View Document Text
November 25, 2025
Disclosure Brochure
LIFELONG WEALTH ADVISORS, INC.
a Registered Investment Adviser
1150 County Road E West
Arden Hills, MN 55112
(651) 444-6500
www.llwadvisors.com
This brochure provides information about the qualifications and business practices of Lifelong Wealth
Advisors, Inc (hereinafter “LLW Advisors” or the “Firm”). If you have any questions about the contents of this
brochure, please contact the Firm at the telephone number listed above. 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. The Firm is a registered investment adviser. Registration does not imply any level
of skill or training.
Disclosure Brochure
Lifelong Wealth Advisors, Inc.
Item 2. Material Changes
In this Item, LLW Advisors is required to discuss any material changes that have been made to the brochure
since the last annual amendment. Since the last annual update filed on March 19, 2025, this Brochure has
been revised to reflect the following material changes:
•
Item 17 has been updated to clarify that LLW no longer maintains proxy voting authority on behalf
of clients; and
•
Item 4 has been updated to remove Texting Access as an available service.
We encourage you to review the entire Brochure for a complete description of our services and policies. A
copy of the Brochure is available on the SEC’s website at www.adviserinfo.sec.gov, or we will provide you
with a summary of material changes made to this brochure annually at no cost. You may receive an updated
copy of this brochure at any time by contacting us at (651) 444-6500.
Page | 2
Disclosure Brochure
Lifelong Wealth Advisors, Inc.
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 ............................................................................... 10
Item 7. Types of Clients .............................................................................................................................................. 10
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ........................................................................ 10
Item 9. Disciplinary Information ................................................................................................................................. 13
Item 10. Other Financial Industry Activities and Affiliations ...................................................................................... 14
Item 11. Code of Ethics ............................................................................................................................................... 14
Item 12. Brokerage Practices ....................................................................................................................................... 15
Item 13. Review of Accounts ...................................................................................................................................... 18
Item 14. Client Referrals and Other Compensation ..................................................................................................... 19
Item 15. Custody ......................................................................................................................................................... 19
Item 16. Investment Discretion ................................................................................................................................... 20
Item 17. Voting Client Securities ................................................................................................................................ 20
Item 18. Financial Information .................................................................................................................................... 21
Page | 3
Disclosure Brochure
Lifelong Wealth Advisors, Inc.
Item 4. Advisory Business
LLW Advisors offers a variety of advisory services, which include financial planning, consulting, and
investment management services. Prior to LLW Advisors rendering any of the foregoing advisory services,
clients are required to enter into one or more written agreements with LLW Advisors setting forth the
relevant terms and conditions of the advisory relationship (the “Advisory Agreement”).
LLW Advisors is a registered investment adviser with the U.S. Securities and Exchange Commission and
is owned by Robert M. Bonine, Anders J. Haugen and Jeremy M. Lipinski. As of December 31, 2024,
LLW Advisors has $615,076,306 of assets under management.
While this brochure generally describes the business of LLW Advisors, certain sections also discuss the
activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons
occupying a similar status or performing similar functions), employees or other persons who provide
investment advice on LLW Advisors’s behalf and are subject to the Firm’s supervision or control.
Financial Planning and Consulting Services
LLW Advisors offers clients a broad range of financial planning and consulting services listed below based
on client needs and goals, which include any or all of the following functions:
Risk Budgeting
Financial Plan/Report/Consultation
•
•
Financial Advice
Legacy Planning
•
•
Investment Analysis
P&C Analysis
•
•
Philanthropic Planning
Retirement Planning
•
•
Estate Planning
Health Care Planning
•
•
Cash Flow Management
Debt Management
•
•
Education Planning
Net Worth Evaluation
•
•
Financial Planning Team
Insurance/Risk Management
•
•
Tax Analysis
Behavioral Financial Advice
•
•
Goal Planning
•
While each of these services is available on a stand-alone basis, certain of them can also be rendered in
conjunction with investment portfolio management as part of a comprehensive wealth management
engagement (described in more detail below).
Page | 4
Disclosure Brochure
Lifelong Wealth Advisors, Inc.
