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Ledgewood Wealth Advisors, LLC
Form ADV Part 2A
Investment Adviser Brochure
February 6, 2026
92 Portsmouth Avenue, Suite 15
Exeter, NH 03833
603.773.0080
robw@ledgewoodwealth.com
www.ledgewoodwealth.com
This brochure provides information about the qualifications and business practices of Ledgewood
Wealth Advisors, LLC. If you have any questions about the contents of this brochure, please
contact Robert L. Wofchuck, Managing Member and Chief Compliance Officer. The information in
this brochure has not been approved or verified by the United States Securities and Exchange
Commission or by any state securities authority.
Additional information about Ledgewood Wealth Advisors, LLC is also available on the SEC’s
website at www.adviserinfo.sec.gov.
Item 2: Summary of Material Changes
Annual Update
This Item of the brochure is updated if material changes have occurred during the
course of the Firm’s fiscal year; or with the Firm’s Annual Updating Amendment (ADV).
Material Changes since the Last Update
Since the last filing of the annual amendment on February 12, 2025, the following
material changes have been made:
• Regulatory assets under management have been updated as of December 31, 2025 and are
disclosed in Item 4.
• The Firm expanded its risk disclosures to include additional discussion of risks associated
with certain investment strategies, products, and third-party programs that may be
recommended to clients (Item 8).
• Additional disclosure was added regarding the Firm’s potential recommendation of securities
lending programs offered by qualified custodians or third-party lending agents (Items 8, 10,
and 11).
• Custody disclosures were updated to clarify the Firm’s ability to deduct advisory fees and act
pursuant to client-authorized standing letters of authorization (“SLOAs”), consistent with
applicable SEC guidance (Item 15).
• Technology and recordkeeping disclosure was added describing the Firm’s use of automated
transcription or note-taking tools for internal documentation purposes only (Item 11).
Full Brochure Available
We will provide you with a new Brochure as necessary based on changes or new
information, at any time, without charge.
Currently, Ledgewood’s Brochure may be requested by contacting Robert L. Wofchuck,
Managing Member and Chief Compliance Officer, at 603.773.0080 or
robw@ledgewoodwealth.com.
Additional information about Ledgewood is also available via the SEC’s web site
www.adviserinfo.sec.gov. The SEC’s web site also provides information about any
persons affiliated with Ledgewood who are registered, or are required to be registered,
as investment adviser representatives of Ledgewood.
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Item 3: Table of Contents
Item 2: Summary of Material Changes
Annual Update
Material Changes since the Last Update
Full Brochure Available
2
2
2
2
Item 4: Advisory Business
Firm Description and Types of Advisory Services
Principal Owners
Types of Advisory Services
Investment Advisory Services
Financial Planning
Tailored Relationships
Wrap Fee Programs
Private Funds
Client Assets
5
5
5
5
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6
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6
Item 5: Fees and Compensation
Compensation
Calculation and Payment
Agreement Terms
Other Compensation
General Information on Compensation and Other Fees
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8
Item 7: Types of Clients
Types of Clients
Account Minimums
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9
9
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Investment Strategies
Risk of Loss
Other Investments
Securities Lending
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9
10
10
12
12
Item 9: Disciplinary Information
13
Item 10: Other Financial Industry Activities and Affiliations
Financial Industry Activities
13
13
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Code of Ethics
Participation or Interest in Client Transactions – Personal Securities Transactions
Participation or Interest in Client Transactions – Principal/Agency Cross
Participation or Interest in Client Transactions – General Partner
Participation or Interest in Client Transactions – Aggregation
Securities Lending
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14
14
15
15
15
15
Item 12: Brokerage Practices
16
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Research and Other Soft Dollar Benefits
Brokerage for Client Referrals
Directed Brokerage
Directed Brokerage – Other Economic Benefits
Trade Aggregation
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16
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17
17
Item 13: Review of Accounts
Review Triggers
Reporting
Financial Planning – Reviews and Reporting
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19
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Item 14: Client Referrals and Other Compensation
Other Compensation
Other Compensation – Brokerage Arrangements
Compensation – Client Referrals
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Item 15: Custody
Custody – Fee Debiting
Custody – Account Statements
19
19
19
Item 16: Investment Discretion
20
Item 17: Voting Client Securities
20
Item 18: Financial Information
20
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Item 4: Advisory Business
Firm Description and Types of Advisory Services
Ledgewood Wealth Advisors, LLC (“Ledgewood” or “Adviser”) is an investment adviser
that provides continuous and investment supervisory and portfolio management
services to its clients. Ledgewood provides investment advisory services to individuals,
trusts, estates, corporations and business entities. These services include portfolio
management services and financial planning.
