge a lesser fee based upon
certain criteria, such as anticipated future earning capacity, anticipated future additional assets, dollar
amount of assets to be managed, related accounts, account composition, pre-existing/legacy client
relationship, account retention and pro bono activities.
Additional Fees and Expenses
In addition to the advisory fees paid to the Firm, clients may also incur certain charges imposed by other
third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions
(collectively “Financial Institutions”). These additional charges may include securities brokerage
commissions, transaction fees, custodial fees, fees attributable to alternative assets, reporting charges,
fees charged by the Independent Managers, margin costs, charges imposed directly by a mutual fund or
ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees and other fund
expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund
fees, and other fees and taxes on brokerage accounts and securities transactions. The firm regularly
reviews accounts that have transferred different share classes of mutual funds and will convert share
classes to a lower expense share class when we believe doing so would be beneficial to the client. The
Firm’s brokerage practices are described at length in Item 12 below.
Direct Fee Debit
Clients generally provide Jeppson Wealth Management 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 the Firm.
Account Additions and Withdrawals
Clients may make additions to and withdrawals from their account at any time, subject to Jeppson Wealth
Management’s right to terminate an account. Additions may 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 may withdraw account assets on notice to the Firm, subject to the usual
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and customary securities settlement procedures. However, the Firm generally designs its portfolios as
long-term investments and the withdrawal of assets may impair the achievement of a client’s investment
objectives. Jeppson Wealth Management 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.
ITEM 6. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
The Firm does not provide any services for a separate 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
Jeppson Wealth Management offers investment advice to individuals, pension and profit-sharing plans,
trusts, estates, charitable organizations, corporations, and other business entities.
Minimum Account Requirements
The Firm does not impose a stated minimum fee or minimum portfolio value for starting and maintaining
an investment management relationship.
ITEM 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
Methods of Analysis and Investment Strategies
Jeppson Wealth Management may utilize several methods of analysis when structuring client portfolios
including fundamental analysis and technical analysis.
Fundamental analysis involves the fundamental financial condition and competitive position of a
company. Jeppson Wealth Management may analyze the financial condition, capabilities of management,
earnings, new products, and services, as well as the company’s markets and position amongst its
competitors in order to determine the recommendations made to clients. The primary risk in using
fundamental analysis is that while the overall health and position of a company may be good, market
conditions may negatively impact the security.
Technical analysis involves the analysis of past market data rather than specific company data in
determining the recommendations made to clients. Technical analysis may involve the use of charts to
identify market patterns and trends which may be based on investor sentiment rather than the
fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends
may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no
guarantee that Jeppson Wealth Management will be able to accurately predict such a reoccurrence.
To implement its recommendations, the Firm primarily allocates client assets among various individual
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equity and debt securities, fixed income, mutual funds and exchange-traded funds (“ETFs”) in accordance
with their stated investment objectives. On a more limited basis, the Firm may utilize mutual funds or
other securities to meet a client’s investment needs.
Risk of Loss
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 Jeppson Wealth Management’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. There can be no assurance that the Firm will
be able to predict those price movements accurately or capitalize on any such assumptions.
Mutual Funds and Exchange Traded Funds (ETFs)
An investment in a mutual fund or exchange traded funds (ETFs) 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 a calculated at the 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 significantly 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 indexed 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.
Use of Independent Managers
As stated above, Jeppson Wealth Management may select certain Independent Managers to manage a
portion of its clients’ assets. In these situations, the Firm continues to conduct ongoing due diligence of
such managers, but such recommendations rely to a great extent on the Independent Mangers’ ability to
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successfully implement their investment strategies.
In addition, the Firm generally may not have the ability to supervise the Independent Mangers on a day-
to-day basis.
ITEM 9. DISCIPLINARY INFORMATION
Jeppson Wealth Management 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. Please see
www.BrokerCheck.finra.org for information disclosures or disciplinary actions on the Firm’s IARs.
ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
This item requires investment advisers to disclose certain financial industry activities and affiliations.
Relationship with tru Independence, LLC
The Firm maintains a business relationship with tru Independence, LLC (“tru Independence”), a service
platform for investment professionals and an SEC registered investment adviser. tru Independence is
wholly owned by Sanctuary Wealth, LLC. Through its relationship with tru Independence, the Firm gains
access to services related to reporting, custody, investments, compliance, trading, technology, transition
support and other related services.
In fulfilling its duties to its clients, the Firm endeavors at all times to put the interests of its clients first.
The Firm reviews all of its service provider relationships on an ongoing basis in an effort to ensure
decisions are made in the best interests of clients. Clients should be aware, however, that this relationship
may pose certain conflicts of interest. Specifically, tru Independence charges the Firm a platform fee that
decreases as assets increase. Accordingly, the Firm has an incentive to increase the assets it places through
the tru Independence platform. tru Independence also provided transition support aimed at helping the
Firm launch its new advisory firm. The receipt of economic and other benefits as described above from
tru Independence creates an incentive for the Firm to choose tru Independence over other service
providers that do not furnish similar benefits.
Retirement Plan Accounts
The Firm may from time to time recommend the rollover to an IRA from an employer sponsored
retirement plan. This product will be recommended when it is deemed by the Firm to be in the best
interest of the client. It is understood that the Investment Advisor Representative will receive
management fee paid as indicated by the client agreement that will be signed when the account is
opened.
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income
Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement
accounts. The way we make money creates some conflicts with your interests, so we operate under a
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special rule that requires us to act in your best interest and not put our interest ahead of yours.
Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent
advice).
• Never put our financial interests ahead of yours when making recommendations (give loyal
advice).
• Avoid misleading statements about conflicts of interest, fees, and investments.
• Follow policies and procedures designed to ensure that we give advice that is in your best interest.
• Charge no more than is reasonable for our services.
• Give you basic information about conflicts of interest.
When recommending the rollover to an IRA from an employer sponsored retirement plan, you will be
provided with disclosure on the reasons why the transaction is in your best interested, it will be required
to be signed by both you and the advisor and will be maintained in your file.
ITEM 11. CODE OF ETHICS
Jeppson Wealth Management has adopted a code of ethics in compliance with applicable securities laws
(“Code of Ethics”) that sets forth the standards of conduct expected of its Supervised Persons. The Firm’s
Code of Ethics contains written policies reasonably designed to prevent certain unlawful practices such as
the use of material non-public information by the Firm or any of its Supervised Persons and the trading by
the same of securities ahead of clients in order to take advantage of pending orders.