In performing these services, LLW Advisors is not required to verify any information received from the
client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized
to rely on such information. LLW Advisors recommends certain clients engage the Firm for additional
related services, its Supervised Persons in their individual capacities as insurance agents and/or other
professionals to implement its recommendations. Clients are advised that a conflict of interest exists for
the Firm to recommend that clients engage LLW Advisors or its affiliates to provide (or continue to provide)
additional services for compensation, including investment management services. Clients retain absolute
discretion over all decisions regarding implementation and are under no obligation to act upon any of the
recommendations made by LLW Advisors 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 LLW Advisors’s
recommendations and/or services.
Investment and Wealth Management Services
LLW Advisors provides clients with wealth management services which include a broad range of financial
planning and consulting services as well as discretionary management of investment portfolios.
Alternatively, clients can also engage the Firm to provide only investment management services.
LLW Advisors primarily allocates client assets among various mutual funds, exchange-traded funds
(“ETFs”), independent investment managers (“Independent Managers”) and direct indexing in accordance
with their stated investment objectives.
Where appropriate, the Firm also provides advice about any type of legacy position or other investment
held in client portfolios, but clients should not assume that these assets are being continuously monitored
or otherwise advised on by the Firm unless specifically agreed upon. Clients can engage LLW Advisors 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
and qualified tuition plans (i.e., 529 plans). In these situations, LLW Advisors 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.
LLW Advisors 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. LLW Advisors 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 LLW Advisors if there are changes in their financial
situation or if they wish to place any limitations on the management of their portfolios. Clients can impose
reasonable restrictions or mandates on the management of their accounts if LLW Advisors determines, in
Page | 5
Disclosure Brochure
Lifelong Wealth Advisors, Inc.
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.
Retirement Plan Consulting Services
LLW Advisors provides various consulting services to qualified employee benefit plans and their
fiduciaries. These services are limited to providing education to participants and helping with their
enrollment. The Firm does not act as an ERISA fiduciary when providing these services, but is still subject
to fiduciary duty under the Investment Advisers Act of 1940, as amended.
Use of Independent Managers
As mentioned above, LLW Advisors selects certain Independent Managers to actively manage a portion of
its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager
are set forth in a separate written agreement with the designated Independent Manager. That agreement can
be between the Firm and the Independent Manager (often called a subadvisor) or the client and the
Independent Manager (sometimes called a separate account manager). In addition to this brochure, clients
will typically also receive the written disclosure documents of the respective Independent Managers
engaged to manage their assets.
LLW Advisors evaluates a variety of information about Independent Managers, which includes the
Independent Managers’ public disclosure documents, materials supplied by the Independent Managers
themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks
to assess the Independent Managers’ investment strategies, past performance and risk results in relation to
its clients’ individual portfolio allocations and risk exposure. LLW Advisors also takes into consideration
each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing
and research capabilities, among other factors.
LLW Advisors continues to provide services relative to the discretionary selection of the Independent
Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by
Independent Managers. LLW Advisors seeks to ensure the Independent Managers’ strategies and target
allocations remain aligned with its clients’ investment objectives and overall best interests.
Item 5. Fees and Compensation
LLW Advisors offers services on a fee basis, which includes fixed fees, as well as fees based upon assets
under management or advisement. Additionally, certain of the Firm’s Supervised Persons, in their
individual capacities, offer insurance products under a separate commission-based arrangement.
Page | 6
Disclosure Brochure
Lifelong Wealth Advisors, Inc.
Financial Planning and Consulting Fees
LLW Advisors charges a fixed fee for providing financial planning and consulting services under a stand-
alone engagement. These fees are negotiable, but range up to $15,000, depending upon the scope and
complexity of the services and the professional rendering the financial planning and/or the consulting
services. If the client engages the Firm for additional investment advisory services, LLW Advisors can
offset all or a portion of its fees for those services based upon the amount paid for the financial planning
and/or consulting services.
The terms and conditions of the financial planning and/or consulting engagement are set forth in the
Advisory Agreement. For project-based services LLW Advisors requires one-half of the fee payable upon
execution of the Advisory Agreement. The Firm does not, however, take receipt of $1,200 or more in
prepaid fees, six or more months in advance of services rendered.
