Overview
- Headquarters
- Timonium, MD
- Total Firm Assets
- $172 million
- Average High-Net-Worth Client Portfolio Size
- $3.1 million
- Minimum Account Size
- $1,000,000
Fee Structure
Primary Fee Schedule (FORM ADV PART 2A - FIRM BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $3,000,000 | 0.95% |
| $3,000,001 | and above | 0.65% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $9,500 | 0.95% |
| $5 million | $41,500 | 0.83% |
| $10 million | $74,000 | 0.74% |
| $50 million | $334,000 | 0.67% |
| $100 million | $659,000 | 0.66% |
Clients
- High-Net-Worth Share of Firm Assets
- 90.16%
- Number of High-Net-Worth Clients
- 50
- Total Client Accounts
- 333
- Discretionary Accounts
- 333
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Investment Advisor Selection
Regulatory Filings
- SEC CRD Number
- 338023
Additional Brochure: FORM ADV PART 2A - FIRM BROCHURE (2026-06-09)
View Document Text
Item 1: Cover Page
Thompson Wealth Solutions, LLC
dba Meta Wealth Advisory
1954 Greenspring Dr, Suite 310
Timonium, MD 21093
(410) 683-9263
Form ADV Part 2A – Firm Brochure
Dated: June 2026
This Brochure provides information about the qualifications and business practices of Thompson Wealth
Solutions, LLC dba Meta Wealth Advisory. If you have any questions about the contents of this Brochure,
please contact us at (410) 683-9263. The information in this Brochure has not been approved or verified by
the United States Securities and Exchange Commission or by any state securities authority.
Thompson Wealth Solutions, LLC dba Meta Wealth Advisory is a registered investment adviser. Registration
does not imply a certain level of skill or training.
Additional information about Thompson Wealth Solutions, LLC dba Meta Wealth Advisory also is available on
the SEC’s website at www.adviserinfo.sec.gov, which can be found using the firm’s identification number,
338023.
1
Item 2: Material Changes
Since filing the last annual amendment to this brochure in March 2026, the following changes have occurred:
● Updates have been made to disclose our new program for recommending third-party money
managers. As of the filing date of this brochure, the separately managed account program offered by
Dimensional Fund Advisors LP (“DFA SMA”) is the only third-party manager platform that SC&H is
recommending for suitable clients. The DFA SMA program offers clients access to several of
Dimensional Fund Advisors LP’s (“Dimensional”) U.S. or global strategies. Refer to Item 4: Advisory
Business, Item 5: Fes and Compensation, and Item 10: Other Financial Industry Activities and
Affiliations for more information.
In the future, any material changes made during the year will be reported here.
2
Item 3: Table of Contents
Item 1: Cover Page
1
Item 2: Material Changes
2
Item 3: Table of Contents
3
Item 4: Advisory Business
4
Item 5: Fees and Compensation
9
Item 6: Performance-Based Fees and Side-By-Side Management
13
Item 7: Types of Clients
14
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
15
Item 9: Disciplinary Information
18
Item 10: Other Financial Industry Activities and Affiliations
19
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
20
Item 12: Brokerage Practices
22
Item 13: Review of Accounts
26
Item 14: Client Referrals and Other Compensation
27
Item 15: Custody
28
Item 16: Investment Discretion
29
Item 17: Voting Client Securities
30
Item 18: Financial Information
31
3
Item 4: Advisory Business
Description of Advisory Firm
Thompson Wealth Solutions, LLC dba Meta Wealth Advisory is an Investment Adviser principally located in the
state of Maryland. We are a limited liability company founded in July 2025. Thompson Wealth Solutions, LLC
dba Meta Wealth Advisory became registered in 2025. Andrew Thompson is the principal owner and Chief
Compliance Officer (“CCO”).
As used in this brochure, the words “Meta Wealth Advisory”, “MWA”, "we", "our firm", “Advisor” and "us" refer
to Thompson Wealth Solutions, LLC and the words "you", "your" and "Client" refer to you as either a client or
prospective client of our firm.
Types of Advisory Services
MWA is a fee-only firm, meaning the only compensation we receive is from our Clients for our services. From
time to time, MWA recommends third-party professionals such as attorneys, accountants, tax advisors,
insurance agents, or other financial professionals. Clients are never obligated to utilize any third-party
professional we recommend. MWA is not affiliated with nor does MWA receive any compensation from third-
party professionals we may recommend.