The Code of Ethics also requires certain of the Firm’s personnel to report their personal securities holdings
and transactions and obtain pre-approval of certain investments (e.g., initial public offerings, limited
offerings). However, the Firm’s Supervised Persons are permitted to buy or sell securities that it also
recommends to clients if done in a fair and equitable manner that is consistent with the Firm’s policies
and procedures. This Code of Ethics has been established recognizing that some securities trade in
sufficiently broad markets to permit transactions by certain personnel to be completed without any
appreciable impact on the markets of such securities. Therefore, under limited circumstances, exceptions
may be made to the policies stated below.
When the Firm is engaging in or considering a transaction in any security on behalf of a client, no
Supervised Person will access to this information may knowingly effect for themselves or for their
immediate family (i.e., spouse, minor children and adults living in the same household) a transaction in
that security unless:
•
•
•
the transaction has been completed;
the transaction for the Supervised Person is completed as part of a batch trade with clients; or
a decision has been made not to engage in the transaction for the client.
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These requirements are not applicable to: (i) direct obligations of the Government of the United States.
(ii) Money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper,
repurchase agreements and other high quality short-term debt instruments, including repurchase
agreements; (iii) shares issued by mutual funds or money market funds; and (iv) shares issued by unit
investment trusts that are invested exclusively in one or more mutual funds.
Clients and prospective clients may contact the Firm to request a copy of its Code of Ethics.
ITEM 12. BROKERAGE PRACTICES
Recommendation of Broker/Dealers for Client Transactions
Jeppson Wealth Management generally recommends that clients utilize the custody, brokerage and
clearing services of Schwab Advisor Services TM, Charles Schwab & Co, Inc. or Charles Schwab & Co., Inc.
Advisor Services (the “Custodian” or “Schwab”) for investment management accounts.
Factors which the Firm considers in recommending the Schwab or any other broker-dealer to clients
include their respective financial strength, reputation, execution, pricing, research, and service. The
Custodian may enable the Firm to obtain many mutual funds without transaction charges and other
securities at nominal transaction charges. The commissions and/or transaction fees charged by the
Custodian may be higher or lower than those charged by other Financial Institutions.
Jeppson Wealth Management may recommend/require that clients establish brokerage accounts with the
Schwab Advisor Services division of Charles Schwab & Co., Inc. (Schwab), a registered broker-dealer,
member SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. The final
decision to custody assets with Schwab is at the discretion of the Advisor’s clients, 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. Jeppson Wealth Management is independently owned and operated and
not affiliated with Schwab. Schwab provides Jeppson Wealth Management with access to its institutional
trading and custody services, which are typically not available to Schwab retail investors. These services
generally are available to independent investment advisors on an unsolicited basis, at no charge to
advisors. Schwab’s services include brokerage services that are related to the execution of securities
transactions, custody, research, including that in the form of advice, analyses and reports, and access to
mutual funds and other investments that are otherwise generally available only to institutional investors
or would require a significantly higher minimum initial investment.
Schwab also makes available to Jeppson Wealth Management other products and services that benefit
the Firm but may not benefit its clients’ accounts. These benefits may include national, regional or Jeppson
Wealth Management specific educational events organized and/or sponsored by Schwab Advisor
Services. Other potential benefits may include occasional business entertainment of personnel of the
Firm by Schwab Advisor Services personnel, including meals, invitations to sporting events, including golf
tournaments, and other forms of entertainment, some of which may accompany educational
opportunities. Other of these products and services assist the Firm in managing and administering clients’
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accounts. These include software and other technology (and related technological training) that provide
access to client account data (such as trade confirmations and account statements), facilitate trade
execution (and allocation of aggregated trade orders for multiple client accounts), provide research,
pricing information and other market data, facilitate payment of Jeppson Wealth Management’s fees from
its clients’ accounts, and assist with back-office training and support functions, recordkeeping and client
reporting. Many of these services generally may be used to service all or some substantial number of
Jeppson Wealth Management’s accounts, including accounts not maintained at Schwab Advisor Services.
Schwab Advisor Services also makes available to Jeppson Wealth Management other services intended to
help the Firm manage and further develop its business enterprise. These services may include professional
compliance, legal and business consulting, publications and conferences on practice management,
information technology, business succession, regulatory compliance, employee benefits providers,
human capital consultants, insurance, and marketing. In addition, Schwab may make available, arrange
and/or pay vendors for these types of services rendered to Jeppson Wealth Management by independent
third parties. Schwab Advisor Services may discount or waive fees it would otherwise charge for some of
these services or pay all or a part of the fees of a third-party providing these services to the Firm. While,
as a fiduciary, the Firm endeavors to act in its clients’ best interests, Jeppson Wealth Management’s
recommendation/requirement that clients maintain their assets in accounts at Schwab may be based in
part on the benefit to the Firm of the availability of some of the foregoing products and services and other
arrangements and not solely on the nature, cost or quality of custody and brokerage services provided by
Schwab, which may create a potential conflict of interest.
The commissions paid by the Firm’s clients to the Custodian comply with the Firm’s duty to obtain “best
execution.” Clients may pay commissions that are higher than another qualified Financial Institution might
charge to effect the same transaction where the Firm determines that the commissions are reasonable in
relation to the value of the brokerage and research services received. 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 Financial Institution’s services, including
among others, the value of research provided, execution capability, commission rates and responsiveness.
The Firm seeks competitive rates but may not necessarily obtain the lowest possible commission rates for
client transactions.
Transactions may be cleared through other broker-dealers with whom the Firm and its custodians have
entered into agreements for prime brokerage clearing services. Should an account make use of prime
brokerage, the client may be required to sign an additional agreement and additional fees are likely to be
charged.
Consistent with obtaining best execution, brokerage transactions may be directed to certain
broker/dealers in return for investment research products and/or services which assist the Firm in its
investment decision-making process. Such research generally will be used to service all of the Firm’s
clients, but brokerage commissions paid by one client may be used to pay for research that is not used in
managing that client’s portfolio. The receipt of investment research products and/or services as well as
the allocation of the benefit of such investment research products and/or services poses a conflict of
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interest because the Firm does not have to produce or pay for the products or services.