Ledgewood was founded in 2000.
Principal Owners
Ledgewood is owned by Robert L. Wofchuck, Managing Member and Chief Compliance
Officer, and Lawrence E. Sarkozy, Chief Operating Officer.
Types of Advisory Services
Recommendations or selections are intended to meet the client’s stated investment
objectives and to provide diversification within the client’s stated objectives. Ledgewood
provides two specific services:
Investment Advisory Services
Ledgewood offers a wide range of financial services to clients based on each client’s
personal needs and investment objectives. Ledgewood will review the financial situation
of each client and if requested, Ledgewood will provide a comprehensive review of the
client’s financial situation and financial plan. Based on the client’s investment objectives
and stated levels of risk tolerance, Ledgewood will recommend an asset allocation
employing various types of securities to meet the client’s goals. These securities will
primarily include equities, both foreign and domestic, fixed income securities, both
taxable and tax-exempt, cash and cash equivalents, and alternative investments if
appropriate. The allocation of the assets is actively monitored and re-allocated as
appropriate to maintain the intended diversity and risk levels.
Ledgewood will manage portfolios directly, either by choosing the individual securities in
each asset class, or by using mutual funds.
Financial Planning
Financial planning is typically offered as a component of Investment Advisory Services
and may include a review of a client’s current financial situation. A review may include
the following components: cash management, risk management, insurance, education
funding, goal setting, retirement planning, estate and charitable giving planning, tax
planning, and capital needs planning. Financial Planning may also be provided exclusive
of Investment Advisory Services.
5 Ledgewood Wealth Advisors, LLC
Tailored Relationships
Ledgewood tailors investment advisory services to the individual needs of the client.
Ledgewood clients are allowed to impose restrictions on the investments in their
account. Ledgewood may accept any reasonable limitation or restriction to
discretionary authority on the accounts placed by the client. All limitations and
restrictions placed on accounts must be presented to Ledgewood in writing.
Wrap Fee Programs
Ledgewood does not participate in a Wrap Fee Program.
Private Funds
Ledgewood does not have any private funds.
Client Assets
As of December 31, 2025, Ledgewood’s regulatory assets under management are as
follows:
Discretionary:
$209,392,612
Non-Discretionary: $ 7,4358,531
Total:
$216,828,143
Item 5: Fees and Compensation
Compensation
Ledgewood bases its fees on a percentage of assets under management, hourly charges,
and fixed fees. Ledgewood’s fee schedules are described below.
Compensation – Investment Advisory Services
For Investment Advisory Services, Ledgewood’s fees vary with the size of the client’s
Account. Generally, this fee is equal to a percentage of the assets under management
calculated using the following tiered schedule. Fees are billed quarterly in advance
based on the value of assets under management on the last business day of the
previous quarter.
On an Annual Basis
(Minimum Account Size $500,000)
First $500,000 1.50%
Next $500,000 0.70%
Next $2 Million 0.60%
6 Ledgewood Wealth Advisors, LLC
Next $2 Million 0.50%
Balance 0.40%
If client uses Pershing Advisor Solutions, LLC (Pershing), transaction and other
miscellaneous service fees are charge directly to the client by Pershing.
Compensation – Financial Planning
For providing financial planning services on a standalone basis, Ledgewood charges
either and hourly or fixed fee. Hourly fees range from $100 to $250 per hour. Fixed
fees range from $3,000 to $15,000. Fee charged will be determined based upon the
complexity of the client’s financial situation, and time estimated to be spent on the in-
depth analysis and plan. Fees are billed to client upon completion of work.
Calculation and Payment
The specific manner in which fees are charged by Ledgewood is established in a
client’s written agreement with Ledgewood. Ledgewood will generally calculate fees in
advance based on the value of assets under management on the last business day of
the previous quarter. Fees are negotiable under certain circumstances. Clients may
elect to be invoiced directly for fees or to authorize Ledgewood to directly debit fees
from client accounts.
Accounts initiated or terminated during a calendar quarter will be charged a prorated
fee. Upon termination of any account, any prepaid, unearned fees will be promptly
refunded, and any earned, unpaid fees will be due and payable.
Agreement Terms
A client may terminate the client agreement at any time by notifying Ledgewood in
writing and paying the rate for the time spent on the investment advisory engagement
prior to notification of termination. If the client made an advance payment, Ledgewood
will refund any unearned portion of the advance payment.