Wealth Management Services
Wealth Management encompasses investment management services and financial planning. Our firm
provides continuous advice to a Client regarding the investment of Client funds based on the individual needs
of the Client. Through personal discussions in which goals and objectives based on a Client's particular
circumstances are established, we develop a Client's personal investment policy or an investment plan with
an asset allocation target and create and manage a portfolio based on that policy and allocation targets. We
will also review and discuss a Client’s prior investment history, as well as family composition and background.
Account supervision is guided by the stated objectives of the Client (e.g., maximum capital appreciation,
growth, income, or growth and income), as well as risk tolerance and tax considerations.
We primarily advise our Clients regarding investments in stocks, bonds, mutual funds, ETFs, U.S. government
and municipal securities, and cash and cash equivalents. We may also provide advice regarding investments
held in Client’s portfolio at the inception of our advisory relationship and/or other investment types not listed
above, at the Client’s request.
When we provide investment management services, Clients grant us limited authority to buy and sell
securities on a discretionary basis or non-discretionary basis. More information on our trading authority is
explained in Item 16 of this Brochure. Clients may impose reasonable restrictions in writing on investing in
certain securities, types of securities, or industry sectors.
Third-Party Manager Platforms: We can select for client accounts one or more specific third-party
investment adviser firms to serve as third-party managers to manage all or a portion of the assets of
the client’s account(s).
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As of the filing date of this brochure, the separately managed account program offered by
Dimensional Fund Advisors LP (“DFA SMA”) is the only third-party manager platform that we currently
recommend for suitable clients. The DFA SMA program offers clients access to several of Dimensional
Fund Advisors LP’s (“Dimensional”) U.S. or global strategies. The DFA SMA program allows clients to
directly hold the equity securities purchased by the various Dimensional strategies, rather than
owning shares in a mutual fund or ETF with the same strategy.
investment process
integrates research with advanced portfolio design and
Dimensional’s
management. Their strategies target long-term drivers of stock returns through higher weightings to
stocks with smaller market capitalizations, lower relative prices, and higher profitability, while
pursuing broad diversification across names and sectors.
Accounts in the DFA SMA program may also access exchange-traded funds (“ETFs”) managed by
Dimensional in order to gain broader diversification across multiple asset classes. Additional
advantages of the DFA SMA program include: clients have the ability to restrict account holdings by
security, industry, sector or country; clients may customize their account and enable values-based
decisions through a wide range of environmental, social and governance screens curated by
Dimensional; some clients may prefer to hold individual securities rather than mutual funds or ETFs;
and clients have access to customizable levels of tax management in the account as well as tax
transition analysis during the onboarding stage.
Under the DFA SMA program, MWA has entered into a master agreement with Dimensional Fund Advisors LP.
When MWA recommends the DFA SMA program to a client, and the client agrees with that recommendation,
the client will execute an Investment Advisory Agreement with MWA. That agreement grants MWA with
discretionary authority over the assets of the account, including the authority to utilize third-party manager
programs such as DFA SMA. MWA also provides the Client with a financial plan. A Client will be taken through
establishing their goals and values around money. Clients will be required to provide pertinent information
to help complete the following areas of analysis: net worth, cash flow, credit scores/reports, employee
benefits, retirement planning, insurance, investments, college planning, and estate planning. Once the Client's
information is reviewed, their plan will be built and analyzed, and then the findings, analysis and potential
changes to their current situation will be reviewed with the Client. Clients will receive a detailed financial plan
designed to help achieve Client’s stated financial goals and objectives. The plan and the Client's financial
situation and goals will be monitored throughout the year.
In general, the financial plan will address some or all of the following areas of concern. The Client and MWA
will work together to select specific areas to cover. These areas may include, but are not limited to, the
following:
● Business Planning: We provide consulting services for Clients who currently operate their own
business, are considering starting a business, or are planning for an exit from their current business.
Under this type of engagement, we work with you to assess your current situation, identify your
objectives, and develop a plan aimed at achieving your goals.