The Firm periodically and systematically reviews its policies and procedures regarding its recommendation
of Financial Institutions in light of its duty to obtain best execution.
Software and Support Provided by Financial Institutions
Jeppson Wealth Management may receive without cost from Schwab computer software and related
systems support, which allow the Firm to better monitor client accounts maintained at Schwab. The Firm
may receive the software and related support without cost because the Firm renders investment
management services to clients that maintain assets at Schwab. The software and support is not provided
in connection with securities transactions of clients (i.e., not “soft dollars”). The software and related
systems support may benefit the Firm, but not its clients directly. In fulfilling its duties to its clients, the
Firm endeavors at all times to put the interests of its clients first. Clients should be aware, however, that
the Firm’s receipt of economic benefits from a broker/dealer creates a conflict of interest since these
benefits may influence the Firm’s choice of broker/dealer over another that does not furnish similar
software, systems support or services.
Specifically, the Firm may receive the following benefits from Schwab:
• Receipt of duplicate client confirmations and bundled duplicate statements;
• Access to a trading desk that exclusively services its institutional traders;
• Access to block trading which provides the ability to aggregate securities transactions and
then allocate the appropriate shares to client accounts; and
• Access to an electronic communication network for client order entry and account information.
Brokerage for Client Referrals
Jeppson Wealth Management 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 Jeppson Wealth Management 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 the Firm (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, the Firm 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.
Trade Aggregation
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Transactions for each client generally will be effected independently, unless Jeppson Wealth Management
decides to purchase or sell the same securities for several clients at approximately the same time. The
Firm may (but is not obligated to) combine or “batch” such orders to obtain best execution, to negotiate
more favorable commission rates or to allocate equitably among the Firm’s clients differences in prices
and commissions or other transaction costs that might not have been obtained had such orders been
placed independently. Under this procedure, transactions will generally be averaged as to price and
allocated among the Firm’s clients pro rata to the purchase and sale orders placed for each client on any
given day. To the extent that the Firm determines to aggregate client orders for the purchase or sale of
securities, including securities in which the Firm’s Supervised Persons may invest, the Firm generally does
so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance
provided by the staff of the U.S. Securities and Exchange Commission. The Firm does not receive any
additional compensation or remuneration as a result of the aggregation.
In the event that the Firm determines that a prorated allocation is not appropriate under the particular
circumstances, the allocation will be made based upon other relevant factors, which may include: (i) when
only a small percentage of the order is executed, shares may be allocated to the account with the smallest
order or the smallest position or to an account that is out of line with respect to security or sector
weightings relative to other portfolios, with similar mandates; (ii) allocations may be given to one account
when one account has limitations in its investment guidelines which prohibit it from purchasing other
securities which are expected to produce similar investment results and can be purchased by other
accounts; (iii) if an account reaches an investment guideline limit and cannot participate in an allocation,
shares may be reallocated to other accounts (this may be due to unforeseen changes in an account’s
assets after an order is placed); (iv) with respect to sale allocations, allocations may be given to accounts
low in cash; (v) in cases when a pro rata allocation of a potential execution would result in a de minimis
allocation in one or more accounts, the Firm may exclude the account(s) from the allocation; the
transactions may be executed on a pro rata basis among the remaining accounts; or (vi) in cases where a
small proportion of an order is executed in all accounts, shares may be allocated to one or more accounts
on a random basis.
ITEM 13. REIVEW OF ACCOUNTS
Account Reviews
Jeppson Wealth Management monitors client portfolios on a continuous and ongoing basis while regular
account reviews are conducted on at least an annual basis. Such reviews are conducted by the Firm’s
Investment Committee and/or investment adviser representatives and are intended to fulfil the Firm’s
fiduciary obligations to their advisory clients. All advisory clients are encouraged to discuss their needs,
goals and objectives with Jeppson Wealth Management and to keep the Firm informed of any changes
thereto. The Firm contacts ongoing investment advisory clients at least annually to review its previous
services and/or recommendations and quarterly to discuss the impact resulting from any changes in the
client’s financial and/or investment objectives.
Account Statements and Reports
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Clients are provided with transaction confirmation notices and regular summary account statements
directly from the Financial Institutions where their assets are custodied. From time-to-time, or as
otherwise requested, clients may also receive written or electronic reports from the Firm and/or an
outside service provider, which contain certain account and/or market-related information, such as an
inventory of account holdings or account performance. Clients should compare the account statements
they receive from their custodian with any documents or reports they receive from the Firm or an outside
service provider.
ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION
Client Referrals
Jeppson Wealth Management may provide compensation to third-party solicitors for client referrals. In
the event a client is introduced to the Firm by either an unaffiliated or an affiliated solicitor, the Firm may
pay that solicitor a referral fee in accordance with applicable state securities laws. Unless otherwise
disclosed, any such referral fee is paid solely from the Firm’s investment management fee and does not
result in any additional charge to the client. If the client is introduced to the Firm by an unaffiliated
solicitor, the solicitor is required to provide the client with the Firm’s written brochure(s) and a copy of a
solicitor’s disclosure statement containing the terms and conditions of the solicitation arrangement. Any
affiliated solicitor of the Firm is required to disclose the nature of his or her relationship to prospective
clients at the time of the solicitation and will provide all prospective clients with a copy of the Firm’s
written brochure(s) at the time of the solicitation.
ITEM 15. CUSTODY
The Advisory Agreement and/or the separate agreement with any Financial Institution generally authorize
the Firm and/or the Independent Managers to debit client accounts for payment of Jeppson Wealth
Management’s fees and to directly remit that those funds to the Firm in accordance with applicable
custody rules. 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 the Firm.
In addition, as discussed in Item 13, the Firm may also send periodic supplemental reports to clients.
Clients should carefully review the statements sent directly by the Financial Institutions and compare
them to those received from the Firm.
Third-Party Standing Letters of Authorization (“SLOA”)
Our firm is deemed to have custody of clients’ funds or securities when clients have standing
authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) and,
under that SLOA, it authorizes us to designate the amount or timing of transfers with the custodian.
The SEC has set forth a set of standards intended to protect client assets in such situations, which we
follow. By working with the qualified custodian, the Firm has in place seven provisions set forth by the SEC to
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assist in mitigating risk.
The below must be followed to clients with third-party SLOAs:
1.
2.
3.
4.
5.
6.
7.
