View Document Text
LPWM, LLC
dba
Logan Park Wealth Management
Form ADV Part 2A – Disclosure Brochure
Effective: September 3, 2025
This Form ADV 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of
LPWM, LLC dba Logan Park Wealth Management (“Logan Park” or the “Advisor”). If you have any questions about
the content of this Disclosure Brochure, please contact the Advisor at (612) 315-2105.
Logan Park is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The
information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities
authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure
Brochure provides information through Logan Park to assist you in determining whether to retain the Advisor.
Additional information about Logan Park and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 299007.
LPWM, LLC dba Logan Park
121 S 8th Street, Suite #1110, Minneapolis, MN 55402
Phone: (612) 315-2105 | Fax: (612) 677-3092
http://lpwm.com/
Item 2 – Material Changes
Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure
Supplements"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s
business practices and conflicts of interest. The Brochure Supplements provide information about Advisory
Persons of Logan Park. For convenience, the Advisor has combined these documents into a single disclosure
document.
Logan Park believes that communication and transparency are the foundation of its relationship with Clients and
will continually strive to provide you with complete and accurate information at all times. Logan Park encourages all
current and prospective Clients to read this Disclosure Brochure and discuss any questions you may have with the
Advisor.
Material Changes
The following material changes have been made to this Disclosure Brochure since the annual amendment filing on
February 19, 2025:
• The Advisor has added Trustee Services as an offering to Clients. Please see Items 4 and 5 for more
details.
• The Advisor as a result of offering Trustee Services to Clients will have custody of certain Client accounts.
As a result of having custody the firm has amended Item 15 to reflect this update along with the firm being
subject to a surprise audit. Please see Item 15 for more details.
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices,
changes in regulations or routine annual updates as required by the securities regulators. This complete
Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change
occurs in the business practices of Logan Park.
You may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 299007. You may also request a
copy of this Disclosure Brochure at any time, by contacting the Advisor at (612) 315-2105.
LPWM, LLC dba Logan Park
Page 2
121 S 8th Street, Suite #1110, Minneapolis, MN 55402
Phone: (612) 315-2105 | Fax: (612) 677-3092
http://lpwm.com/
Item 3 – Table of Contents
Item 1 – Cover Page ............................................................................................................................................... 1
Item 2 – Material Changes ..................................................................................................................................... 2
Item 3 – Table of Contents .................................................................................................................................... 3
Item 4 – Advisory Services ................................................................................................................................... 4
A. Firm Information ............................................................................................................................................................. 4
B. Advisory Services Offered .............................................................................................................................................. 4
C. Client Account Management .......................................................................................................................................... 6
D. Wrap Fee Programs ....................................................................................................................................................... 6
E. Assets Under Management ............................................................................................................................................ 6
Item 5 – Fees and Compensation ......................................................................................................................... 6
A. Fees for Advisory Services ............................................................................................................................................ 7
B. Fee Billing ...................................................................................................................................................................... 8
C. Other Fees and Expenses ............................................................................................................................................. 8
D. Advance Payment of Fees and Termination .................................................................................................................. 8
E. Compensation for Sales of Securities ............................................................................................................................ 9
Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 9
Item 7 – Types of Clients ....................................................................................................................................... 9
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .......................................................... 9
A. Methods of Analysis ....................................................................................................................................................... 9
B. Risk of Loss .................................................................................................................................................................... 9
Item 9 – Disciplinary Information ....................................................................................................................... 11
Item 10 – Other Financial Industry Activities and Affiliations ......................................................................... 11
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 11
A. Code of Ethics .............................................................................................................................................................. 11
B. Personal Trading with Material Interest ........................................................................................................................ 11
C. Personal Trading in Same Securities as Clients .......................................................................................................... 11
D. Personal Trading at Same Time as Client ................................................................................................................... 12
Item 12 – Brokerage Practices ............................................................................................................................ 12
A. Recommendation of Custodian[s] ................................................................................................................................ 12
B. Aggregating and Allocating Trades .............................................................................................................................. 12
Item 13 – Review of Accounts ............................................................................................................................ 13
A. Frequency of Reviews .................................................................................................................................................. 13
B. Causes for Reviews ..................................................................................................................................................... 13
C. Review Reports ............................................................................................................................................................. 13
Item 14 – Client Referrals and Other Compensation ........................................................................................ 13
A. Compensation Received by Logan Park ...................................................................................................................... 13
B. Compensation for Client Referrals ............................................................................................................................... 14
Item 15 – Custody ................................................................................................................................................ 14
Item 16 – Investment Discretion ......................................................................................................................... 14
Item 17 – Voting Client Securities ...................................................................................................................... 14
Item 18 – Financial Information .......................................................................................................................... 14
Form ADV Part 2B – Brochure Supplement ...................................................................................................... 15
Privacy Policy…………………………………………………………………………………………………..…………..24
LPWM, LLC dba Logan Park
Page 3
121 S 8th Street, Suite #1110, Minneapolis, MN 55402
Phone: (612) 315-2105 | Fax: (612) 677-3092
http://lpwm.com/
Item 4 – Advisory Services
A. Firm Information
LPWM, LLC dba Logan Park (“Logan Park” or the “Advisor”) is a registered investment advisor with the U.S.
Securities and Exchange Commission (“SEC”), which is organized as a limited liability company (“LLC”) under the
laws of the State of Delaware. Logan Park was founded in November 2018 and is owned and operated by David
M. Benning (Managing Partner, Private Wealth Advisor and Chief Compliance Officer) and Jeffery J. Sutton
(Managing Partner and Private Wealth Advisor).
This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory
services provided by Logan Park. For information regarding this Disclosure Brochure, please contact David M.
Benning, who also serves as the Chief Compliance Officer of Logan Park. Mr. Benning can be reached at (612)
315-2105.