● Cash Flow and Debt Management: We will conduct a review of your income and expenses to
determine your current surplus or deficit along with advice on prioritizing how any surplus should be
used or how to reduce expenses if they exceed your income. Advice may also be provided on which
debts to pay off first based on factors such as the interest rate of the debt and any income tax
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ramifications. We may also recommend what we believe to be an appropriate cash reserve that should
be considered for emergencies and other financial goals, along with a review of accounts (such as
to save desired amounts.
money market
funds)
for such
reserves, plus strategies
● College Savings: Includes projecting the amount that will be needed to achieve college or other post-
secondary education funding goals, along with advice on ways for you to save the desired amount.
Recommendations as to savings strategies are included, and, if needed, we will review your financial
picture as it relates to eligibility for financial aid or the best way to contribute to children and
grandchildren (if appropriate).
● Employee Benefits Optimization: We will provide review and analysis as to whether you, as an
employee, are taking the maximum advantage possible of your employee benefits. If you are a
business owner, we will consider and/or recommend the various benefit programs that can be
goals.
structured
to
meet
both
business
and
personal
retirement
● Estate Planning: This usually includes an analysis of your exposure to estate taxes and your current
estate plan, which may include whether you have a will, powers of attorney, trusts, and other related
documents. Our advice also typically includes ways for you to minimize or avoid future estate taxes
by implementing appropriate estate planning strategies such as the use of applicable trusts. We
always recommend that you consult with a qualified attorney when you initiate, update, or complete
estate planning activities. We may provide you with contact information for attorneys who specialize
in estate planning when you wish to hire an attorney for such purposes. From time-to-time, we will
participate in meetings or phone calls between you and your attorney with your approval or request.
● Financial Goals: We will help Clients identify financial goals and develop a plan to reach them. We will
identify what you plan to accomplish, what resources you will need to make it happen, how much time
you will need to reach the goal, and how much you should budget for your goal.
●
Insurance: Review of existing policies to ensure proper coverage for life, health, disability, long-term
care, liability, home, and automobile.
●
Investment Analysis: This may involve developing an asset allocation strategy to meet Clients’
financial goals and risk tolerance, providing information on investment vehicles and strategies,
reviewing employee stock options, as well as assisting you in establishing your own investment
account at a selected broker/dealer or custodian. The strategies and types of investments we may
recommend are further discussed in Item 8 of this brochure.
● Retirement Planning: Our retirement planning services typically include projections of your
likelihood of achieving your financial goals, typically focusing on financial independence as the
primary objective. For situations where projections show less than the desired results, we may make
recommendations, including those that may impact the original projections by adjusting certain
variables (e.g., working longer, saving more, spending less, taking more risk with investments).
If you are near retirement or already retired, advice may be given on appropriate distribution
strategies to minimize the likelihood of running out of money or having to adversely alter spending
years.
during
your
retirement
6
● Risk Management: A risk management review includes an analysis of your exposure to major risks
that could have a significant adverse impact on your financial picture, such as premature death,
disability, property and casualty losses, or the need for long-term care planning. Advice may be
provided on ways to minimize such risks and about weighing the costs of purchasing insurance versus
the benefits of doing so and, likewise, the potential cost of not purchasing insurance (“self-insuring”).
● Tax Planning Strategies: Advice may include ways to minimize current and future income taxes as a
part of your overall financial planning picture. For example, we may make recommendations on which
type of account(s) or specific investments should be owned based in part on their “tax efficiency,” with
the consideration that there is always a possibility of future changes to federal, state or local tax laws
and rates that may impact your situation.
We recommend that you consult with a qualified tax professional before initiating any tax planning
strategy, and we may provide you with contact information for accountants or attorneys who
specialize in this area if you wish to hire someone for such purposes. We will participate in meetings
or phone calls between you and your tax professional with your approval.
In certain circumstances, we pay all or a portion of fees charged by third-party professionals (such as attorneys
or accountants) to assist clients with specialized needs. These payments are separate from and in addition to
the advisory fees you pay to Meta Wealth Advisory. See Item 5 for more information.