The client or Ledgewood may terminate the investment advisory agreement without
payment of any penalty, by either party giving the other thirty (30) days’ prior written
notice.
Upon notice of termination, Ledgewood will await further instruction from the client as to
what steps the client requests to liquidate and/or transfer the portfolio and remit the
proceeds. Ledgewood, upon instructions from the client, will instruct brokers, dealers,
mutual fund sponsors, and others to liquidate and/or transfer the portfolio and remit the
proceeds to the client. If an investment advisory agreement is terminated, a final fee will
be charged which will be prorated according to the number of days for which
Ledgewood provided its management services during the relevant quarter.
Other Compensation
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Neither Ledgewood nor any of its supervised persons (employees) accept
compensation for the sale of securities or other investment products.
General Information on Compensation and Other Fees
In certain circumstances, fees, account minimums and payment terms are negotiable
depending on client’s unique situation – such as the size of the aggregate related party
portfolio size, family holdings, low cost basis securities, or certain passively advised
investments and pre-existing relationships with clients. Certain clients may pay more or
less than others depending on the amount of assets, type of portfolio, or the time
involved, the degree of responsibility assumed, complexity of the engagement, special
skills needed to solve problems, the application of experience and knowledge of the
client’s situation. Lower fees for comparable services may be available from other
sources.
Ledgewood’s fees are exclusive of brokerage commissions, transaction fees, and other
related costs and expenses which shall be incurred by the client. Clients may incur
certain charges imposed by custodians, brokers, third party investment and other third
parties such as fees charged by managers, custodial fees, 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. Mutual funds and exchange
traded funds also charge internal management fees, which are disclosed in a fund’s
prospectus.
Such charges, fees and commissions are exclusive of and in addition to Ledgewood’s
fee, and Ledgewood shall not receive any portion of these commissions, fees, and
costs.
All fees paid to Ledgewood for investment advisory services are separate and distinct
from the fees and expenses charged by mutual funds and variable annuity sub-
accounts to their shareholders. These fees and expenses are described in each fund’s
or sub account’s prospectus. These fees will generally include a management fee,
other expenses, and a possible distribution fee. If the fund also imposes sales charges,
a client may pay an initial or deferred sales charge.
A client could invest in a mutual fund or sub-account directly, without the services of
Ledgewood. In that case, the client would not receive the services provided by
Ledgewood which are designed, among other things, to assist the client in determining
which mutual funds or sub-accounts are most appropriate to each client’s financial
condition and objectives. Accordingly, the client should review both the fees charged by
the funds/sub-accounts and the fees charged by Ledgewood to fully understand the
total amount of fees to be paid by the client and to thereby evaluate the advisory
services being provided.
Clients should note that similar advisory services may (or may not) be available from
other registered investment advisers for similar or lower fees.
8 Ledgewood Wealth Advisors, LLC
Item 6: Performance-Based Fees and Side-by-Side Management
Neither Ledgewood nor any of its Supervised Persons (employees) accepts
performance-based fees (fees based on a share of capital gains on or capital
appreciation of the assets of a client).
Ledgewood does not use a performance-based fee structure because of the potential
conflict of interest. Performance-based compensation may create an incentive for the
adviser to recommend an investment that may carry a higher degree of risk to the client.
Item 7: Types of Clients
Types of Clients
As described in Item 4, Ledgewood‘s clients include individuals, trusts, estates,
corporations and business entities.
Account Minimums
Ledgewood considers each new prospective client on an individual basis. Although
Ledgewood generally will not accept a new client whose investment account is less than
$500,000 for investment advisory clients, this may be negotiable under certain
circumstances. Ledgewood may group certain related client accounts for the purposes
of achieving the minimum account size.
Item 8: Methods of Analysis, Investment Strategies and Risk of
Loss
Methods of Analysis
Ledgewood regularly seeks to identify industry groups and individual companies for
potential investments. Ledgewood may employ a fundamental security analysis method.
Fundamental Analysis.
Ledgewood attempts to measure the intrinsic value of a security by looking at
economic and financial factors (including the overall economy, industry conditions, and
the financial condition and management of the company itself) to determine if the
company is underpriced (indicating it may be a good time to buy) or overpriced
(indicating it may be time to sell).
Fundamental analysis does not attempt to anticipate market movements. This
presents a potential risk, as the price of a security can move up or down along with
9 Ledgewood Wealth Advisors, LLC
the overall market regardless of the economic and financial factors considered in
evaluating the stock.