Investment Management Fees
LLW Advisors offers investment management services for an annual fee based on the amount of assets
under the Firm’s management. This management fee varies in accordance with the following blended fee
schedules which are dependent upon the amount of financial planning and consulting services included in
the fee. The different service levels referenced below will include various numbers of financial planning or
consulting services, as agreed upon.
Standard
PORTFOLIO VALUE
BASE FEE
First $300,000
Next $300,000
Next $400,000
Next $1,500,000
Above $2,500,000
1.75%
1.50%
0.70%
0.55%
0.25%
Hybrid
PORTFOLIO VALUE
BASE FEE
First $300,000
Next $300,000
Next $400,000
Next $1,500,000
Above $2,500,000
1.50%
1.20%
0.60%
0.50%
0.25%
Page | 7
Disclosure Brochure
Lifelong Wealth Advisors, Inc.
Compact
PORTFOLIO VALUE
BASE FEE
First $300,000
Next $300,000
Next $400,000
Next $1,500,000
Above $2,500,000
1.25%
0.85%
0.50%
0.45%
0.25%
The annual fee is prorated and charged quarterly, in advance, based upon the market value of the assets
being managed by LLW Advisors on the last day of the previous quarter determined by a party independent
from the Firm (including the client’s custodian or another third-party). Alternatively, the Firm may charge
a fixed fee for the investment management services. The fixed fee will be individually negotiated and will
be based upon a number of factors including the size and composition of a client’s portfolio, the type and
amount of services rendered and the individual(s) providing the services.
The Firm includes cash in a client’s account in determining the valuation for billing purposes. The Firm
may, in its sole discretion, not include cash in determining the fee, especially where a client has a high
percentage of cash for reasons other than the Firm's investment management decision.
If assets 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 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.), LLW Advisors can negotiate a
fee rate that differs from the range set forth above. Clients are advised that a conflict of interest exists for
the Firm to recommend that clients engage LLW Advisors for additional services for compensation,
including rolling over retirement accounts or moving other assets to the Firm’s management. Clients retain
absolute discretion over all decisions regarding engaging the Firm and are under no obligation to act upon
any of the recommendations.
Retirement Plan Consulting Fees
LLW Advisors charges as fixed fee to provide clients with retirement plan consulting services. Each
engagement is individually negotiated and tailored to accommodate the needs of the individual plan
sponsor, as memorialized in the Agreement.
Page | 8
Disclosure Brochure
Lifelong Wealth Advisors, Inc.
Fee Discretion
LLW Advisors 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,
pro bono activities, or competitive purposes.
Additional Fees and Expenses
In addition to the advisory fees paid to LLW Advisors, clients 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 include securities brokerage commissions,
transaction fees, custodial fees, fees attributable to alternative assets, fees charged by the Independent
Managers, margin and other borrowing 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’s brokerage practices are
described at length in Item 12, below.
Direct Fee Debit
Clients provide LLW Advisors and/or certain Independent Managers with the authority to directly debit
their accounts for payment of the investment advisory fees. The Financial Institutions that act as the
qualified custodian for client accounts, from which the Firm retains the authority to directly deduct fees,
have agreed to send statements to clients not less than quarterly detailing all account transactions, including
any amounts paid to LLW Advisors.
Account Additions and Withdrawals
Clients can make additions to and withdrawals from their account at any time, subject to LLW Advisors’s
right to terminate an account. Additions can be in cash or securities provided that the Firm reserves the
right to liquidate any transferred securities or declines to accept particular securities into a client’s account.
Clients can withdraw account assets on notice to LLW Advisors, subject to the usual and customary
securities settlement procedures. However, the Firm designs its portfolios as long-term investments and the
withdrawal of assets may impair the achievement of a client’s investment objectives. LLW Advisors 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.
Page | 9
Disclosure Brochure
Lifelong Wealth Advisors, Inc.
Item 6. Performance-Based Fees and Side-by-Side Management
LLW Advisors does not provide any services for a performance-based fee (i.e., a fee based on a share of
capital gains or capital appreciation of a client’s assets).