Tax Preparation Services
We offer tax preparation services for our Clients to assist with the filing of federal and state tax returns for
individuals and businesses. We may ask for an explanation or clarification of some items, but we will not audit
or otherwise verify Client data. The Client is responsible for the completeness and accuracy of information
used to prepare the returns. We may utilize the services of a third party accounting, bookkeeping, and tax
preparation firm to facilitate the preparation and filing of your tax return and we will work with you and the
third party in order to gather the necessary information as part of this service.
We may observe opportunities for tax savings that require planning or changes in the way the Client handles
some transactions. While an engagement for tax return preparation does not include significant tax planning
services, we will share any ideas we have with you and discuss terms for any additional work that may be
required to implement those ideas.
Client Tailored Services and Client Imposed Restrictions
We tailor the delivery of our services to meet the individual needs of our Clients. We consult with Clients
initially and on an ongoing basis, through the duration of their engagement with us, to determine risk
tolerance, time horizon and other factors that may impact the Clients’ investment and/or planning needs.
Clients are able to specify, within reason, any restrictions they would like to place as it pertains to individual
securities and/or sectors that will be traded in their account. All such requests must be provided to MWA in
writing. MWA will notify Clients if they are unable to accommodate any requests.
Wrap Fee Programs
We do not participate in wrap fee programs.
7
Assets Under Management
As of December 31, 2025, MWA has $172,057,328 in discretionary and $0 in non-discretionary assets under
management.
8
Item 5: Fees and Compensation
Please note, unless a Client has received this brochure at least 48 hours prior to signing an Advisory Contract,
the Advisory Contract may be terminated by the Client within five (5) business days of signing the Advisory
Contract without penalty or incurring any fees. At no time do we require prepayment of $1,200 or more six
months or more in advance of rendering the services.
How we are paid depends on the type of advisory services we perform. Below is a brief description of our
fees, however, you should review your executed Advisory Contract for more detailed information regarding
the exact fees you will be paying. Fees are negotiable and some fees may vary by Client for similar services.
No increase to the agreed-upon advisory fees outlined in the Advisory Contract shall occur without prior Client
consent.
Wealth Management Services
The fee is based on a percentage of assets under management and is negotiable. The annualized fee is based
on the following fee schedule:
Assets Under Management
Annual Advisory Fee
0.95%
$0 - $3,000,000
0.65%
$3,000,001 and Above
The annual advisory fee is paid quarterly in advance of each quarter based on the actual balance of the
Client’s account(s) as of the last day of each prior quarter. The advisory fee is based on asset ranges with
different rates applied to each range. For example, for assets under management of $4,000,000, a Client
would pay 0.95% on the first $3,000,000 and 0.65% on the remaining balance (using MWA’s standard fee
schedule). The formula for the quarterly fee is determined by the following calculation:(($3,000,000 x 0.95%)
+ ($1,000,000 x 0.65%)) /4. The effective rate is 0.875 percent.
MWA relies on the valuation as provided by Client’s custodian in determining assets under management. Our
advisory fee is prorated for any partial billing periods occurring during the engagement, including the initial
and terminating billing periods.
Third-Party Manager Platforms: As described in Item 5 of this brochure, clients that participate in the
DFA SMA program, or other third-party manager programs, will incur additional fees payable to the
third-party manager for the investment management services rendered.
You are advised that fees for third-party managed programs may be higher or lower than if you
directly obtained the services of the third-party manager or if you obtained advisory services
separately. You should read the third-party manager’s disclosure brochure for additional disclosure
of its managed program. When you engage with a recommended third-party manager, MWA will not
directly conduct any securities transactions on your behalf or participate directly in the selection of
the securities to be purchased or sold. Investment decisions are made by the third-party manager.
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All third-party manager fees are calculated and collected by the third-party manager. A complete
description of third-party manager’s services, fee schedules and account minimums will be disclosed
in the third-party manager’s disclosure brochure which will be provided to you prior to or at the time
the third-party manager is added to your account.
Tax Preparation Services
We charge an hourly fee of $350 for Tax Preparation Services. Fees may be negotiated or waived at the
discretion of MWA; the final agreed upon fee will be outlined in your Advisory Contract. Fees are due upon
completion of the services.
Fee Payment
For Wealth Management services, we deduct our advisory fee from one or more account(s) held at an
unaffiliated third-party custodian, as directed by the Client. Please refer to Item 15 of this Brochure regarding
our policy on direct fee deduction.