Investment Strategies
The investment strategy for a specific client is based upon the objectives stated by the
client during consultations. The client may change these objectives at any time. Each
client executes an Investment Policy Statement that documents their objectives and
their desired investment strategy.
Securities purchased generally meet our definition of good quality stocks and bonds
with fair to excellent marketability. A limited amount of option writing against existing
holdings is done for selected approved accounts. Infrequently, outright purchase of
options is used. Margin transactions are occasionally used.
Other strategies may include long-term purchases, short-term purchases, trading, and
short sales.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear. All
investment programs have certain risks that are borne by the investor. Ledgewood’s
investment approach constantly keeps the risk of loss in mind. Investors face the
following investment risks:
• General Investment and Trading Risks: Clients may invest in securities and
other financial instruments using strategies and investment techniques with
significant risk characteristics. The investment program utilizes such
investment techniques as option transactions, margin transactions, short
sales, leverage, and derivatives trading, the use of which can, in certain
circumstances, maximize the adverse impact to which a Client may be
subject.
•
Interest-rate Risk: Fluctuations in interest rates may cause investment prices
to fluctuate. For example, when interest rates rise, yields on existing bonds
become less attractive, causing their market values to decline.
• Market Risk: The price of a security, bond, or mutual fund may drop in
reaction to tangible and intangible events and conditions. This type of risk is
caused by external factors independent of a security’s particular underlying
circumstances. For example, political, economic and social conditions may
trigger market events.
•
Inflation Risk: When any type of inflation is present, a dollar next year will not
buy as much as a dollar today, because purchasing power is eroding at the
rate of inflation.
• Currency Risk: Overseas investments are subject to fluctuations in the value
of the dollar against the currency of the investment’s originating country. This
is also referred to as exchange rate risk.
10 Ledgewood Wealth Advisors, LLC
• Reinvestment Risk: This is the risk that future proceeds from investments
may have to be reinvested at a potentially lower rate of return (i.e. interest
rate). This primarily relates to fixed income securities.
• Business Risk: These risks are associated with a particular industry or a
particular company within an industry. For example, oil-drilling companies
depend on finding oil and then refining it, a lengthy process, before they can
generate a profit. They carry a higher risk of profitability than an electric
company, which generates its income from a steady stream of customers who
buy electricity no matter what the economic environment is like.
• Liquidity Risk: Liquidity is the ability to readily convert an investment into
cash. Generally, assets are more liquid if many traders are interested in a
standardized product. For example, Treasury Bills are highly liquid, while real
estate properties are not.
• Financial Risk: Excessive borrowing to finance a business’ operations
increases the risk of profitability, because the company must meet the terms
of its obligations in good times and bad. During periods of financial stress,
the inability to meet loan obligations may result in bankruptcy and/or a
declining market value.
• Exchange-Traded Funds: ETFs are a type of index fund bought and sold on a
securities exchange. The risks of owning an ETF generally reflect the risks of
owning the underlying securities they are designed to track, although lack of
liquidity in an ETF could result in it being more volatile and ETFs have
management fees that increase their costs. ETFs are also subject to other
risks, including: (i) the risk that their prices may not correlate perfectly with
changes in the underlying reference units; and (ii) the risk of possible trading
halts due to market conditions or other reasons that, in the view of the
exchange upon which an ETF trades, would make trading in the ETF
inadvisable.
• Mutual Fund Risks: An investment in mutual funds could lose money over
short or even long periods. A mutual fund’s share price and total return are
expected to fluctuate within a wide range, like the fluctuations of the overall
stock market.
• Common Stocks and Equity-Related Securities: Certain ETFs or mutual funds
hold common stock. Prices of common stock react to the economic condition
of the company that issued the security, industry and market conditions, and
other factors which may fluctuate widely. Investments related to the value of
stocks may rise and fall based on an issuer’s actual and anticipated earnings,
changes in management, the potential for takeovers and acquisitions, and
other economic factors. Similarly, the value of other equity-related securities,
including preferred stock, warrants, and options may also vary widely.
• Cybersecurity Risk: Ledgewood and its service providers may be subject to
operational and information security risks resulting from cyberattacks.