The client provides an instruction to the qualified custodian, in writing, that includes the client’s
signature, the third party’s name, and either the third party’s address or the third party’s account
number at a custodian to which the transfer should be directed.
The client authorizes the Firm, in writing, either on the qualified custodian’s form or separately, to
direct transfers to the third party either on a specified schedule or from time to time.
The client’s qualified custodian performs appropriate verification of the instruction, such as a signature
review or other method to verify the client’s authorization and provides a transfer of funds notice to
the client promptly after each transfer.
The client can terminate or change the instruction to the client’s qualified custodian.
The Firm has no authority or ability to designate or change the identity of the third party, the address,
or any other information about the third party contained in the client’s instruction.
The Firm maintains records showing that the third party is not a related party of Firm or located at the
same address as the Firm.
The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction
and an annual notice reconfirming the instruction.
As stated earlier in this section, account statements reflecting all activity on the account(s), are delivered
directly from the qualified custodian to each client or the client’s independent representative, at least
quarterly. You should carefully review those statements and are urged to compare the statements against
reports received from us. When you have questions about your account statements, you should contact us,
your Advisor or the qualified custodian preparing the statement.
ITEM 16. INVESTMENT DISCRETION
Jeppson Wealth Management may be given the authority to exercise discretion on behalf of clients. The
Firm 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. The Firm is given this authority through
a power-of-attorney included in the agreement between the Firm and the client. Clients may request a
limitation on this authority (such as certain securities not to be bought or sold). The Firm takes discretion
over the following activities:
The securities to be purchased or sold;
The amount of securities to be purchased or sold; and
•
•
• When transactions are made.
ITEM 17. VOTING CLIENT SECURITIES
Voting of Proxies
In regard to SEC Rule 206(4)-6 under the Advisers Act, the Advisor will not vote proxies relating to equity
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securities in client accounts. You are responsible for: (1) directing the manner in which proxies solicited
by issuers of securities beneficially owned in your Account are voted and voting or causing such proxies
to be so voted and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy
proceedings or other similar type events pertaining to your Assets. Please contact us if you would like to
receive a copy of our Proxy Voting Policy.
Class Action Lawsuits
As a matter of company policy, Advisor does not file proofs of claim relating to class action lawsuits
affecting individual client accounts. However, upon Client’s request Advisor will provide any and all
documentation required to complete any such proof of claim.
Mutual Funds
The investment adviser that manages the assets of a registered investment company (i.e., mutual fund)
generally votes proxies issued on securities held by the mutual fund.
ITEM 18. FINANCIAL INFORMATION
Registered investment advisers are required in this item to provide clients with certain financial
information or disclosures about the firm’s financial condition. Jeppson Wealth Management does not
require the prepayment of more than $1,200 in fees per client, six months or more in advance, does not
have or foresee any financial condition that is reasonably likely to impair our ability to meet contractual
commitments to clients and has not been the subject of a bankruptcy proceeding.
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Additional Brochure: JEPPSON WEALTH MANAGEMENT WRAP FEE PROGRAM BROCHURE (2026-03-24)
View Document Text
Part 2A Appendix 1 of Form ADV
Wrap Fee Program
Sponsored by
Jeppson Wealth Management
January 1, 2026
Office Location:
Manhattan Towers
1230 Rosecrans Avenue, Suite 300
Manhattan Beach, CA 90266
(424) 456-3111
www.Jeppson-Wealth.com
This wrap fee program brochure provides information about the qualifications and business practices of
Jeppson Wealth Management, LLC, an SEC registered investment adviser. If you have any questions about
the contents of this brochure, please contact the Firm at the telephone number listed above. For
compliance specific request, please call (971) 371-3446. The information in this brochure has not been
approved or verified by the United States Securities and Exchange Commission (SEC) or by any state
securities authority. Additional information about the Firm is available on the SEC’s website at
www.adviserinfo.sec.gov. Registration does not imply any level of skill or training.
ITEM 2. MATERIAL CHANGES
In this Item, Jeppson Wealth Management, LLC (hereby known as “Jeppson Wealth Management” or the
“Firm”) is required to discuss any material changes that have been made to the Brochure since the last
annual amendment. The business practices of the Firm are substantially the same as represented in the
Firm’s previous and current years’ annual updated Brochures. Any material changes are discussed below:
Material changes since the initial filing of this brochure include:
• The Firm has amended its Form ADV to update current Assets Under Management.
We will ensure that all current clients receive a Summary of Material Changes and updated Wrap Program
Brochure within 120 days of the close of our business’ fiscal year. A Summary of Material Changes is also
included with our Brochure on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD
number for Jeppson Wealth Management, LLC is #305552. We may further provide other ongoing
disclosure information about material changes as necessary and will further provide you with a new
Brochure as necessary based on changes or new information, at any time, without charge.
Currently, our Brochure may be requested by contacting Michelle Eldridge, Chief Compliance Officer at
971-371-3446 or michelle@tru-ind.com.
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ITEM 3. TABLE OF CONTENTS
ITEM 2. MATERIAL CHANGES ................................................................................................................................................... 2
ITEM 3. TABLE OF CONTENTS .................................................................................................................................................. 3
ITEM 4. SERVICES, FEE AND COMPENSATION .......................................................................................................................... 4
ITEM 5. ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ................................................................................................... 8
ITEM 6. PORTFOLIO MANAGER SELECTION AND EVALUTION .................................................................................................. 8
ITEM 7. CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGER ................................................................................. 12
ITEM 8. CLIENT CONTACT WITH PORTFOLIO MANAGER ....................................................................................................... 12
ITEM 9. ADDITIONAL INFORMATION ..................................................................................................................................... 12
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ITEM 4. SERVICES, FEE AND COMPENSATION
Jeppson Wealth Management, LLC (“Jeppson”, “we”, “our,” “us,” or “Firm) is a privately owned limited
liability company headquartered in Manhattan Beach, California.
Jeppson Wealth Management has been registered as an investment advisor with the U.S. Securities and
Exchange Commission (“SEC”) since 2019. The Firm was formed in February 2017 and is owned by Michael
Jeppson.
As of December 31, 2025, Jeppson Wealth Management managed approximately $763,237,260 in assets
for approximately 994 accounts all on a discretionary basis and in a wrap fee program.