For Tax Preparation services, fees are paid by electronic funds transfer (EFT) or check. We use an independent
third party payment processor in which the Client can securely input their banking information and pay their
fee. We do not have access to the Client’s banking information at any time. The Client will be provided with
their own secure portal in order to make payments.
Other Types of Fees and Expenses
Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses
which may be incurred by the Client. Clients may incur certain charges imposed by custodians, brokers, and
other third parties such as custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire
transfer, and electronic fund fees, and other fees and taxes on brokerage accounts and securities
transactions. Mutual fund and exchange-traded funds also charge internal management fees, which are
disclosed in a fund's prospectus. Such charges, fees, and commissions are exclusive of and in addition to our
fee, and we shall not receive any portion of these commissions, fees, and costs.
Item 12 further describes the factors that we consider in selecting or recommending custodians for Client’s
transactions and determining the reasonableness of their compensation (e.g., commissions).
Clients may incur fees from third-party professionals such as accountants and attorneys that MWA may
recommend, upon Client request. Such fees are separate and distinct from MWA’s advisory fees.
When appropriate and based on the client’s individual needs, Meta Wealth Advisory will recommend the use
of outside professionals (e.g., attorneys or accountants) while providing financial planning and/or investment
advisory services to clients. This is most commonly done for tax planning and preparation services, estate
planning and drafting of legal documents by an attorney.
Fees for the services of an outside professional are in addition to and separate from the fees charged by Meta
Wealth Advisory. Depending on the client’s situation, Meta Wealth Advisory can offer to pay the entire third-
party fee or a portion of the fee, and the client will not be required to reimburse Meta Wealth Advisory for the
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payments. However, we do not cover the costs of outside professionals in all situations or for all clients. For
example, to the extent that you personally engage an outside professional on your own and without the
knowledge of Meta Wealth Advisory, you will be responsible for the third-party fees, and Meta Wealth Advisory
will not be required to reimburse you for such payments.
We generally offer to pay all or a portion of tax services for clients who meet our definition of high-net worth
($5 million of investable assets), but we are willing to consider covering all or a portion of the costs for any
client depending on the client’s situation and needs. We most commonly offer to pay all or a portion of third-
party service provider fees when a client’s tax situation is complex enough for us to make an impactful
difference in assisting with their tax planning or recommending a rebuttable third-party tax service provider.
Complex would mean significant tax planning throughout the year is required due to the calculation of
estimated payments, unique needs of a small business owner, those who own private entities and/or
partnerships generating K-1’s, certain real estate ownership, foreign entity ownership, and other sophisticated
scenarios. In these cases we would offer to assist with their tax services (in house or refer out to a third-party
service provider) and cover all or a portion of the cost of those services. We do not pay for clients who
can/should either self-prepare or who use a low-cost tax preparer because their tax situation is relatively
simple.
Similarly, we are willing to pay all or a portion of legal fees for estate planning and other needs that require
the use of a qualified attorney (drafting of documents and specific legal advice). This also typically applies to
the firm’s high-net worth client base, but we are willing to consider covering the costs for any client depending
on the client’s situation and needs. Limitations on the amount of legal fees we pay will apply due to
unforeseen circumstances we cannot always anticipate in advance. For example, we will not cover all legal
fees if the attorney identifies a more complicated legal situation that requires extensive legal research, time
and attention. However, in such a situation, we will ensure the attorney provides a quote for anticipated
services so you can agree or decline such services in advance.
There may be other firms than those we suggest that are more appropriate for your tax planning and legal
needs and other firms that charge lower fees for such services. Covering third-party fees creates a potential
conflict of interest because clients could perceive an incentive to use professionals recommended by Meta
Wealth Advisory. We address this conflict by:
• Not accepting any compensation, referral fees, or other benefits from recommended professionals.
• Providing multiple options and encouraging clients to conduct independent due diligence.
• Allowing clients to select any provider of their choice.
Terminations and Refunds
For Wealth Management services, the Advisory Contract may be terminated with written notice 30 calendar
days in advance. Upon termination of the Advisory Contract, a prorated refund will be provided to the Client.