11 Ledgewood Wealth Advisors, LLC
Cyberattacks include, among other behaviors, stealing or corrupting data
maintained online or digitally, denial of service attacks on websites, the
unauthorized release of confidential information or various other forms of
cybersecurity breaches. Cybersecurity attacks affecting Ledgewood and its
service providers may adversely impact Clients. For instance, cyberattacks
may interfere with the processing of transactions, cause the release of private
information about Clients, impede trading, subject Ledgewood to regulatory
fines or financial losses, and cause reputational damage. Similar types of
cybersecurity risks are also present for issuers of securities in which Clients
may invest in, qualified custodians, governmental and other regulatory
authorities, exchange and other financial market operators, or other financial
institutions. Cybersecurity incidents that could ultimately cause them to incur
losses, including for example: financial losses, cost and reputational
damages, and loss from damage or interruption of systems. Although
Ledgewood has established its systems to reduce the risk of these incidents
from coming to fruition, there is no guarantee that these efforts will always be
successful, especially considering that Ledgewood does not directly control
the cybersecurity measures and policies employed by third party service
providers.
• Management Risk: The advisor’s investment approach may fail to produce
the intended results. If the advisor’s assumptions regarding the performance
of a specific asset class or fund are not realized in the expected time frame,
the overall performance of the Client’s portfolio may suffer.
Other Investments
Ledgewood may recommend the purchase of interests in partnerships as alternative
investments to clients for whom such investments are suitable and meet the client’s
investment objectives.
Ledgewood reserves the right to advise clients on any other type of investment that it
deems appropriate based on the client’s stated goals and objectives. Ledgewood may
also provide advice on any type of investment held in a client’s portfolio at the inception
of the advisory relationship or on any investment on which the client requests advice.
Securities Lending
From time to time, the Ledgewood may recommend that certain clients participate in a
securities lending program offered by a qualified custodian or third-party lending agent.
Securities lending involves the temporary loan of securities held in a client’s account to
third parties, typically in exchange for income to the client and is subject to various risks,
including counterparty risk, delayed return of securities, collateral management risk, and
potential tax consequences. Participation in securities lending may also limit the client’s
ability to sell or transfer loaned securities until they are returned.
12 Ledgewood Wealth Advisors, LLC
The Adviser does not act as a securities lending agent, does not take custody of loaned
securities or collateral, and does not receive compensation in connection with securities
lending unless otherwise disclosed. Participation in securities lending is voluntary and
governed by the terms of the applicable custodial or lending agreement.
Item 9: Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any
legal or disciplinary events that would be material to your evaluation of Ledgewood or
the integrity of Ledgewood’s management. Ledgewood has no information to disclose
applicable to this Item.
Item 10: Other Financial Industry Activities and Affiliations
Financial Industry Activities
Neither Ledgewood nor its management persons are registered as a broker-dealer or
broker-dealer representative.
Neither Ledgewood nor its management persons are registered as futures commission
merchant, commodity pool operator, or a commodity trading advisor.
Neither Ledgewood nor its management persons have any additional material
relationships to this advisory business that would present a possible conflict of interest
other than what may be disclosed above.”
● Ledgewood does not utilize nor select other advisors.
Financial Industry Affiliations – Sponsor or Syndicator of Limited Partnerships
Ledgewood has no relationship or arrangement with related persons or financial
industry entities as a sponsor or syndicator of limited partnerships.
Other Investment Advisors
Ledgewood does not recommend or select other investment advisors for its clients.
Securities Lending
Ledgewood and its supervised persons are not engaged in any securities lending,
broker-dealer, or banking activities and do not act as a securities lending agent.
Securities lending programs, if recommended, are administered by the client’s qualified
custodian or its designated third-party lending agent. The Adviser does not have any
arrangements with custodians or third-party lending agents that would materially affect
13 Ledgewood Wealth Advisors, LLC
its advisory business or create additional conflicts of interest in connection with
securities lending.
Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
Code of Ethics
Ledgewood’s employees must comply with a Code of Ethics and Statement for Insider
Trading. The Code describes the Firms’ high standard of business conduct, and
fiduciary duty to its clients. The Code’s key provisions include:
• Statement of General Principles
• Policy on and reporting of Personal Securities Transactions
• A prohibition on Insider Trading
• Restrictions on the acceptance of significant gifts
• Procedures to detect and deter misconduct and violations
• Requirement to maintain confidentiality of client information
The Firm may utilize third-party technology tools, including automated transcription or
note-taking applications, to assist with internal documentation and recordkeeping of
client meetings and communications. These tools are used for administrative purposes
only and do not replace the Firm’s professional judgment or decision-making. The Firm
seeks to maintain appropriate safeguards to protect client information when using such
technology and does not permit the use of client information for purposes unrelated to
the Firm’s advisory services.