B. Advisory Services Offered
Logan Park offers advisory services to individuals, high net worth individuals, families, trusts, estates, businesses
and retirement plans (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under applicable laws and regulations. As a fiduciary, the
Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. Logan Park’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For
more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in
Client Transactions and Personal Trading.
Investment Management Services
Logan Park provides customized investment advisory solutions for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary investment management and related advisory
services. Logan Park works closely with each Client to identify their investment goals and objectives as well as risk
tolerance and financial situation in order to create a portfolio strategy. Logan Park will then construct an investment
portfolio, consisting of low-cost, diversified mutual funds and/or exchange traded funds (“ETFs”) to achieve the
Client’s investment goals. The Advisor may also utilize individual stocks or bonds to meet the needs of its Clients.
The Advisor may retain certain legacy investments based on portfolio fit and/or tax considerations. The Advisor
may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy,
tax-related reasons, or other reasons as identified between the Advisor and the Client.
Logan Park’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate
positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. Logan Park will construct, implement and monitor the portfolio to ensure it meets the goals, objectives,
circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place
reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by
the Advisor.
Logan Park evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. Logan Park may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. Logan Park may recommend specific positions to increase sector or asset class weightings. The Advisor
may recommend employing cash positions as a possible hedge against market movement. Logan Park may
recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses,
business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the
position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk
deemed unacceptable for the Client’s risk tolerance.
At no time will Logan Park accept or maintain custody of a Client’s funds or securities, except for the limited
authority as outlined in Item 15 – Custody. All Client assets will be managed within their designated account[s] at
the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
Cash Management Services – Logan Park may provide investment advisory services for Cash Management for
Clients who may need to maintain cash positions over a longer period of time. Cash Management Services are
LPWM, LLC dba Logan Park
Page 4
121 S 8th Street, Suite #1110, Minneapolis, MN 55402
Phone: (612) 315-2105 | Fax: (612) 677-3092
http://lpwm.com/
provided to Clients seeking to improve yield and / or total return by incorporating assets such as T Bills, ultra short
duration bonds, laddered CDs, intermediate bonds, and other cash equivalents.
Retirement Plan Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the
assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account
to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or
increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a
retirement account to an account managed by the Advisor.
Financial Planning Services
Logan Park will typically provide to its Clients a variety of financial planning services and consulting services.
Services may be included in an overall wealth management engagement or provided as a separate service,
pursuant to the terms of the agreement. Financial planning services based on the Client’s needs and complexity of
the services to be provided. Services are offered in several areas of a Client’s financial situation, depending on
their goals and objectives.
Generally, such financial planning services involve preparing a formal financial plan or rendering a specific
financial consultation based on the Client’s financial goals and objectives. This planning or consulting may
encompass one or more areas of need, including but not limited to, investment planning, retirement planning,
personal savings, education savings and other areas of a Client’s financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs.
Financial planning and consulting services may not cover every aspect of a Client’s financial life. For example,
some areas that Logan Park does not provide consulting services on include homeowners and excess liability
coverage. Additionally, an area may not be included in the financial plan for a variety of reasons. For example, we
did not receive sufficient data from the Client to complete an analysis. The Client should not take any omission as
an indication that the topic is not applicable to their financial situation.
Logan Park may also refer Clients to an accountant, attorney or other specialist, as appropriate for the Client’s
unique situation. For certain financial planning engagements, the Advisor will generally provide a written report that
contains observations and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide
a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming
all information and documents requested are provided promptly.
Financial planning recommendations poses a conflict between the interests of the Advisor and the interests of the
Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment
management services or to increase the level of investment assets with the Advisor, as it would increase the
amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by
the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the
recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the
Advisor.
Retirement Plan Advisory Services
Logan Park provides retirement plan advisory services on behalf of retirement plans (each a “Plan”) and the
company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan
Sponsor in meeting its fiduciary obligations to the Plan and Plan Participants. Each engagement is customized to
the needs of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
LPWM, LLC dba Logan Park
Page 5
121 S 8th Street, Suite #1110, Minneapolis, MN 55402
Phone: (612) 315-2105 | Fax: (612) 677-3092
http://lpwm.com/
“IPS” Design and Monitoring
• Policy Statement
•
• Ongoing Investment Recommendation and Assistance
• Benchmarking Services
These services are provided by Logan Park serving in the capacity as a fiduciary under the Employee Retirement
Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan
Sponsor is provided with a written description of Logan Park’s fiduciary status, the specific services to be rendered
and all direct and indirect compensation the Advisor reasonably expects under the engagement.
Trust Services
Logan Park offers Trust Management Services for Trusts for which an Advisory Person of the Advisor serves as
Trustee. The services provided are as follows:
• Administration of all trust assets per trust documents.
• Managing distributions in accordance with trust provisions.
• Ensuring that the trust assets are held in safekeeping.
• Records maintenance and full annual accounting of all trust activities.
• Filing of trust tax returns.
C. Client Account Management
Prior to engaging Logan Park to provide advisory services, each Client is required to enter into one or more
agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the
Client. These services may include:
• Establishing an Investment Strategy – Logan Park, in connection with the Client, will develop a strategy
that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Logan Park will develop a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – Logan Park will develop a portfolio for the Client that is intended to meet the stated
goals and objectives of the Client.
•
Investment Management and Supervision – Logan Park will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Logan Park does not manage or place Client assets into a wrap fee program.
E. Assets Under Management
As of December 31, 2024, Logan Park manages approximately $376,320,625 in Client assets, all of which are
managed on a discretionary basis. Clients may request more current information at any time by contacting the
Advisor.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written
agreement with the Advisor.