For Tax Preparation services, this service is not an ongoing engagement, thus upon receipt of the final fees,
the Advisory Contract will automatically be terminated. Clients may terminate at any time provided written
notice. Client shall be charged a pro-rata fee based upon the number of hours work that was performed by
MWA up to the date of termination.
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Sale of Securities or Other Investment Products
MWA and its supervised persons do not accept compensation for the sale of securities or other investment
products including asset-based sales charges or service fees from the sale of mutual funds.
12
Item 6: Performance-Based Fees and Side-By-Side Management
We do not offer performance-based fees and do not engage in side-by-side management.
13
Item 7: Types of Clients
We provide financial planning and investment management services to individuals and high net-worth
individuals.
Our minimum account size requirement is $1,000,000 to open or maintain an account under our
management. MWA may reduce or waive the minimum account size requirement on a case-by-case basis.
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Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
Below is a brief description of our methods of analysis and primary investment strategies.
Methods of Analysis
Mutual Fund and/or ETF Analysis: We look at the experience and track record of the manager of the mutual
fund or ETF in an attempt to determine if that manager has demonstrated an ability to invest over a period of
time and in different economic conditions. We also look at the underlying assets in a mutual fund or ETF in
an attempt to determine if there is significant overlap in the underlying investments held in other funds in the
Client’s portfolio. In addition, we monitor the funds or ETFs in an attempt to determine if they are continuing
to follow their stated investment strategy.
A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not
guarantee future results. A manager who has been successful may not be able to replicate that success in the
future. In addition, as we do not control the underlying investments in a fund or ETF, managers of different
funds held by the client may purchase the same security, increasing the risk to the client if that security were
to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy
of the fund or ETF, which could make the fund or ETF less suitable for the Client’s portfolio.
Investment Strategies
Evidence-Based Investment Management
The Advisor employs an evidence-based investment approach, relying on academic research, historical
market data, and empirical studies rather than speculation or market timing. This philosophy supports a
disciplined, long-term strategy grounded in diversification, asset allocation, and risk management, rather than
short-term trading or attempts to beat the market.
Material Risks Involved
All investing strategies we offer involve risk and may result in a loss of your original investment which
you should be prepared to bear. Many of these risks apply equally to stocks, bonds, commodities, and any
other investment or security. Material risks associated with our investment strategies are listed below.
Market Risk: Market risk involves the possibility that an investment’s current market value will fall because
of a general market decline, reducing the value of the investment regardless of the operational success of the
issuer’s operations or its financial condition.
Strategy Risk: The Adviser’s investment strategies and/or investment techniques may not work as intended.
Small and Medium Cap Company Risk: Securities of companies with small and medium market
capitalizations are often more volatile and less liquid than investments in larger companies. Small and
medium cap companies may face a greater risk of business failure, which could increase the volatility of the
Client’s portfolio.
Interest Rate Risk: Bond (fixed income) prices generally fall when interest rates rise, and the value may fall
below par value or the principal investment. The opposite is also generally true: bond prices generally rise
15
when interest rates fall. In general, fixed income securities with longer maturities are more sensitive to these
price changes. Most other investments are also sensitive to the level and direction of interest rates.
Legal or Legislative Risk: Legislative changes or Court rulings may impact the value of investments, or the
securities’ claim on the issuer’s assets and finances.
Inflation: Inflation may erode the buying power of your investment portfolio, even if the dollar value of your
investments remains the same.
Risks Associated with Securities
Apart from the general risks outlined above which apply to all types of investments, specific securities may
have other risks.
Bank Obligations including bonds and certificates of deposit may be vulnerable to setbacks or panics in the
banking industry. Banks and other financial institutions are greatly affected by interest rates and may be
adversely affected by downturns in the U.S. and foreign economies or changes in banking regulations.
Commercial Paper is, in most cases, an unsecured promissory note that is issued with a maturity of 270 days
or less. Being unsecured the risk to the investor is that the issuer may default.
Common stocks may go up and down in price quite dramatically, and in the event of an issuer’s bankruptcy
or restructuring could lose all value. A slower-growth or recessionary economic environment could have an
adverse effect on the price of all stocks.