Robert L. Wofchuck, Managing Member and Chief Compliance Officer, reviews all
employee trades each quarter. All access persons are required to submit initial and
annual holdings reports and quarterly transaction reports in accordance with Rule 204A-
1 under the Advisers Act. These reviews ensure that personal trading does not affect
the markets, and that clients of Ledgewood receive preferential treatment.
Ledgewood’s employees must acknowledge the terms of the Code of Ethics at least
annually. Any individual not in compliance with the Code of Ethics may be subject to
termination.
Clients and prospective clients can obtain a copy of Ledgewood’s Code of Ethics by
contacting Robert L. Wofchuck at 603.773.0080.
Participation or Interest in Client Transactions – Personal Securities Transactions
Ledgewood and its employees may buy or sell securities identical to those
recommended to clients for their personal accounts. The Code of Ethics, described
above, is designed to assure that the personal securities transactions, activities and
interests of the employees of Ledgewood will not interfere with (i) making decisions in
14 Ledgewood Wealth Advisors, LLC
the best interest of advisory clients and (ii) implementing such decisions while, at the
same time, allowing employees to invest for their own accounts. Under the Code certain
classes of securities, primarily mutual funds, have been designated as exempt
transactions, based upon a determination that these would materially not interfere with
the best interest of Ledgewood’s clients. In addition, the Code requires pre-clearance of
many transactions. Nonetheless, because the Code of Ethics in some circumstances
would permit employees to invest in the same securities as clients, there is a possibility
that employees might benefit from market activity by a client in a security held by an
employee. Employee trading is continually monitored under the Code of Ethics, and
designed to reasonably prevent conflicts of interest between Ledgewood and its clients.
No security may be bought or sold by a principal or employee of Ledgewood before
Ledgewood’s clients’ accounts have had the opportunity to make such transactions as
appropriate. Principals and employees will not receive a more favorable execution price
on a particular day than those received by Ledgewood’s investment advisory clients.
Participation or Interest in Client Transactions – Principal/Agency Cross
It is Ledgewood’s policy that the Firm will not affect any principal or agency cross
securities transactions for client accounts. Ledgewood will also not cross trades
between client accounts.
Participation or Interest in Client Transactions – General Partner
Neither Ledgewood nor its employees recommend to clients or buy or sell for client
accounts, securities in which they have a material financial interest.
Participation or Interest in Client Transactions – Aggregation
Ledgewood and its employees may trade in the same securities with client accounts on
an aggregated basis when consistent with Ledgewood’s obligation of best execution. In
such circumstances, the affiliated and client accounts will share commission costs
equally and receive securities at a total average price. Ledgewood will retain records of
the trade order (specifying each participating account) and its allocation, which will be
completed prior to the entry of the aggregated order. Completed orders will be allocated
as specified in the initial trade order.
Securities Lending
Ledgewood may recommend that certain clients participate in securities lending
programs offered by their qualified custodians. The Adviser does not receive
compensation, fees, or other economic benefits in connection with client participation in
securities lending programs. Because securities lending is administered by the client’s
custodian pursuant to custodial agreements entered into directly between the client and
the custodian, the Adviser does not participate in the execution, administration, or
collateral management of securities lending transactions. The Adviser’s
recommendation of securities lending is based on the client’s individual investment
objectives, liquidity needs, risk tolerance, and overall financial circumstances. The
15 Ledgewood Wealth Advisors, LLC
Adviser maintains a Code of Ethics that addresses conflicts of interest and requires
supervised persons to act in the best interests of clients at all times.
Item 12: Brokerage Practices
Research and Other Soft Dollar Benefits
Ledgewood does not receive formal soft dollar benefits other than execution from
broker/dealers in connection with client securities transactions. The Adviser receives
certain economic benefits from Pershing that may present a potential conflict of interest.
These benefits do not influence the selection of custodians or brokers. See disclosure
below in “Directed Brokerage – Other Economic Benefits”.
Brokerage for Client Referrals
Ledgewood does not receive client referrals from broker/dealers.
Directed Brokerage
While not routine, the client may direct Ledgewood to use a particular broker-dealer to
execute some or all transactions for the client. This brokerage direction must be
requested by the client in writing. In that case, the client will negotiate terms and
arrangements for the account with that broker-dealer, and Ledgewood will not seek
better execution services or prices from other broker-dealers or be able to “batch” client
transactions for execution through other broker-dealers with orders for other accounts
managed by Ledgewood. By directing brokerage, the client may pay higher
commissions or other transaction costs or greater spreads, or receive less favorable net
prices, on transactions for the account than would otherwise be the case. Not all
advisers require or allow their clients to direct brokerage. Subject to its duty of best
execution, Ledgewood may decline a client’s request to direct brokerage if, in
Ledgewood’s sole discretion, such directed brokerage arrangements would result in
additional operational difficulties.