The Jeppson Wealth Management Wrap Program (the “Program”) is an investment advisory program
sponsored by Jeppson Wealth Management. Prior to the Firm rendering any of the foregoing advisory
services, clients are required to enter into one or more written agreements with Jeppson Wealth
Management setting forth the relevant terms and conditions of the advisory relationship (the
“Advisory Agreement”).
While this brochure generally describes the business of the Firm, 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 any other person who provides
investment advice on the Firm’s behalf and is subject to the Firm’s supervision or control.
Description of the Program
The Program is offered as a wrap fee program, which provides clients with the ability to trade in certain
investment products without incurring separate brokerage commissions or transaction charges. A wrap fee
program is considered any arrangement under which clients receive investment advisory services (which
may include portfolio management or advice concerning the selection of other investment advisers) and
the execution of client transactions for a specified fee or fees not based upon transactions in their accounts.
Clients must also open a new securities brokerage account and complete a new account agreement with
Schwab Advisor ServicesTM (“Schwab”) or another broker-dealer that Jeppson Wealth Management
approves under the Program (collectively “Financial Institutions”).
At the onset of the Program, clients complete an investor profile describing their individual investment
objectives, liquidity and cash flow needs, time horizon and risk tolerance, as well as any other factors
pertinent to their specific financial situations. After an analysis of the relevant information, Jeppson
Wealth Management assists its clients in developing an appropriate strategy for managing their assets.
Clients’ investment portfolios are generally managed on a discretionary or non-discretionary basis by
the Firm.
Financial Planning and Consulting Services
Jeppson Wealth Management offers clients a broad range of financial planning and consulting services,
which may include any or all of the following functions:
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• Retirement Planning
• Portfolio Management
• Trust and Estate Planning
•
Investment Consulting
• Cash Flow Forecasting
• Distribution Planning
• Pension Planning
•
Insurance Planning
• Risk Management
• Charitable Giving
While each of these services is available on a stand-alone basis, certain of them may also be rendered in
conjunction with investment portfolio management as part of a comprehensive wealth management
engagement (described in more detail below).
In performing these services, the Firm is not required to verify any information received from the client
or from the client’s other professionals (e.g., attorneys, accounts, etc.) and is expressly authorized to rely
on such information. The Firm may recommend clients engage the Firm for additional related services,
its Supervised Persons in their individual capacities as insurance agents or register representatives of a
broker-dealer and/or other professionals to implement its recommendations. Clients are advised that a
conflict of interest exists if client engages Firm or its affiliates to provide additional services for
compensation. Clients retain absolute discretion over all decisions regarding implementation and are
under no obligation to act upon any of the recommendations made by the Firm 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 the Firm’s recommendations and/or services.
Wealth Management Services
Jeppson Wealth Management provides clients with wealth management services which may include a
broad range of comprehensive financial planning and consulting services as well as discretionary and/or
non-discretionary management of investment portfolios.
Under an investment management engagement, Jeppson Wealth Management primarily allocates client
assets among various individual equity and debt securities, fixed income, mutual funds and exchange-
traded funds (“ETFs”) in accordance with their stated investment objectives.
Where appropriate, Jeppson Wealth Management may also provide advice about any type of legacy
position or other investment held in client portfolios. Clients may engage the Firm to manage and/or
advise on certain investment products that are not maintained at their primary custodian, such as variable
life insurance and annuity contracts and assets held in employer sponsored retirement plans. In these
situations, Jeppson Wealth Management directs or recommends the allocation of client assets among the
various investment options available with the product. These assets are generally maintained at the
underwriting insurance company, or the custodian designated by the product’s provider.
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The Firm tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a
continuous basis, that client portfolios are managed in a manner consistent with those needs and
objectives. The Firm consults with clients on an initial and ongoing basis to assess their specific risk
tolerance, time horizon, liquidity constraints and other related factors relevant to the management of
their portfolios. Clients are advised to promptly notify Jeppson Wealth Management if there are changes
in their financial situation or if they wish to place any limitations on the management of their portfolios.
Clients may impose reasonable restrictions or mandates on the management if the Firm determines, in
its sole discretion, the conditions will not materially impact the performance of a management strategy
or prove overly burdensome to the Firm’s management efforts.
Use of Independent Managers
Jeppson Wealth Management may select certain Independent Managers or Sub-Advisors to actively
manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an
Independent Manager may be set forth in a separate written agreement with the designated Independent
Manager. In addition to this brochure, clients may also receive the written disclosure documents of the
respective Independent Managers engaged to manage their assets.
The Firm evaluates a variety of information about Independent Managers, which may include 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. The Firm also takes into consideration
each Independent Manager’s management style, returns, reputation, financial strength, reporting,
pricing, and research capabilities, among other factors.
The Firm continues to provide services relative to the discretionary or non-discretionary selection of
Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being
managed by Independent Manager. The Firm seeks to ensure the Independent Mangers’ strategies and
target allocations remain aligned with its clients’ investment objectives and overall best interests.
Fees for Participation in the Program
The Program is offered on a fee basis, meaning participants pay a single annualized fee based upon assets
under management (“Program Fee”).
Jeppson Wealth Management offers investment management for an annual fee based on the amount of
assets under management. This management fee generally varies between 25 and 150 basis points
(0.25% - 1.50%), depending on the size and composition of a client’s portfolio and the type of services
rendered.
The annual fee is prorated and charged monthly, in advance, based upon the market value of the assets
being managed by the Firm on the last day of the previous billing period.
If assets in excess of $10,000 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. For the initial period of an engagement, the fee is calculated on a pro rata basis. In the
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event the advisory agreement is terminated, the fee for the final billing period is prorated through the
effective date of the termination and the outstanding or unearned portion of the fee is charged or
refunded to the client, as appropriate.
Additionally, for asset management services, the Firm provides with respect to certain client holdings
(e.g., held-away assets, accommodation accounts, alternative investments, etc.), the Firm may negotiate
a fee rate that differs from the range set forth above.
Fee Comparison
As referenced above, a portion of the fees paid to Jeppson Wealth Management are used to cover
the securities brokerage commissions and transactional costs attributed to the management of its
clients’ portfolios.
Services provided through the Program may cost clients more or less than purchasing these services
separately. The number of transactions made in clients’ accounts, as well as the commissions charged for
each transaction, determines the relative cost of the Program versus paying for execution on a per
transaction basis and paying a separate fee for advisory services. Therefore, the Firm has an incentive to
place less trades for clients in the Program since the Firm incurs transaction expenses. Fees paid for the
Program may also be higher or lower than fees charged by other sponsors of comparable investment
advisory programs.