LPWM, LLC dba Logan Park
Page 6
121 S 8th Street, Suite #1110, Minneapolis, MN 55402
Phone: (612) 315-2105 | Fax: (612) 677-3092
http://lpwm.com/
A. Fees for Advisory Services
Investment Management Services
Investment advisory fees are paid monthly in advance of each month, pursuant to the terms of the investment
advisory agreement. Investment advisory fees are based on market value of assets under management at the end of
the prior month. Investment advisory fees are based on the following schedule:
Annual Rate (%)
Assets Under Management ($)
Up to $500,000
$500,001 to $2,500,000
$2,500,001 to $5,000,000
$5,000,001 to $10,000,000
$10,000,001 and over
1.25%*
1.00%
0.90%
0.80%
Negotiable
* Logan Park generally requires a minimum fee of $3,000 that may be waived at the sole discretion of the Advisor.
The tiered fee schedule results in a “blended” fee based on the assets under management at the time of the billing
calculation. For example, for an account valued at $1,000,000 based on the above schedule, Clients will be
charged 1.25% for the first $500,000 and 1.00% for the next $500,000. This results in a blended rate of 1.125%
annually.
The investment advisory fee in the first month of service is prorated from the inception date of the account[s] to the
end of the first month. Fees may be negotiable at the sole discretion of the Advisor. Certain legacy clients may pay
fees that do not conform to this fee schedule. The Client’s fees will take into consideration the aggregate assets
under management with the Advisor. All securities held in accounts managed by Logan Park will be independently
valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate
billing.
Cash Management Services – The fee for Cash Management fees ranges from 0.10% to 0.25% depending on the
account balance and portfolio complexity. Fees may be negotiable at the sole discretion of the Advisor.
The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and
other related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the
Advisor shall not receive any portion of these commissions, fees, and costs.
Financial Planning Services
Logan Park may include financial planning services as part of an overall wealth management agreement. Logan
Park also offers financial planning services for a fixed fee or an ongoing planning engagement. Fees range between
$3,000 and $50,000. Ongoing engagement fees are billed quarterly, in advance of each calendar quarter. Fees may
be negotiable based on the nature and complexity of the services to be provided and the overall relationship with the
Advisor. An estimate for total costs will be provided to the Client prior to engaging for these services.
Retirement Plan Advisory Services
Fees for retirement plan advisory services are charged an asset-based fee that ranges from 0.25% to 1.00% and are
billed quarterly, at the end of each calendar quarter, pursuant to the terms of the retirement plan advisory agreement.
Retirement plan advisory fees are based on the market value of assets under management at the end of the prior
calendar month. Fees are negotiable depending on the size and complexity of the Plan.
Trust Services
Trust service fees are paid monthly, in advance of each calendar month, pursuant to the terms of the investment
advisory agreement. Trust service fees are based on the market value of the trust’s assets under management at the
end of the prior month. The Trust service fees are an additional fee added to the Client’s investment advisory fee.
Trust service fees are based on the following schedule:
Annual Rate (%)
Assets Under Management ($)
Under $2,500,000
$2,500,001-$5,000,000
Over $5,000,000
0.50%
0.33%
0.25%
LPWM, LLC dba Logan Park
Page 7
121 S 8th Street, Suite #1110, Minneapolis, MN 55402
Phone: (612) 315-2105 | Fax: (612) 677-3092
http://lpwm.com/
B. Fee Billing
Investment Management Services
Investment advisory fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at
the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted
from the Client’s account[s] at the beginning of the respective month. The amount due is calculated by applying the
monthly rate (annual rate divided by twelve) to the total assets under management at the end of the prior month.
Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment
advisory fee. It is the responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s
brokerage statement as the Custodian does not assume responsibility. Clients provide written authorization permitting
advisory fees to be deducted by Logan Park to be paid directly from their account[s] held by the Custodian as part of
the investment advisory agreement and separate account forms provided by the Custodian.
Financial Planning Services
Financial planning fees for fixed fee engagements may be invoiced up to 50% upon execution of the financial
planning agreement. The balance shall be invoiced upon completion of the agreed upon deliverable[s]. Ongoing
financial planning engagements are billed in advance of each calendar quarter.
Retirement Plan Advisory Services
Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan,
depending on the terms of the retirement plan advisory agreement.
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than Logan Park, in connection with
investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities
execution fees charged by the Custodian. The Advisor’s recommended custodian does not charge securities
transaction fees for ETFs and equity trades in Client accounts, but typically charges for mutual fund and other
types of investments. The fees charged by Logan Park are separate and distinct from these custody and execution
fees.
In addition, all fees paid to Logan Park for investment advisory services are separate and distinct from the expenses
charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in
each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds,
other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible
distribution fee. A Client may be able to invest in these products directly, without the services of Logan Park, but
would not receive the services provided by Logan Park which are designed, among other things, to assist the Client
in determining which products or services are most appropriate for each Client’s financial situation and objectives.
Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Logan Park to
fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information.
D. Advance Payment of Fees and Termination
Investment Advisory Services
Logan Park is compensated for its services at the beginning of the month in which investment advisory services are
rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance written
notice to the other party. The Client may also terminate the investment advisory agreement within five (5) business
days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur
charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable
by the Client. The Advisor will refund any unearned, prepaid investment advisory fees from the effective date of
termination to the end of the month. The Client’s investment advisory agreement with the Advisor is non-transferable
without the Client’s prior consent.
Financial Planning Services
Logan Park is compensated for its services upon completion of the engagement deliverable[s]. Logan Park requires
an advance deposit as described above. Either party may terminate the financial planning agreement, at any time, by
providing advance written notice to the other party. The Client may also terminate the financial planning agreement
within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period,
the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will
be due and payable by the Client. Upon termination, the Client shall be responsible for planning fees based on the
LPWM, LLC dba Logan Park
Page 8
121 S 8th Street, Suite #1110, Minneapolis, MN 55402
Phone: (612) 315-2105 | Fax: (612) 677-3092
http://lpwm.com/
percentage of the engagement scope completed by the Advisor. For ongoing retainers, the amount due is based on
the number of days in the quarter for which services we provided up to and including the effective date of termination.