Corporate Bonds are debt securities to borrow money. Generally, issuers pay investors periodic interest and
repay the amount borrowed either periodically during the life of the security and/or at maturity. Alternatively,
investors can purchase other debt securities, such as zero coupon bonds, which do not pay current interest,
but rather are priced at a discount from their face values and their values accrete over time to face value at
maturity. The market prices of debt securities fluctuate depending on factors such as interest rates, credit
quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase
when interest rates fall. The longer the time to a bond’s maturity, the greater its interest rate risk.
Exchange Traded Funds prices may vary significantly from the Net Asset Value due to market conditions.
Certain Exchange Traded Funds may not track underlying benchmarks as expected. ETFs are also subject to
the following risks: (i) an ETF’s shares may trade at a market price that is above (premium) or below (discount)
their net asset value and an ETF purchased at a premium may ultimately be sold at a discount; (ii) trading of
an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are
delisted from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large
decreases in stock prices) halts stock trading generally. The Adviser has no control over the risks taken by the
underlying funds in which the Clients invest.
Municipal Bonds are debt obligations generally issued to obtain funds for various public purposes, including
the construction of public facilities. Municipal bonds pay a lower rate of return than most other types of
bonds. However, because of a municipal bond’s tax-favored status, investors should compare the relative
after-tax return to the after-tax return of other bonds, depending on the investor’s tax bracket. Investing in
municipal bonds carries the same general risks as investing in bonds in general. Those risks include interest
16
rate risk, reinvestment risk, inflation risk, market risk, call or redemption risk, credit risk, and liquidity and
valuation risk.
Mutual Funds When a Client invests in open-end mutual funds or ETFs, the Client indirectly bears its
proportionate share of any fees and expenses payable directly by those funds. Therefore, the Client will incur
higher expenses, many of which may be duplicative. In addition, the Client's overall portfolio may be affected
by losses of an underlying fund and the level of risk arising from the investment practices of an underlying
fund (such as the use of derivatives).
Options and other derivatives carry many unique risks, including time-sensitivity, and can result in the
complete loss of principal. While covered call writing does provide a partial hedge to the stock against which
the call is written, the hedge is limited to the amount of cash flow received when writing the option. When
selling covered calls, there is a risk the underlying position may be called away at a price lower than the current
market price.
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Item 9: Disciplinary Information
Criminal or Civil Actions
MWA and its management persons have not been involved in any criminal or civil action.
Administrative Enforcement Proceedings
MWA and its management persons have not been involved in any administrative enforcement proceedings.
Self-Regulatory Organization Enforcement Proceedings
MWA and its management persons have not been involved in any self-regulatory organization (SRO)
proceedings.
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Item 10: Other Financial Industry Activities and Affiliations
As described in Item 4 and Item 5, Meta Wealth Advisory recommends the use of specific law firms,
accounting firms, and other professional service providers but we are not affiliated or under common
ownership with any third-party service provider. We do not receive compensation, referral fees, or any other
benefits from third-party professionals we recommend. Our recommendations are based solely on
qualifications and client needs.
Broker-Dealer Affiliation
Neither MWA or its management persons is registered, or have an application pending to register, as a broker-
dealer or a registered representative of a broker-dealer.
Other Affiliations
Neither MWA or its management persons is registered, or have an application pending to register, as a futures
commission merchant, commodity pool operator, commodity trading advisor, or an associated person of the
foregoing entities.
Related Persons
Neither MWA or its management persons have any relationship or arrangement with any outside financial
industry related parties.
Andrew Thompson is currently a licensed insurance agent, however, he no longer sells any insurance
products, and is not affiliated with any insurance companies. Andrew Thompson will not sell any insurance
products to clients or prospective clients of MWA.
Recommendations or Selections of Other Investment Advisers
As described in Item 4 – Advisory Business and Item 5 – Fees and Compensation, MWA can form relationships
with independent, investment advisers to serve as third-party managers. We do not receive a referral fee or
other compensation from the third-party manager to refer clients to them.
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Item 11: Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
As a fiduciary, our firm has a duty of utmost good faith to act solely in the best interests of each Client. Our
Clients entrust us with their funds and personal information, which in turn places a high standard on our
conduct and integrity. Our fiduciary duty is a core aspect of our Code of Ethics and represents the expected
basis of all of our dealings. The firm also adheres to the Code of Ethics and Professional Responsibility adopted
by the CFP® Board of Standards Inc., and accepts the obligation not only to comply with the mandates and
requirements of all applicable laws and regulations but also to take responsibility to act in an ethical and
professionally responsible manner in all professional services and activities.