Fee Discretion
Jeppson Wealth Management, in its sole discretion, may negotiate to charge a lesser fee based upon
certain criteria, such as anticipated future earning capacity, anticipated future additional assets, dollar
amount of assets to be managed, related accounts, account composition, pre-existing/legacy client
relationship, account retention and pro bono activities.
Other Charges
The fees not included in the advisory fee for our wrap services are charges imposed directly by a mutual
fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e., fund
management fees and other fund expenses), mark-ups and mark-downs, spreads paid to market makers,
fees for trades executed at a broker dealer other than Schwab, wire transfer fees and other fees and taxes
on brokerage accounts and securities transactions. Our firm regularly reviews accounts that have
transferred different share classes of mutual funds and will convert share classes to a lower expense share
class when we believe doing so would be beneficial to the client.
Direct Fee Debit
Clients generally provide Jeppson Wealth Management 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,
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including any amounts paid to Jeppson Wealth Management.
Account Additions and Withdrawals
Clients may make additions to and withdrawals from their account at any time, subject to Jeppson Wealth
Management’s right to terminate an account. Additions may be in cash or securities provided that the
Firm reserves the right to liquidate any transferred securities or decline to accept particular securities
into a client’s account. Clients may withdraw account assets on notice to Jeppson Wealth Management,
subject to
the usual and customary securities settlement procedures. However, Jeppson Wealth
Management designs its portfolios as long-term investments, and the withdrawal of assets may impair
the achievement of a client’s investment objectives. Jeppson Wealth Management 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, fees assessed at the
mutual fund level (e.g., contingent deferred sales charge) and/or tax ramifications.
Compensation for Recommending the Program
Jeppson Wealth Management has no internal arrangements in place whereby persons recommending the
Program are entitled to receive additional compensation as a result of clients’ participation. A person
recommending the Program will not earn more compensation than he or she would otherwise receive if
a client elected another investment management program.
ITEM 5. ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS
Jeppson Wealth Management offers services to individuals, pension and profit-sharing plans, trusts,
estates, charitable organizations, corporations, and business entities.
Minimum Account Value and Fee
The Firm does not impose a stated minimum fee or minimum portfolio value for starting and maintaining
an investment management relationship.
ITEM 6. PORTFOLIO MANAGER SELECTION AND EVALUTION
Use of Independent Managers
As stated above, Jeppson Wealth Management may select certain Independent Managers to manage a
portion of its clients’ assets in a separate written agreement with the designated Independent Manager
which will include the payment of any solicitor fees by Jeppson Wealth Management to the Independent
Manager for their services. In these situations, Jeppson Wealth Management continues to conduct
ongoing due diligence of such managers, but such recommendations rely to a great extent on the
Independent Mangers’ ability to successfully implement their investment strategies. In addition, Jeppson
Wealth Management generally may not have the ability to supervise the Independent Mangers on a day-
to-day basis.
Individual Tailoring of Advice to Clients
We offer individualized investment advice to clients using our services.
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Ability of Clients to Impose Restrictions
We do allow clients to impose reasonable restrictions on investing in certain securities or types of securities.
Participation in Wrap Fee Programs
Our wrap fee and non-wrap fee accounts are managed on an individual basis according to the client’s
investment objectives, financial goals, risk tolerance, etc. We do not manage wrap fee accounts in a different
fashion than non-wrap fee accounts.
Side-By-Side Management
Jeppson Wealth Management 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).
Methods of Analysis and Investment Strategies
Jeppson Wealth Management may utilize several methods of analysis when structuring client portfolios
including fundamental analysis and technical analysis.
Fundamental analysis involves the fundamental financial condition and competitive position of a
company. Jeppson Wealth Management may analyze the financial condition, capabilities of management,
earnings, new products, and services, as well as the company’s markets and position amongst its
competitors in order to determine the recommendations made to clients. The primary risk in using
fundamental analysis is that while the overall health and position of a company may be good, market
conditions may negatively impact the security.
Technical analysis involves the analysis of past market data rather than specific company data in
determining the recommendations made to clients. Technical analysis may involve the use of charts to
identify market patterns and trends which may be based on investor sentiment rather than the
fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends
may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no
guarantee that Jeppson Wealth Management will be able to accurately predict such a reoccurrence.
To implement its recommendations, the Firm primarily allocates client assets among various individual
equity and debt securities, fixed income, mutual funds and exchange-traded funds (“ETFs”) in accordance
with their stated investment objectives. On a more limited basis, the Firm may utilize mutual funds or
other securities to meet a client’s investment needs.
Risk of Loss
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 Jeppson Wealth Managements’ 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. There can be no assurance that Jeppson
Wealth Management will be able to predict those price movements accurately or capitalize on any such
assumptions.
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Mutual Funds and Exchange Traded Funds (ETFs)
An investment in a mutual fund or exchange traded funds (ETFs) 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 a calculated at the 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 significantly 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 indexed 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.
Use of Private Collective Investment Vehicles
The Firm may recommend that certain clients invest in privately placed collective investment vehicles
(e.g., hedge funds, private equity funds, etc.). The managers of these vehicles have broad discretion in
selecting the investments. There are few limitations on the types of securities or other financial
instruments which may be traded and no requirement to diversify. Hedge funds may trade on margin or
otherwise leverage positions, thereby potentially increasing the risk to the vehicle. In addition, because
the vehicles are not registered as investment companies, there is an absence of regulation. There are
numerous other risks in investing in these securities. Clients should consult each fund’s private placement
memorandum and/or other documents explaining such risks prior to investing.
Real Estate Investment Trusts (REITs)
The Firm may recommend 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
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shares. Mortgage related holdings may give rise to additional concerns pertaining to interest rates,
inflation, liquidity and counterparty risk.
Liquidity
The Firm may recommend investments intended for longer-term investment, such as private real estate
opportunities. These types of investments may be less liquid, meaning funds may not be readily available
for withdrawal by the client. The risk of illiquidity shall be measured against the potential return of the
product and the position size as well as the client’s investment specific return and investment objectives
to ensure the risk is appropriate.
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.