The Advisor will refund any unearned, prepaid financial planning fees from the effective date of termination. The
Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent.
Retirement Plan Advisory Services
Logan Park is compensated for its retirement plan advisory services at the end of the quarter in which services are
rendered. Either party may terminate the retirement plan advisory agreement, at any time, by providing advance
written notice to the other party. The Client shall be responsible for retirement plan advisory fees up to and including
the effective date of termination. The Client’s retirement plan advisory agreement with the Advisor is non-
transferable without the Client’s prior consent.
E. Compensation for Sales of Securities
Logan Park does not buy or sell securities to earn commissions and does not receive any compensation for
securities transactions in any Client account, other than the investment advisory fees noted above.
Item 6 – Performance-Based Fees and Side-By-Side Management
Logan Park does not charge performance-based fees for its investment advisory services. The fees charged by
Logan Park are as described in Item 5 above and are not based upon the capital appreciation of the funds or
securities held by any Client.
Logan Park does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund
or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients.
Item 7 – Types of Clients
Logan Park offers advisory services to individuals, high net worth individuals, families, trusts, estates, businesses
and retirement plans. The amount of each type of Client is available on Logan Park’s Form ADV Part 1A. These
amounts may change over time and are updated at least annually by the Advisor. Logan Park generally does not
impose a minimum relationship size.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
Logan Park primarily employs its investment methodology based on the principles of modern portfolio theory in
developing investment strategies for its Clients. Research and analysis from Logan Park is derived from numerous
sources, including financial media companies, third-party research materials, Internet sources, and review of
company activities, including annual reports, prospectuses, press releases and research prepared by others.
Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the
same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if
compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept
more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off
differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest
in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of
risk an alternative portfolio exists which has better expected returns.
As noted above, Logan Park generally employs a long-term investment strategy for its Clients, as consistent with
their financial goals. Logan Park will typically hold all or a portion of a security for more than a year, but may hold
for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Logan
Park may also buy and sell positions that are more short-term in nature, depending on the goals of the Client
and/or the fundamentals of the security, sector or asset class.
B. Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. Logan Park will assist Clients in determining an appropriate
LPWM, LLC dba Logan Park
Page 9
121 S 8th Street, Suite #1110, Minneapolis, MN 55402
Phone: (612) 315-2105 | Fax: (612) 677-3092
http://lpwm.com/
strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a
Client will meet their investment goals.
While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the
investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may
lose value and may have negative investment performance. The Advisor monitors these economic indicators to
determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are
included below in Item 13 – Review of Accounts.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client
or their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or
other factors that may affect this analysis.
The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts.
The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction
process. Following are some of the risks associated with the Advisor’s investment approach:
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs
will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk
based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large bid-
ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may
dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased
or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the
mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual
fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same
price as a mutual fund purchased later that same day.
Bond Risks
Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will
fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon
rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than
was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that
exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk
associated with purchasing a debt instrument which includes the possibility of the company defaulting on its
repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the
company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity
Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond.
Options Contracts
Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts
are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock.
This leverage can compound gains or losses.
LPWM, LLC dba Logan Park
Page 10
121 S 8th Street, Suite #1110, Minneapolis, MN 55402
Phone: (612) 315-2105 | Fax: (612) 677-3092
http://lpwm.com/
Margin Borrowings
The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if securities
pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin
call", pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory
liquidation of the pledged securities to compensate for the decline in value.
Alternative Investments (Limited Partnerships)
The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An
investor could lose all or a portion of their investment. Such investments often have concentrated positions and
investments that may carry higher risks. Clients should only have a portion of their assets in these investments.
Past performance is not a guarantee of future returns. Investing in securities and other investments
involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to
discuss these risks with the Advisor.
Item 9 – Disciplinary Information
There are no legal, regulatory or disciplinary events involving Logan Park or its management person[s].
Logan Park values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite
due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor and its
Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov
by searching with the Advisor’s firm name or CRD# 299007.
Item 10 – Other Financial Industry Activities and Affiliations
The sole business of Logan Park and is Advisory Persons is to provide investment advisory services to its Clients.
Neither Logan Park nor its Advisory Persons are involved in other business endeavors. Logan Park does not
maintain any affiliations with other firms, other than contracted service providers to assist with the servicing of its
Client’s accounts.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions, and Personal
Trading
A. Code of Ethics
Logan Park has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to
each Client. This Code applies to all persons associated with Logan Park (“Supervised Persons”). The Code was
developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to the
Client. Logan Park and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client.
It is the obligation of Logan Park’s Supervised Persons to adhere not only to the specific provisions of the Code,
but also to the general principles that guide the Code. The Code of Ethics covers a range of topics that address
employee ethics and conflicts of interest. To request a copy, please contact the Advisor at (612) 315-2105.
B. Personal Trading with Material Interest
Logan Park allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Logan Park does not act as principal in any transactions. In addition, the Advisor
does not act as the general partner of a fund, or advise an investment company. Logan Park does not have a
material interest in any securities traded in Client accounts.
C. Personal Trading in Same Securities as Clients
Logan Park allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Owning the same securities that are recommend (purchase or sell) to Clients
presents a potential conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through
policies and procedures. As noted above, the Advisor has adopted the Code, to address insider trading (material
non-public information controls); gifts and entertainment; outside business activities and personal securities
reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same
securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made
with more advantageous terms than Client trades, or by trading based on material non-public information. This risk
LPWM, LLC dba Logan Park
Page 11
121 S 8th Street, Suite #1110, Minneapolis, MN 55402
Phone: (612) 315-2105 | Fax: (612) 677-3092
http://lpwm.com/
is mitigated by Logan Park requiring reporting of personal securities trades by its Supervised Persons for review by
the Chief Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures
to detect the misuse of material, non-public information.