Item 7. Types of Clients
LLW Advisors offers services to individuals, trusts, estates, and profit sharing plans.
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis and Investment Strategies
LLW Advisors’s mission is to bring all pieces of its clients’ financial lives together by listening to their
goals and customizing a strategic plan. The Firm’s commitment to this mission is defined by three core
principles:
I. Consultative Approach
•
Interactive discovery and active listening help the Firm understand what is truly important to each
client.
• A tailored plan and investment strategy is designed based on a realistic picture of each client’s current
situation and stated needs.
• The Firm looks to make sound recommendations using clear, straightforward language to help ease
decision making.
II. Tailored Strategies
• A team approach with experienced and credentialed professionals with a goal of allowing for
specialization and innovation.
• A clear and understandable investment approach coupled with tested principles helps the Firm build
portfolios customized for each client.
• The ability to leverage resources and collaborate with other professionals allows for cohesiveness.
III. Personal Attention
Page | 10
Disclosure Brochure
Lifelong Wealth Advisors, Inc.
• A demonstrated commitment to accessibility, responsiveness, and approachability.
• Ongoing reviews and proactive communication allows clients to know where they stand.
• Flexibility, independence, and acting in the client’s best interest in order to help create comfort and
trust.
The Firm believes that money is a tool to help achieve the things that are most important to the people it
serves. LLW Advisors is committed to a proactive and holistic planning approach which focuses on the
priorities of its clients’ financial life. Each client goes through the Firm’s investment process, financial plan
and advice. That includes asset allocation, portfolio construction, portfolio management, regular reviews,
delivery of a plan and implementation, as well as advice on estate planning, retirement income, tax
management and insurance and risk management. The Firm’s services include advice regarding:
Insurance (see description in Item 10, below)
•
Investments
• Retirement
•
• Education
• Estate
Risk of Loss
The following list of risk factors does not purport to be a complete enumeration or explanation of the risks
involved with respect to the Firm’s investment management activities. Clients should consult with their
legal, tax, and other advisors before engaging the Firm to provide investment management services on their
behalf.
Market Risks
Investing involves risk, including the potential loss of principal, and all investors should be guided
accordingly. The profitability of a significant portion of LLW Advisors’s recommendations and/or
investment decisions may depend to a great extent upon correctly assessing the future course of price
movements of stocks, bonds and other asset classes. In addition, investments may be adversely affected by
financial markets and economic conditions throughout the world. There can be no assurance that LLW
Advisors will be able to predict these price movements accurately or capitalize on any such assumptions.
Volatility Risks
The prices and values of investments can be highly volatile, and are influenced by, among other things,
interest rates, general economic conditions, the condition of the financial markets, the financial condition
of the issuers of such assets, changing supply and demand relationships, and programs and policies of
governments.
Page | 11
Disclosure Brochure
Lifelong Wealth Advisors, Inc.
Cash Management Risks
The Firm may invest some of a client’s assets temporarily in money market funds or other similar types of
investments, during which time an advisory account may be prevented from achieving its investment
objective.
Mutual Funds and ETFs
An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF
shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s
underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains,
as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for
a profit that cannot be offset by a corresponding loss.
Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a
broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily
per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees, redemption
fees). The per share NAV of a mutual fund is calculated at the end of each business day, although the actual
NAV fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a
mutual fund’s shares may differ from the NAV during periods of market volatility, which may, among other
factors, lead to the mutual fund’s shares trading at a premium or discount to actual NAV.
Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary
market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least
once daily for index-based ETFs and potentially more frequently for actively managed ETFs. However,
certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There
is also no guarantee that an active secondary market for such shares will develop or continue to exist.
Generally, an ETF only redeems shares when aggregated as creation units (usually 20,000 shares or more).
Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may
have no way to dispose of such shares.
Finally, some mutual funds and ETFs may have lock-up periods that restrict an investor from selling their
position for a period of time. Other mutual funds and ETFs could also have early redemption fees that are
taken if the investor sells their position before a certain amount of time.