Use of Margin
While the use of margin borrowing can substantially improve returns, it may also increase overall portfolio
risk. Margin transactions are generally affected using capital borrowed from a Financial Institution, which
is secured by a client’s holdings. Under certain circumstances, a lending Financial Institution may demand
an increase in the underlying collateral. If the client is unable to provide the additional collateral, the
Financial Institution may liquidate account assets to satisfy the client’s outstanding obligations, which
could have extremely adverse consequences. In addition, fluctuations in the amount of a client’s
borrowings and the corresponding interest rates may have a significant effect on the profitability and
stability of a client’s portfolio.
Proxy Voting Authority
In regard to SEC Rule 206(4)-6 under the Advisers Act, Jeppson will note vote proxies relating to equity
securities in client accounts, nor do we offer guidance on how to vote proxies.
Account holders may receive voting proxies or similar solicitations sent directly from the custodian of
record or transfer agent. Note that we do not forward duplicate copies of these or any correspondence
relating to the voting of securities, class action litigation, or other corporate actions.
Each account holder will maintain exclusive responsibility for directing how proxies solicited by issuers of
beneficially owned securities shall be voted, as well as making all other elections relative to mergers,
acquisitions, tender offers, or other events pertaining to such holdings. We will answer limited questions
with respect to what a proxy voting request or other corporate matter may be and how to reach the issuer
or their legal representative.
Account holders of record maintain responsibility for directing the manner in which proxies solicited by
issuers of beneficially owned securities shall be voted, as well as making all other elections relative to
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mergers, acquisitions, tender offers, or other legal matters or events pertaining to their holdings. The
account holder should consider contacting the issuer or their legal counsel with specific questions they
may have concerning a particular proxy solicitation or corporate action.
ITEM 7. CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGER
We are required to describe the information about you that we communicate to your portfolio
manager(s), and how often or under what circumstances we provide updated information. Our firm
communications with your portfolio manager(s) on a regular basis as needed to ensure you’re most
current investment goals and objectives are understood by your portfolio manager(s). In most cases, we
will communicate such information as part of our regular investment management duties. Nevertheless,
we will also communicate information to your portfolio manager(s) when you request us to, when market
or economic conditions make it prudent to do so, etc.
ITEM 8. CLIENT CONTACT WITH PORTFOLIO MANAGER
Our clients may directly contact their portfolio manager(s) with questions or concerns or by calling the
number on this Brochure for contact information.
ITEM 9. ADDITIONAL INFORMATION
Disciplinary Information
Jeppson Wealth Management 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. Please see
www.BrokerCheck.finra.org for information disclosures or disciplinary actions on the Firm’s IARs.
Other Financial Industry Activities and Affiliations
This item requires investment advisers to disclose certain financial industry activities and affiliations.
Relationship with tru Independence, LLC
The Firm maintains a business relationship with tru Independence, LLC (“tru Independence”), a service
platform for investment professionals and an SEC registered investment adviser. tru Independence is
wholly owned by Sanctuary Wealth, LLC. Through its relationship with tru Independence, the Firm gains
access to services related to reporting, custody, investments, compliance, trading, technology, transition
support and other related services.
In fulfilling its duties to its clients, the Firm endeavors at all times to put the interests of its clients first.
The Firm reviews all of its service provider relationships on an ongoing basis in an effort to ensure
decisions are made in the best interests of clients. Clients should be aware, however, that this relationship
may pose certain conflicts of interest. Specifically, tru Independence charges the Firm a platform fee that
decreases as assets increase. Accordingly, the Firm has an incentive to increase the assets it places
through the tru Independence platform. tru Independence also provided transition support aimed at
helping the Firm launch its new advisory firm. The receipt of economic and other benefits as described
above from tru Independence creates an incentive for the Firm to choose tru Independence over other
service providers that do not furnish similar benefits.
Retirement Plan Accounts
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The Firm may from time to time recommend the rollover to an IRA from an employer sponsored
retirement plan. This product will be recommended when it is deemed by the Firm to be in the best
interest of the client. It is understood that the Investment Advisor Representative will receive
management fee paid as indicated by the client agreement that will be signed when the account is
opened.
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income
Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement
accounts. The way we make money creates some conflicts with your interests, so we operate under a
special rule that requires us to act in your best interest and not put our interest ahead of yours.
Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent
advice).
• Never put our financial interests ahead of yours when making recommendations (give loyal
advice).
• Avoid misleading statements about conflicts of interest, fees, and investments.
• Follow policies and procedures designed to ensure that we give advice that is in your best interest.
• Charge no more than is reasonable for our services.
• Give you basic information about conflicts of interest.
When recommending the rollover to an IRA from an employer sponsored retirement plan, you will be
provided with disclosure on the reasons why the transaction is in your best interested, it will be required
to be signed by both you and the advisor and will be maintained in your file.
Code of Ethics
The Firm has adopted a code of ethics in compliance with applicable securities laws (“Code of Ethics”)
that sets forth the standards of conduct expected of its Supervised Persons. The Firm’s Code of Ethics
contains written policies reasonably designed to prevent certain unlawful practices such as the use of
material non-public information by the Firm or any of its Supervised Persons and the trading by the same
of securities ahead of clients in order to take advantage of pending orders.
The Code of Ethics also requires certain of the Firm’s personnel to report their personal securities holdings
and transactions and obtain pre-approval of certain investments (e.g., initial public offerings, limited
offerings). However, the Firm’s Supervised Persons are permitted to buy or sell securities that it also
recommends to clients if done in a fair and equitable manner that is consistent with the Firm’s policies
and procedures. This Code of Ethics has been established recognizing that some securities trade in
sufficiently broad markets to permit transactions by certain personnel to be completed without any
appreciable impact on the markets of such securities. Therefore, under limited circumstances, exceptions
may be made to the policies stated below.
When the Firm is engaging in or considering a transaction in any security on behalf of a client, no
Supervised Person will access to this information may knowingly effect for themselves or for their
immediate family (i.e., spouse, minor children and adults living in the same household) a transaction in
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that security unless:
•
•
•
the transaction has been completed.
the transaction for the Supervised Person is completed as part of a batch trade with clients. or
a decision has been made not to engage in the transaction for the client.
These requirements are not applicable to: (i) direct obligations of the Government of the United States;
(ii) money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper,
repurchase agreements and other high quality short-term debt instruments, including repurchase
agreements; (iii) shares issued by mutual funds or money market funds; and (iv) shares issued by unit
investment trusts that are invested exclusively in one or more mutual funds.