D. Personal Trading at Same Time as Client
While Logan Park allows Supervised Persons to purchase or sell the same securities that may be recommended to
and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterward. At no
time will Logan Park, or any Supervised Person of Logan Park, transact in any security to the detriment of
any Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
Logan Park does not have discretionary authority to select the broker-dealer/custodian for custody and execution
services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets
and authorize Logan Park to direct trades to the Custodian as agreed upon in the investment advisory agreement.
Further, Logan Park does not have the discretionary authority to negotiate commissions on behalf of Clients on a
trade-by-trade basis.
Where Logan Park does not exercise discretion over the selection of the Custodian, it may recommend the
Custodian to Clients for custody and execution services. Clients are not obligated to use the recommended
Custodian and will not incur any extra fee or cost from the Advisor associated with using a custodian not
recommended by Logan Park. However, the Advisor may be limited in the services it can provide if the
recommended Custodian is not engaged. Logan Park may recommend the Custodian based on criteria such as,
but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, its
reputation, and/or location of the Custodian’s offices.
Logan Park will generally recommend that Clients establish their account[s] at Charles Schwab & Co., Inc.
(“Schwab”), a FINRA-registered broker-dealer and member SIPC. Schwab will serve as the Client’s “qualified
custodian”. Logan Park maintains an institutional relationship with Schwab, whereby the Advisor receives
economic benefits from Schwab. Please see Item 14 below.
Following are additional details regarding the brokerage practices of the Advisor:
1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor
enters into an agreement to place security trades with the broker-dealer/custodian in exchange for research and
other services. Logan Park does not participate in soft dollar programs sponsored or offered by any broker-
dealer/custodian, but does receive economic benefits from the Custodian. Please see Item 14 below.
2. Brokerage Referrals - Logan Park does not receive any compensation from any third party in connection with
the recommendation for establishing an account.
3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Logan Park will place
trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are
traded within their respective brokerage account[s]. The Advisor will not engage in any principal transactions (i.e.,
trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e.,
purchase of a security into one Client account from another Client’s account[s]). Logan Park will not be obligated to
select competitive bids on securities transactions and does not have an obligation to seek the lowest available
transaction costs. These costs are determined by the Custodian.
B. Aggregating and Allocating Trades
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the
most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of
execution, 4) confidentiality and 5) skill required of the Custodian. Logan Park will execute its transactions through
the Custodian as authorized by the Client.
Logan Park may aggregate orders in a block trade or trades when securities are purchased or sold through the
Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full
LPWM, LLC dba Logan Park
Page 12
121 S 8th Street, Suite #1110, Minneapolis, MN 55402
Phone: (612) 315-2105 | Fax: (612) 677-3092
http://lpwm.com/
at the same price or time, the securities actually purchased or sold by the close of each business day must be
allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done
in a way that does not consistently advantage or disadvantage particular Clients’ accounts.
Item 13 – Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by David Benning, Chief
Compliance Officer of Logan Park. Formal reviews are generally conducted at least annually or more frequently
depending on the needs of the Client.
B. Causes for Reviews
In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least
annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a
result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large
deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Logan Park if changes occur
in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional
reviews may be triggered by material market, economic or political events.
C. Review Reports
The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage
statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to
the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage
statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also
provide Clients with periodic reports regarding their holdings, allocations, and performance.
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by Logan Park
Logan Park does not receive securities commissions or other compensation from product sponsors, broker-dealers
or any un-related third party. Logan Park may refer Clients to various unaffiliated, non-advisory profesionals (e.g.,
attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its
Clients. Likewise, Logan Park may receive referrals of new Clients from various third-parties.
Participation in Institutional Advisor Platform
Logan Park has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a
division of Schwab dedicated to serving independent advisory firms like Logan Park. As a registered investment
advisor participating on the Schwab Advisor Services platform, Logan Park receives access to software and
related support without cost because the Advisor renders investment management services to Clients that
maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not
all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all
times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits
from a custodian creates a potential conflict of interest since these benefits may influence the Advisor's
recommendation of this custodian over one that does not furnish similar software, systems support, or services.
Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of Client’s funds and securities. Through
Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be
able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds
and other investments without having to adhere to investment minimums that might be required if the Client were
to directly access the investments.
Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology,
research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts,
the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with
Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may
not directly benefit all Clients.
LPWM, LLC dba Logan Park
Page 13
121 S 8th Street, Suite #1110, Minneapolis, MN 55402
Phone: (612) 315-2105 | Fax: (612) 677-3092
http://lpwm.com/
Services that May Only Benefit the Advisor – Schwab also offers other services and financial support to Logan
Park that may not benefit the Client, including: educational conferences and events, financial start-up support,
consulting services and discounts for various service providers. Access to these services creates a financial
incentive for the Advisor to recommend Schwab, which results in a potential conflict of interest. Logan Park
believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients.
B. Compensation for Client Referrals
The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for
Client referrals.
Item 15 – Custody
All Clients must maintain their accounts with a “qualified custodian,” as described in Item 12 – Brokerage
Practices. Logan Park accepts custody of a Client’s funds or securities, through the deduction of management fees
from the Client’s account[s] at the Custodian, and in certain situations where Supervised Persons of Logan Park
serve as trustee for certain Client relationships. Clients should review statements provided by the Custodian and
compare to any reports provided by Logan Park to ensure accuracy, as the Custodian does not perform this
review.
Surprise Independent Examination
As Logan Park is deemed to have custody over certain Client accounts and/or securities as part of their role as
trustee for certain Client accounts, pursuant to securities regulations the Advisor is required to engage an
independent accounting firm to perform an annual surprise examination of those assets and accounts over which
Logan Park maintains custody. Any related opinions issued by an independent accounting firm are filed with the
SEC and are publicly available on the SEC’s Investment Adviser Public Disclosure website
(http://adviserinfo.sec.gov).