Use of Independent Managers
As stated above, LLW Advisors selects certain Independent Managers to manage a portion of its clients’
assets. In these situations, LLW Advisors continues to conduct ongoing due diligence of such managers,
but such recommendations rely to a great extent on the Independent Managers’ ability to successfully
implement their investment strategies. In addition, LLW Advisors does not have the ability to supervise
the Independent Managers on a day-to-day basis.
Page | 12
Disclosure Brochure
Lifelong Wealth Advisors, Inc.
Management through Similarly Managed “Model” Accounts
LLW Advisors manages certain accounts through the use of similarly managed “model” portfolios, whereby
the Firm allocates all or a portion of its clients’ assets among various mutual funds and/or securities on a
discretionary basis using one or more of its proprietary investment strategies. In managing assets through
the use of models, the Firm remains in compliance with the safe harbor provisions of Rule 3a-4 of the
Investment Company Act of 1940.
The strategy used to manage a model portfolio may involve an above average portfolio turnover that could
negatively impact clients’ net after tax gains. While the Firm seeks to ensure that clients’ assets are managed
in a manner consistent with their individual financial situations and investment objectives, securities
transactions effected pursuant to a model investment strategy are usually done without regard to a client’s
individual tax ramifications. Clients should contact the Firm if they experience a change in their financial
situation or if they want to impose reasonable restrictions on the management of their accounts.
Cyber Security
With the increased use of technologies such as the internet to conduct business, the Firm and other service
providers used by the Firm, of as well as the underlying investments made by clients are susceptible to
operational, information security and related risks. In general, cyber incidents can result from deliberate
attacks or unintentional events and may arise from external or internal sources. Cyber incidents have the
ability to cause disruptions and impact business operations, potentially resulting in financial losses, the
release of investor information or confidential business information, interference with the ability to
calculate the value of client investments, destruction to equipment and systems, violations of applicable
privacy and other laws, regulatory fines or penalties, reputation damage, or additional compliance costs.
The Firm will seek to implement safeguards to protect clients against cyber attacks. However, there can be
no assurance that the Firm will be successful in preventing the occurrence of cyber attacks or mitigating the
impact of cyber attacks.
Interest Rate Risks
Interest rates may fluctuate significantly, causing price volatility with respect to securities or instruments
held by clients.
Item 9. Disciplinary Information
LLW Advisors 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.
Page | 13
Disclosure Brochure
Lifelong Wealth Advisors, Inc.
Item 10. Other Financial Industry Activities and Affiliations
This item requires investment advisers to disclose certain financial industry activities and affiliations.
Licensed Insurance Agents
A number of the Firm’s Supervised Persons are licensed insurance agents and offer certain insurance
products on a fully-disclosed commissionable basis. A conflict of interest exists to the extent that LLW
Advisors recommends the purchase of insurance products where its Supervised Persons are entitled to
insurance commissions or other additional compensation. The Firm has procedures in place whereby it
seeks to ensure that all recommendations are made in its clients’ best interest regardless of any such
affiliations.
Item 11. Code of Ethics
LLW Advisors 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. LLW Advisors’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 LLW Advisors’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 with 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
•
Page | 14
Disclosure Brochure
Lifelong Wealth Advisors, Inc.
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 money market funds; and iv) shares issued by other unaffiliated open-end
mutual funds.
Clients and prospective clients may contact LLW Advisors to request a copy of its Code of Ethics by
contacting the Firm at the phone number on the cover page of this brochure.
Item 12. Brokerage Practices
Recommendation of Broker-Dealers for Client Transactions
LLW Advisors recommends that clients utilize the custody, brokerage and clearing services of Charles
Schwab & Co, Inc. through its Schwab Advisor Services division (“Schwab”) for investment management
accounts. The final decision to custody assets with Schwab is at the discretion of the client, including those
accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan
sponsor or IRA accountholder. LLW Advisors is independently owned and operated and not affiliated with
Schwab. Schwab provides LLW Advisors with access to its institutional trading and custody services, which
are typically not available to retail investors.
Factors which LLW Advisors considers in recommending Schwab or any other broker-dealer to clients
include their respective financial strength, reputation, execution, pricing, research and service. Schwab
enables 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 Schwab may be higher or lower
than those charged by other Financial Institutions.