Clients and prospective clients may contact the Firm to request a copy of its Code of Ethics.
Account Reviews
The Firm monitors client portfolios on a continuous and ongoing basis while regular account reviews are
conducted on at least an annual basis. Such reviews are conducted by the Firm’s Investment Committee
and/or investment adviser representatives and are intended to fulfil the Firm’s fiduciary obligations to
their advisory clients. All advisory clients are encouraged to discuss their needs, goals and objectives with
Jeppson Wealth Management and to keep the Firm informed of any changes thereto. Jeppson Wealth
Management contacts ongoing investment advisory clients at least annually to review its previous services
and/or recommendations and quarterly to discuss the impact resulting from any changes in the client’s
financial and/or investment objectives.
Account Statements and General Reports
Clients are provided with transaction confirmation notices and regular summary account statements
directly from the Financial Institutions where their assets are custodied. From time-to-time or as
otherwise requested, clients may also receive written or electronic reports from the Firm and/or an
outside service provider, which contain certain account and/or market-related information, such as an
inventory of account holdings or account performance. Clients should compare the account statements
they receive from their custodian with any documents or reports they receive from the Firm or an outside
service provider.
Client Referrals
The Firm may provide compensation to third-party solicitors for client referrals. In the event a client is
introduced to the Firm by either an unaffiliated or an affiliated solicitor, the Firm may pay that solicitor a
referral fee in accordance with applicable state securities laws. Unless otherwise disclosed, any such
referral fee is paid solely from the Firm’s investment management fee and does not result in any
additional charge to the client. If the client is introduced to the Firm by an unaffiliated solicitor, the
solicitor is required to provide the client with the Firm’s written brochure(s) and a copy of a solicitor’s
disclosure statement containing the terms and conditions of the solicitation arrangement. Any affiliated
solicitor of the Firm is required to disclose the nature of his or her relationship to prospective clients at
the time of the solicitation and will provide all prospective clients with a copy of the Firm’s written
brochure(s) at the time of the solicitation.
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Receipt of Economic Benefit and Brokerage Practices
Jeppson Wealth Management generally recommends that clients utilize the custody, brokerage and
clearing services of Charles Schwab & Co., Inc. (“Schwab”) for investment management accounts.
Factors which Jeppson Wealth Management considers in recommending Schwab or any other broker-
dealer to clients include their respective financial strength, reputation, execution, pricing, research and
service.
Jeppson Wealth Management may recommend/require that clients establish brokerage accounts with
the Schwab Advisor Services division of Charles Schwab & Co., Inc. (Schwab), a registered broker-dealer,
member SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. The final
decision to custody assets with Schwab is at the discretion of the Advisor’s clients, 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. Jeppson Wealth Management is independently owned and operated and
not affiliated with Schwab. Schwab provides Jeppson Wealth Management with access to its institutional
trading and custody services, which are typically not available to Schwab retail investors. These services
generally are available to independent investment advisors on an unsolicited basis, at no charge to
advisors. Schwab’s services include brokerage services that are related to the execution of securities
transactions, custody, research, including that in the form of advice, analyses and reports, and access to
mutual funds and other investments that are otherwise generally available only to institutional investors
or would require a significantly higher minimum initial investment.
The execution clients receive from Schwab will comply with the Firm’s duty to obtain “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 Financial
Institution’s services, including among others, the value of research provided, execution capability,
commission rates and responsiveness.
Consistent with obtaining best execution, brokerage transactions may be directed to certain
broker/dealers in return for investment research products and/or services which assist Jeppson Wealth
Management in its investment decision-making process. The receipt of investment research products
and/or services as well as the allocation of the benefit of such investment research products and/or
services poses a conflict of interest because Jeppson Wealth Management does not have to produce or
pay for the products or services.
Jeppson Wealth Management periodically and systematically reviews its policies and procedures regarding
its recommendation of Financial Institutions in light of its duty to obtain best execution.
Schwab also makes available to Jeppson Wealth Management other products and services that benefit
Jeppson Wealth Management but may not benefit its clients’ accounts. These benefits may include
national, regional or Jeppson Wealth Management specific educational events organized and/or
sponsored by Schwab Advisor Services. Other potential benefits may include occasional business
entertainment of personnel of Jeppson Wealth Management by Schwab Advisor Services personnel,
including meals, invitations to sporting events, including golf tournaments, and other forms of
entertainment, some of which may accompany educational opportunities. Other of these products and
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services assist Jeppson Wealth Management in managing and administering clients’ accounts. These
include software and other technology (and related technological training) that provide access to client
account data (such as trade confirmations and account statements), facilitate trade execution (and
allocation of aggregated trade orders for multiple client accounts), provide research, pricing information
and other market data, facilitate payment of Jeppson Wealth Management’s fees from its clients’
accounts, and assist with back-office training and support functions, recordkeeping and client reporting.
Many of these services generally may be used to service all or some substantial number of Jeppson Wealth
Management’s accounts, including accounts not maintained at Schwab Advisor Services. Schwab Advisor
Services also makes available to Jeppson Wealth Management other services intended to help Jeppson
Wealth Management manage and further develop its business enterprise. These services may include
professional compliance, legal and business consulting, publications and conferences on practice
management, information technology, business succession, regulatory compliance, employee benefits
providers, human capital consultants, insurance and marketing. In addition, Schwab may make available,
arrange and/or pay vendors for these types of services rendered to Jeppson Wealth Management by
independent third parties. Schwab Advisor Services may discount or waive fees it would otherwise charge
for some of these services or pay all or a part of the fees of a third-party providing these services to
Jeppson Wealth Management. While, as a fiduciary, Jeppson Wealth Management endeavors to act in its
clients’ best interests, Jeppson Wealth Management’s recommendation/requirement that clients
maintain their assets in accounts at Schwab may be based in part on the benefit to Jeppson Wealth
Management of the availability of some of the foregoing products and services and other arrangements
and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab, which
may create a potential conflict of interest.
Jeppson Wealth Management does not consider, in selecting or recommending broker/dealers, whether
the Firm receives client referrals from the Financial Institutions or other third party.
Financial Information
Jeppson Wealth Management is not required to disclose any financial information due to the following:
•
•
•
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.
The Firm has not been the subject of a bankruptcy petition at any time during the past ten years.
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