If the Client gives the Advisor authority to move money from one account to another account, the Advisor may
have custody of those assets. In order to avoid additional regulatory requirements, the Custodian and the Advisor
have adopted safeguards to ensure that the money movements are completed in accordance with the Client’s
instructions.
Item 16 – Investment Discretion
Logan Park generally has discretion over the selection and amount of securities to be bought or sold in Client
accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be
subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by
Logan Park. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such
authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable
limitations to such authority. All discretionary trades made by Logan Park will be in accordance with each Client's
investment objectives and goals.
Item 17 – Voting Client Securities
Logan Park does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly
from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the
sole responsibility for proxy decisions and voting.
Item 18 – Financial Information
Neither Logan Park, nor its management, have any adverse financial situations that would reasonably impair the
ability of Logan Park to meet all obligations to its Clients. Neither Logan Park, nor any of its Advisory Persons,
have been subject to a bankruptcy or financial compromise. Logan Park is not required to deliver a balance sheet
along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to
be performed six months or more in the future.
LPWM, LLC dba Logan Park
Page 14
121 S 8th Street, Suite #1110, Minneapolis, MN 55402
Phone: (612) 315-2105 | Fax: (612) 677-3092
http://lpwm.com/
Form ADV Part 2B – Brochure Supplement
for
David M. Benning, CIMA®
Managing Partner
Private Wealth Advisor
Chief Compliance Officer
Effective: September 3, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of David
M. Benning, CIMA® (CRD# 4451037) in addition to the information contained in the LPWM LLC dba Logan Park
Wealth Management (“Logan Park” or the “Advisor”, CRD# 299007) Disclosure Brochure. If you have not received
a copy of the Disclosure Brochure or if you have any questions about the content of the Logan Park Disclosure
Brochure or this Brochure Supplement, please contact the Advisor at (612) 315-2105.
Additional information about Mr. Benning is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 4451037.
LPWM, LLC dba Logan Park
Page 15
121 S 8th Street, Suite #1110, Minneapolis, MN 55402
Phone: (612) 315-2105 | Fax: (612) 677-3092
http://lpwm.com/
Item 2 – Educational Background and Business Experience
David M. Benning, CIMA®, born in 1978, is dedicated to advising Clients of Logan Park as a Private Wealth
Advisor and the Chief Compliance Officer. Mr. Benning earned a Bachelor of Arts in Business Administration from
University of Illinois - Champaign - Urbana in 2001. Additional information regarding Mr. Benning’s employment
history is included below.
Employment History:
03/2019 to Present
Private Wealth Advisor and Chief Compliance Officer,
LPWM, LLC dba Logan Park Wealth Management
Financial Advisor, Ameriprise Financial Services, Inc.
09/2001 to 12/2018
Certified Investment Management AnalystSM (CIMA®)
The CIMA certification signifies that an individual has met initial and ongoing experience, ethical, education, and
examination requirements for investment management consulting, including advanced investment management
theory and application. To earn CIMA certification, candidates must: submit an application, pass a background
check and have an acceptable regulatory history; pass an online Qualification Examination; complete an in-person
or online executive education program at an AACSB accredited university business school; pass an online
Certification Examination; and have an acceptable regulatory history as evidenced by FINRA Form U-4 or other
regulatory requirements and have three years of financial services experience at the time of certification.
CIMA certificants must adhere to IMCA’s Code of Professional Responsibility, Standards of Practice, and Rules
and Guidelines for Use of the Marks. CIMA designees must report 40 hours of continuing education credits,
including two ethics hours, every two years to maintain the certification. The designation is administered through
Investment Management Consultants Association (IMCA).
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Benning. Mr. Benning has never
been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration
claims or administrative proceedings against Mr. Benning.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Benning.
However, the Advisor encourages Clients to independently view the background of Mr. Benning on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual
CRD# 4451037.
Item 4 – Other Business Activities
Mr. Benning is dedicated to the investment advisory activities of Logan Park’s Clients. Mr. Benning does not have
any other business activities.
Item 5 – Additional Compensation
Mr. Benning is dedicated to the investment advisory activities of Logan Park’s Clients. Mr. Benning does not
receive any additional forms of compensation.
Item 6 – Supervision
Mr. Benning serves as a Private Wealth Advisor and Chief Compliance Officer of Logan Park. Mr. Benning can be
reached at (612) 315-2105.
LPWM, LLC dba Logan Park
Page 16
121 S 8th Street, Suite #1110, Minneapolis, MN 55402
Phone: (612) 315-2105 | Fax: (612) 677-3092
http://lpwm.com/
Logan Park has implemented a Code of Ethics, an internal compliance document, that guides each Supervised
Person in meeting their fiduciary obligations to Clients of Logan Park. Further, Logan Park is subject to regulatory
oversight by various agencies. These agencies require registration by Logan Park and its Supervised Persons. As
a registered entity, Logan Park is subject to examinations by regulators, which may be announced or
unannounced. Logan Park is required to periodically update the information provided to these agencies and to
provide various reports regarding the business activities and assets of the Advisor.
LPWM, LLC dba Logan Park
Page 17
121 S 8th Street, Suite #1110, Minneapolis, MN 55402
Phone: (612) 315-2105 | Fax: (612) 677-3092
http://lpwm.com/
Form ADV Part 2B – Brochure Supplement
for
Jeffery J. Sutton, CFP®
Managing Partner
Private Wealth Advisor
Effective: September 3, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Jeffery J. Sutton, CFP® (CRD# 4837117) in addition to the information contained in the dba Logan Park Wealth
Management (“Logan Park” or the “Advisor”, CRD# 299007) Disclosure Brochure. If you have not received a copy
of the Disclosure Brochure or if you have any questions about the content of the Logan Park Disclosure Brochure
or this Brochure Supplement, please contact the Advisor at (612) 315-2105.