Unless the client instructs Ledgewood otherwise, the Firm may place orders for the
execution of transactions with Pershing or through a broker/dealer as Ledgewood may
select, and complying with Section 28(e) of the Securities Exchange Act of 1934, may
pay a commission on transactions in excess of the amount of commission another
broker or dealer would have charged. Ledgewood will select such brokers that can
effect transactions at the best price and execution under the prevailing circumstances.
In managing investment portfolios, Ledgewood acts in a manner in keeping with what it
understands and believes to be the best interests of the client.
Generally, Ledgewood will select brokers that can effect transactions at the best
execution under the prevailing circumstances or that can supply research or other
brokerage services to Ledgewood. Ledgewood will supervise and monitor the
investments of clients’ accounts subject to such limitations as the client may impose in
16 Ledgewood Wealth Advisors, LLC
writing. Ledgewood, as agent and attorney-in-fact with respect to the client’s account,
without prior consultation with the client, may, (a) direct the purchase, sell, exchange,
conversion, and otherwise trade in stocks, bonds and other securities including money
market instruments, (b) direct the amount of securities purchased, sold, exchanged, and
otherwise traded, (c) place orders for the execution of such securities transactions with
Pershing or other third party broker/dealers.
Occasionally, trades are done with brokers who are selected on the basis of research
products or other brokerage services. These may be used for the benefit of all clients
and are not necessarily used exclusively by the account for which the transaction was
made. The types of products and services include written and oral reports concerning
current or prospective portfolio holdings, economic interpretations, and portfolio
strategy. Ledgewood may also compensate brokerage firms that supply research of
their own or that of a third party. Such information is available to assist in the
management of all of Ledgewood’s clients whether or not all commissions are available
for use in this matter. When selecting brokers Ledgewood is guided by: (a) its
responsibility to act as a fiduciary when handling client accounts, and (b) the obligation
(subject to the conditions specified above) to seek best execution in all client trades.
Ledgewood has no written or verbal arrangements whereby it receives soft dollars.
While Ledgewood endeavors at all times to put the interest of the clients first as part of
its fiduciary duty, clients should be aware that the receipt of any additional
compensation itself creates a conflict of interest, and may affect the judgment of these
individuals when making recommendations.
When Ledgewood selects brokers other than Pershing, various factors are used in the
selection, including the full range of products offered, including brokerage and research
services. Although Ledgewood may pay commissions higher than those obtainable by
brokers who do not provide brokerage and research services, Ledgewood attempts to
place the execution of transactions with brokers that offer the best combination of price
and execution (including brokerage commissions) who are competitively priced in line
with industry practice.
Directed Brokerage – Other Economic Benefits
Pershing provides Ledgewood with some non-monetary economic benefits. These
include the receipt of duplicate client confirmations and bundled duplicate statements,
access to a trading desk serving Pershing platform participants exclusively, access to
block trading which provides the ability to aggregate securities transactions and then
allocate the appropriate shares to client accounts, ability to have investment advisory fees
deducted directly from client account, access to an electronic communications network
for client order entry and account information, receipt of compliance publications, and
access to mutual funds which generally require significantly higher minimum initial
investments or are generally available only to institutional investors.
Trade Aggregation
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Ledgewood in its sole discretion may elect to combine or “bunch” an order entered for
Client with other orders entered for the same security for other Clients to secure certain
efficiencies and results with respect to execution, clearance and settlement of such
orders. Ledgewood, in its discretion may use the average price at which a security is
bought or sold for the customers involved in the transaction when a bunched order is
executed in parts at different prices, or when two or more separate orders for the same
security are entered at approximately the same time and are executed at different
prices. In making decisions concerning bunching, price averaging, allocating among
clients’ accounts the securities so sold or purchased and the related transaction
expenses, Ledgewood will act in a manner Ledgewood considers to be equitable, taking
into consideration its fiduciary duties to all its clients. In some instances bunching or
price averaging may adversely affect the price paid or received by the Account or the
number of shares of a Security bought or sold for the Account.
Generally, commissions paid to brokers and overall execution costs for bunched trades
will be equal to or lower than those that would apply had the trades been executed
individually.