The commissions paid by LLW Advisors’s clients to Schwab 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 LLW Advisors 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.
LLW Advisors seeks competitive rates but may not necessarily obtain the lowest possible commission rates
for client transactions.
Page | 15
Disclosure Brochure
Lifelong Wealth Advisors, Inc.
LLW Advisors 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
LLW Advisors receives without cost from Schwab administrative support, brokerage support, computer
software, related systems support, research and other third-party support as further described below
(together "Support") which allow LLW Advisors to better monitor client accounts maintained at Schwab
and otherwise conduct its business. LLW Advisors receives the Support without cost because the Firm
renders investment management services to clients that maintain assets at Schwab. The Support is not
provided in connection with securities transactions of clients (i.e., not “soft dollars”). The Support benefits
LLW Advisors, but not its clients directly. Clients should be aware that LLW Advisors’s receipt of
economic benefits such as the Support from a broker-dealer creates a conflict of interest since these benefits
will influence the Firm’s choice of broker-dealer over another that does not furnish similar software,
systems support or services. In fulfilling its duties to its clients, LLW Advisors endeavors at all times to
put the interests of its clients first and has determined that the recommendation of Schwab is in the best
interest of clients and satisfies the Firm's duty to seek best execution.
Specifically, LLW Advisors receives the following benefits from Schwab: i) receipt of duplicate client
confirmations and bundled duplicate statements; ii) access to a trading desk that exclusively services its
institutional traders; iii) access to block trading which provides the ability to aggregate securities
transactions and then allocate the appropriate shares to client accounts; and iv) access to an electronic
communication network for client order entry and account information.
These services generally are available to independent investment advisors on an unsolicited basis, at no
charge to them so long as a certain amount of the advisor’s clients’ assets are maintained in accounts at
Schwab. 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.
For client accounts maintained in its custody, Schwab generally does not charge separately for custody
services but is compensated by account holders through commissions or other transaction-related or asset-
based fees for securities trades that are executed through Schwab or that settle into Schwab accounts.
Schwab also makes available to the Firm other products and services that benefit the Firm but may not
benefit its clients’ accounts. These benefits may include national, regional or Firm specific educational
events organized and/or sponsored by Schwab. Other potential benefits may include occasional business
entertainment of personnel of LLW Advisors by Schwab personnel, including meals, invitations to sporting
events, including golf tournaments, and other forms of entertainment, some of which may accompany
Page | 16
Disclosure Brochure
Lifelong Wealth Advisors, Inc.
educational opportunities. Other of these products and services assist LLW Advisors 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 the Firm'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 the Firm’s
accounts, including accounts not maintained at Schwab. Schwab also makes available to LLW Advisors
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 the Firm by independent third
parties. Schwab 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, LLW
Advisors endeavors to act in its clients’ best interests, the Firm's recommendation that clients maintain their
assets in accounts at Schwab may be based in part on the benefits received and not solely on the nature,
cost or quality of custody and brokerage services provided by Schwab, which creates a conflict of interest.
Brokerage for Client Referrals
LLW Advisors 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 LLW Advisors 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 LLW Advisors (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, LLW Advisors 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.
Page | 17
Disclosure Brochure
Lifelong Wealth Advisors, Inc.
Trade Aggregation
Transactions for each client will be effected independently, unless LLW Advisors decides to purchase or
sell the same securities for several clients at approximately the same time. LLW Advisors 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 be averaged as to price and allocated among LLW Advisors’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
LLW Advisors’s Supervised Persons may invest, the Firm 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. LLW Advisors 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 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. Review of Accounts
Account Reviews
LLW Advisors monitors client portfolios on a continuous and ongoing basis and 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. All investment advisory clients are encouraged to discuss their
needs, goals and objectives with LLW Advisors and to keep the Firm informed of any changes thereto.
Page | 18
Disclosure Brochure
Lifelong Wealth Advisors, Inc.