Additional information about Mr. Sutton is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 4837117.
LPWM, LLC dba Logan Park
Page 18
121 S 8th Street, Suite #1110, Minneapolis, MN 55402
Phone: (612) 315-2105 | Fax: (612) 677-3092
http://lpwm.com/
Item 2 – Educational Background and Business Experience
Jeffery J. Sutton, CFP®, born in 1979, is dedicated to advising Clients of Logan Park as a Private Wealth Advisor.
Mr. Sutton earned a Bachelor of Arts in History and Psychology from New York University in 2001. Mr. Sutton also
earned a Masters in Business Administration from University of Colorado in 2004. Additional information regarding
Mr. Sutton’s employment history is included below.
Employment History:
Private Wealth Advisor, LPWM, LLC dba Logan Park Wealth Management
Financial Advisor, Ameriprise Financial Services, Inc.
03/2019 to Present
08/2004 to 12/2018
CERTIFIED FINANCIAL PLANNER™ (“CFP®”)
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP® (with flame design) marks
(collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified
Financial Planner Board of Standards, Inc. (“CFP® Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to
hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high
standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical
requirements that govern professional engagements with clients. Currently, more than 71,000 individuals have
obtained CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:
• Education – Complete an advanced college-level course of study addressing the financial planning subject
areas that CFP® Board’s studies have determined as necessary for the competent and professional
delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United
States college or university (or its equivalent from a foreign university). CFP® Board’s financial planning
subject areas include insurance planning and risk management, employee benefits planning, investment
planning, income tax planning, retirement planning, and estate planning;
• Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case
studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues
and apply one’s knowledge of financial planning to real world circumstances;
• Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
• Ethics – Agree to be bound by CFP® Board’s Standards of Professional Conduct, a set of documents
outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements in order
to maintain the right to continue to use the CFP® marks:
• Continuing Education – Complete 30 hours of continuing education hours every two years, including two
hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain
competence and keep up with developments in the financial planning field; and
• Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards
prominently require that CFP® professionals provide financial planning services at a fiduciary standard of
care. This means CFP® professionals must provide financial planning services in the best interests of their
clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP® Board’s
enforcement process, which could result in suspension or permanent revocation of their CFP® certification.
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Sutton. Mr. Sutton has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims
or administrative proceedings against Mr. Sutton.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
LPWM, LLC dba Logan Park
Page 19
121 S 8th Street, Suite #1110, Minneapolis, MN 55402
Phone: (612) 315-2105 | Fax: (612) 677-3092
http://lpwm.com/
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Sutton.
However, the Advisor encourages Clients to independently view the background of Mr. Sutton on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual
CRD# 4837117.
Item 4 – Other Business Activities
Mr. Sutton is dedicated to the investment advisory activities of Logan Park’s Clients. Mr. Sutton does not have any
other business activities.
Item 5 – Additional Compensation
Mr. Sutton is dedicated to the investment advisory activities of Logan Park’s Clients. Mr. Sutton does not receive
any additional forms of compensation.
Item 6 – Supervision
Mr. Sutton serves as a Private Wealth Advisor of Logan Park and is supervised by David Benning, the Chief
Compliance Officer. Mr. Benning can be reached at (612) 315-2105.
Logan Park has implemented a Code of Ethics, an internal compliance document, that guides each Supervised
Person in meeting their fiduciary obligations to Clients of Logan Park. Further, Logan Park is subject to regulatory
oversight by various agencies. These agencies require registration by Logan Park and its Supervised Persons. As
a registered entity, Logan Park is subject to examinations by regulators, which may be announced or
unannounced. Logan Park is required to periodically update the information provided to these agencies and to
provide various reports regarding the business activities and assets of the Advisor.
LPWM, LLC dba Logan Park
Page 20
121 S 8th Street, Suite #1110, Minneapolis, MN 55402
Phone: (612) 315-2105 | Fax: (612) 677-3092
http://lpwm.com/
Form ADV Part 2B – Brochure Supplement
for
Cole E. Hystead, CFP®
Financial Advisor
Effective: September 3, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Cole
E. Hystead, CFP® (CRD# 5750427) in addition to the information contained in the dba Logan Park Wealth
Management (“Logan Park” or the “Advisor”, CRD# 299007) Disclosure Brochure. If you have not received a copy
of the Disclosure Brochure or if you have any questions about the content of the Logan Park Disclosure Brochure
or this Brochure Supplement, please contact the Advisor at (612) 315-2105.
Additional information about Mr. Hystead is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 5750427.
LPWM, LLC dba Logan Park
Page 21
121 S 8th Street, Suite #1110, Minneapolis, MN 55402
Phone: (612) 315-2105 | Fax: (612) 677-3092
http://lpwm.com/
Item 2 – Educational Background and Business Experience
Cole E. Hystead, CFP®, born in 1989, is dedicated to advising Clients of Logan Park as a Financial Advisor. Mr.
Hystead earned a Bachelor of Science in Finance from University of Minnesota - Carlson School of Management
in 2012. Additional information regarding Mr. Hystead’s employment history is included below.
Employment History:
Financial Advisor, LPWM LLC dba Logan Park Wealth Management
Financial Advisor, Ameriprise Financial Services, Inc.