Accounts for Ledgewood or its employees will be included in a block trade with client
accounts.
Item 13: Review of Accounts
Reviews
Each client portfolio receives continuous monitoring by Robert Wofchuck, Managing
Member and Chief Compliance Officer. This is intended to ensure that each portfolio is
invested in accordance with the client’s investment objectives and risk tolerance.
Portfolios are also reviewed for proper levels of diversification.
If a client retains Ledgewood for Investment Advisory Services, including
continuous advice, recommendations, and monitoring of the client’s financial
situation then Ledgewood will review the account with the client on an annual basis
or otherwise, depending upon the preference of the client and the nature of the
investments. Triggers for reviews will be the agreed upon period with client or
specific client request but no less then annually.
If a client retains Ledgewood only for the review of the client’s current financial
situation and nothing else, there will be no further review after the issuance of the
requested report which renders advice, counsel and/or recommendations.
Review Triggers
Other conditions that may trigger a review are changes in market, political or economic
conditions, tax laws, new investment information, and changes in a client's own
situation.
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Reporting
The nature and frequency of reports to clients are determined primarily by the
particular needs of each client. However, confirmations will be forwarded by the
executing broker or its clearing firm to clients on the next business day following
the execution of a transaction in the client’s account. Quarterly account statements
are sent by the executing broker or its clearing firm.
Financial Planning – Reviews and Reporting
Financial Planning clients will be reviewed and receive reports as contracted for at the
inception of the engagement.
Item 14: Client Referrals and Other Compensation
Other Compensation
Ledgewood does not receive any economic benefits (other than normal compensation
and as described in Item 12) from any firm or individual for providing investment advice.
Other Compensation – Brokerage Arrangements
See disclosure in Item 12 regarding compensation, including economic benefits
received in connection with giving advice to clients.
Compensation – Client Referrals
Ledgewood does not make or accept referral fees or any form of remuneration from
other professionals when a prospect or client is referred to them.
Item 15: Custody
Custody – Fee Debiting
Ledgewood may be deemed to have custody solely due to its ability to deduct fees or
act under client-authorized standing letters of authorization (‘SLOAs’). Ledgewood relies
on SEC no-action relief (IM Guidance 2017) to avoid separate surprise examination
requirements. Clients may authorize Ledgewood (in the client agreement) to debit fees
directly from the client’s account at the broker dealer, bank or other qualified custodian
(custodian). Client investment assets will be held with a custodian agreed upon by the
client and Ledgewood. The custodian is advised in writing of the limitation of
Ledgewood’s access to the account. The custodian sends a statement to the client, at
least quarterly, indicating all amounts disbursed from the account including the amount
of advisory fees paid directly to Ledgewood.
Custody – Account Statements
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As described above and in Item 13, clients receive at least quarterly statements from
the broker dealer, bank or other qualified custodian that holds and maintains client’s
investment assets. Clients are urged to carefully review such statements and compare
such official custodial records to the account statements or other reports that
Ledgewood provides. Ledgewood statements may vary from custodial statements
based on accounting procedures, reporting dates, or valuation methodologies of certain
securities.
Item 16: Investment Discretion
Through the investment management agreement, Ledgewood may accept limited power
of attorney to act on a discretionary basis on behalf of clients. A limited power of
attorney allows Ledgewood to execute trades on behalf of clients.
When such limited powers exist between Ledgewood and the client, Ledgewood has
the authority to determine, without obtaining specific client consent, both the amount
and type of securities to be bought to satisfy client account objectives. Additionally,
Ledgewood may accept any reasonable limitation or restriction to such authority on the
account placed by the client. All limitations and restrictions placed on accounts must be
presented to Ledgewood in writing.
If Ledgewood has not been given discretionary authority, Ledgewood consults with the
client prior to each trade.
Item 17: Voting Client Securities
Ledgewood does not have any authority to and does not vote proxies on behalf of
clients. Clients retain the responsibility for receiving and voting proxies for securities
maintained in their portfolios; clients receive proxies directly from either custodians or
transfer agents.
Item 18: Financial Information
Ledgewood has no financial condition that is reasonably likely to impair its ability to
meet contractual and fiduciary commitments to clients, and has not been the subject of
a bankruptcy proceeding.
Ledgewood is not required to provide a balance sheet; Ledgewood does not serve as a
custodian for client funds or securities, and does not require prepayment of fees of both
more than $1,200 per client, and more than six months in advance.
20 Ledgewood Wealth Advisors, LLC