Account Statements and Reports
Clients are provided with transaction confirmation notices and regular summary account statements directly
from the Financial Institutions where their assets are custodied. Clients may also receive written or
electronic reports from LLW Advisors 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 on a
quarterly basis. Clients should compare the account statements they receive from their custodian with any
documents or reports they receive from LLW Advisors or an outside service provider.
Item 14. Client Referrals and Other Compensation
Client Referrals
The Firm does not currently provide compensation to any third-party solicitors for client referrals.
Other Compensation
The Firm receives economic benefits from Schwab. The benefits, conflicts of interest and how they are
addressed are discussed above in response to Item 12.
Item 15. Custody
LLW Advisors is deemed to have custody of client funds and securities because the Firm is given the ability
to debit client accounts for payment of the Firm’s fees. As such, client funds and securities are maintained
at one or more Financial Institutions that serve as the qualified custodian with respect to such assets. Such
qualified custodians will send account statements to clients at least once per calendar quarter that typically
detail any transactions in such account for the relevant period.
In addition, as discussed in Item 13, LLW Advisors will also send, or otherwise make available, periodic
supplemental reports to clients. Clients should carefully review the statements sent directly by the Financial
Institutions and compare them to those received from LLW Advisors. Any other custody disclosures can
be found in the Firm’s Form ADV Part 1.
Page | 19
Disclosure Brochure
Lifelong Wealth Advisors, Inc.
Standing Letters of Authorization
LLW Advisors also has custody due to clients giving the Firm limited power of attorney in a standing letter
of authorization (“SLOA”) to disburse funds to one or more third parties as specifically designated by the
client. In such circumstances, the Firm will implement the steps in the SEC’s no-action letter on February
21, 2017 which includes (in summary): i) client will provide instruction for the SLOA to the custodian; ii)
client will authorize the Firm to direct transfers to the specific third party; iii) the custodian will perform
appropriate verification of the instruction and provide a transfer of funds notice to the client promptly after
each transfer; iv) the client will have the ability to terminate or change the instruction; v) the Firm will have
no authority or ability to designate or change the identity or any information about the third party; vi) the
Firm will keep records showing that the third party is not a related party of the Firm or located at the same
address as the Firm; and vii) the custodian will send the client an initial and annual notice confirming the
SLOA instructions.
Item 16. Investment Discretion
LLW Advisors is given the authority to exercise discretion on behalf of clients. LLW Advisors 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. LLW Advisors is given this authority through a
power-of-attorney included in the agreement between LLW Advisors and the client. Clients may request a
limitation on this authority (such as certain securities not to be bought or sold). LLW Advisors takes
discretion over the following activities:
• The securities to be purchased or sold;
• The amount of securities to be purchased or sold;
• When transactions are made; and
• The Independent Managers to be hired or fired.
Item 17. Voting Client Securities
Acceptance of Proxy Voting Authority
LLW Advisors previously accepted proxy voting authority under certain advisory agreements but does not
intend to do so for new clients. The firm has amended existing agreements so that clients retain proxy voting
authority.
Proxy Voting: As a matter of Firm policy and practice, LLW Advisors does not accept the authority to and
does not vote proxies on behalf of advisory clients. Clients retain responsibility for receiving and voting
proxies for any and all securities maintained in client portfolios. Clients will receive applicable proxies
Page | 20
Disclosure Brochure
Lifelong Wealth Advisors, Inc.
directly from the issuer of securities held in their accounts. LLW Advisors, may upon request, provide advice
to clients regarding voting of proxies.
Class Actions, Bankruptcies and Other Legal Proceedings: LLW Advisors does not advise or act on
behalf of clients in legal proceedings involving securities held in client accounts, including class actions or
bankruptcies. Upon request, LLW Advisors will make commercially reasonable efforts to forward related
notices to clients or designated third parties.
Item 18. Financial Information
LLW Advisors is not required to disclose any financial information listed in the instructions to Item 18
because:
• The Firm does not require or solicit the prepayment of more than $1,200 in fees six months or more
in advance of services rendered;
• The Firm does not have a financial condition that is reasonably likely to impair its ability to meet
contractual commitments to clients; and
• The Firm has not been the subject of a bankruptcy petition at any time during the past ten years.
Page | 21