03/2019 to Present
01/2010 to 12/2018
CERTIFIED FINANCIAL PLANNER™ (“CFP®”)
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP® (with flame design) marks
(collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified
Financial Planner Board of Standards, Inc. (“CFP® Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to
hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high
standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical
requirements that govern professional engagements with clients. Currently, more than 71,000 individuals have
obtained CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:
• Education – Complete an advanced college-level course of study addressing the financial planning subject
areas that CFP® Board’s studies have determined as necessary for the competent and professional
delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United
States college or university (or its equivalent from a foreign university). CFP® Board’s financial planning
subject areas include insurance planning and risk management, employee benefits planning, investment
planning, income tax planning, retirement planning, and estate planning;
• Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case
studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues
and apply one’s knowledge of financial planning to real world circumstances;
• Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
• Ethics – Agree to be bound by CFP® Board’s Standards of Professional Conduct, a set of documents
outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements in order
to maintain the right to continue to use the CFP® marks:
• Continuing Education – Complete 30 hours of continuing education hours every two years, including two
hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain
competence and keep up with developments in the financial planning field; and
• Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards
prominently require that CFP® professionals provide financial planning services at a fiduciary standard of
care. This means CFP® professionals must provide financial planning services in the best interests of their
clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP® Board’s
enforcement process, which could result in suspension or permanent revocation of their CFP® certification.
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Hystead. Mr. Hystead has never
been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration
claims or administrative proceedings against Mr. Hystead.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
LPWM, LLC dba Logan Park
Page 22
121 S 8th Street, Suite #1110, Minneapolis, MN 55402
Phone: (612) 315-2105 | Fax: (612) 677-3092
http://lpwm.com/
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Hystead.
However, the Advisor encourages Clients to independently view the background of Mr. Hystead on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual
CRD# 5750427.
Item 4 – Other Business Activities
Mr. Hystead is dedicated to the investment advisory activities of Logan Park’s Clients. Mr. Hystead does not have
any other business activities.
Item 5 – Additional Compensation
Mr. Hystead is dedicated to the investment advisory activities of Logan Park’s Clients. Mr. Hystead does not
receive any additional forms of compensation.
Item 6 – Supervision
Mr. Hystead serves as a Financial Advisor of Logan Park and is supervised by David Benning, the Chief
Compliance Officer. Mr. Benning can be reached at (612) 315-2105.
Logan Park has implemented a Code of Ethics, an internal compliance document, that guides each Supervised
Person in meeting their fiduciary obligations to Clients of Logan Park. Further, Logan Park is subject to regulatory
oversight by various agencies. These agencies require registration by Logan Park and its Supervised Persons. As
a registered entity, Logan Park is subject to examinations by regulators, which may be announced or
unannounced. Logan Park is required to periodically update the information provided to these agencies and to
provide various reports regarding the business activities and assets of the Advisor.
LPWM, LLC dba Logan Park
Page 23
121 S 8th Street, Suite #1110, Minneapolis, MN 55402
Phone: (612) 315-2105 | Fax: (612) 677-3092
http://lpwm.com/
Privacy Policy
Effective Date: September 3, 2025
Our Commitment to You
LPWM, LLC dba Logan Park (“Logan Park” or the “Advisor”) is committed to safeguarding the use of personal
information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as
described here in our Privacy Policy (“Policy”).
Our relationship with you is our most important asset. We understand that you have entrusted us with your private
information, and we do everything that we can to maintain that trust. Logan Park (also referred to as "we", "our"
and "us”) protects the security and confidentiality of the personal information we have and implements controls to
ensure that such information is used for proper business purposes in connection with the management or servicing
of our relationship with you.
Logan Park does not sell your non-public personal information to anyone. Nor do we provide such information to
others except for discrete and reasonable business purposes in connection with the servicing and management of
our relationship with you, as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are set forth
in this Policy.
Why you need to know?
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing
your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose
how we collect, share, and protect your personal information.
What information do we collect from you?
Social security or taxpayer identification number Assets and liabilities
Name, address and phone number[s]
Income and expenses
E-mail address[es]
Investment activity
Account information (including other institutions)
Investment experience and goals
What Information do we collect from other sources?
Custody, brokerage and advisory agreements
Other advisory agreements and legal documents
Transactional information with us or others
Account applications and forms
Investment questionnaires and suitability
documents
Other information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use we maintain physical, procedural and
electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a
secure office environment. Our technology vendors provide security and access control over personal information
and have policies over the transmission of data. Our associates are trained on their responsibilities to protect
Client’s personal information.
We require third parties that assist in providing our services to you to protect the personal information they receive
from us.
LPWM, LLC dba Logan Park
Page 24
121 S 8th Street, Suite #1110, Minneapolis, MN 55402
Phone: (612) 315-2105 | Fax: (612) 677-3092
http://lpwm.com/
How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list some
reasons we may share your personal information.
Basis For Sharing
Do we share?
Can you limit?
Yes
No
No
Not Shared
Yes
Yes
No
Not Shared
Servicing our Clients
We may share non-public personal information with non-affiliated third
parties (such as administrators, broker-dealers, custodians, regulators,
credit agencies, other financial institutions) as necessary for us to provide
agreed upon services to you, consistent with applicable law, including but
not limited to: processing transactions; general account maintenance;
responding to regulators or legal investigations; and credit reporting.
Marketing Purposes
Logan Park does not disclose, and does not intend to disclose, personal
information with non-affiliated third parties to offer you services. Certain
laws may give us the right to share your personal information with
financial institutions where you are a customer and where Logan Park or
the Client has a formal agreement with the financial institution. We will
only share information for purposes of servicing your accounts, not
for marketing purposes.
Authorized Users
Your non-public personal information may be disclosed to you and
persons that we believe to be your authorized agent[s] or
representative[s].
Information About Former Clients
Logan Park does not disclose and does not intend to disclose, non-public
personal information to non-affiliated third parties with respect to persons
who are no longer our Clients.
Changes to our Privacy Policy
We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.
Periodically we may revise this Policy, and will provide you with a revised Policy if the changes materially alter the
previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public
personal information other than as described in this notice unless we first notify you and provide you with an
opportunity to prevent the information sharing.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting
the Advisor at (612) 315-2105.
LPWM, LLC dba Logan Park
Page 25
121 S 8th Street, Suite #1110, Minneapolis, MN 55402
Phone: (612) 315-2105 | Fax: (612) 677-3092
http://lpwm.com/