Code of Ethics Description
This Code of Ethics does not attempt to identify all possible conflicts of interest, and compliance with each of
its specific provisions will not shield our firm or its access persons from liability for misconduct that violates a
fiduciary duty to our Clients. A summary of the Code of Ethics' Principles is outlined below.
Integrity - Access persons shall offer and provide professional services with integrity.
●
● Objectivity - Access persons shall be objective in providing professional services to Clients.
● Competence - Access persons shall provide services to Clients competently and maintain the
necessary knowledge and skill to continue to do so in those areas in which they are engaged.
● Fairness - Access persons shall perform professional services in a manner that is fair and reasonable
to Clients, principals, partners, and employers, and shall disclose conflict(s) of interest in providing
such services.
● Confidentiality - Access persons shall not disclose confidential Client information without the specific
consent of the Client unless in response to proper legal process, or as required by law.
● Professionalism - Access persons conduct in all matters shall reflect the credit of the profession.
● Diligence - Access persons shall act diligently in providing professional services.
We periodically review and amend our Code of Ethics to ensure that it remains current, and we require all
firm access persons to attest to their understanding of and adherence to the Code of Ethics at least annually.
Our firm will provide a copy of its Code of Ethics to any Client or prospective Client upon request.
Investment Recommendations Involving a Material Financial Interest and Conflicts of
Interest
Neither our firm, its access persons, or any related person is authorized to recommend to a Client or effect a
transaction for a Client, involving any security in which our firm or a related person has a material financial
interest, such as in the capacity as an underwriter, adviser to the issuer, principal transaction, among others.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest
In order to mitigate any conflicts of interest, neither the firm or its related persons buys or sells the same
securities we recommend to clients.
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Trading Securities At/Around the Same Time as Client’s Securities
Neither our firm or its related persons buys or sells securities for client accounts at or about the same time
that we or a related person buys or sells the same securities for our own accounts.
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Item 12: Brokerage Practices
Factors Used to Select Custodians
In recommending custodians, we have an obligation to seek the “best execution” of transactions in Client
accounts. The determinative factor in the analysis of best execution is not the lowest possible commission
cost, but whether the transaction represents the best qualitative execution, taking into consideration the full
range of the custodian’s services. The factors we consider when evaluating a custodian for best execution
include, without limitation, the custodian’s:
● Combination of transaction execution services and asset custody services (generally without a
separate fee for custody);
● Capability to execute, clear, and settle trades (buy and sell securities for your account);
● Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests,
bill payment, etc.);
● Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds
(ETFs), etc.);
● Availability of investment research and tools that assist us in making investment decisions;
● Quality of services;
● Competitiveness of the price of those services (commission rates, margin interest rates, other fees,
etc.) and willingness to negotiate the prices;
● Reputation, financial strength, security and stability;
● Prior service to us and our clients.
With this in consideration, our firm recommends Fidelity, Altruist, and/or Schwab, independent and
unaffiliated SEC registered broker-dealer firms and members of the Financial Industry Regulatory Authority
(“FINRA”) and the Securities Investor Protection Corporation (“SIPC”).
Research and Other Soft-Dollar Benefits
We do not have any soft-dollar arrangements with custodians whereby soft-dollar credits, used to purchase
products and services, are earned directly in proportion to the amount of commissions paid by a Client.
However, as a result of being on their institutional platform, Fidelity may provide us with certain services that
may benefit us.
Fidelity
MWA has an arrangement with National Financial Services, LLC, and Fidelity Brokerage Services, LLC (together
with all affiliates, “Fidelity”) through which Fidelity provides MWA with Fidelity’s “platform” services. The
platform services include, among others, brokerage, custodial, administrative support, record keeping and
related services that are intended to support intermediaries like MWA in conducting business and in serving
the best interests of their clients, but that may benefit MWA.
1. SERVICES THAT BENEFIT YOU. Fidelity provides access to a range of investment products, execution
of securities transactions, and custody of client assets through National Financial Services, LLC and
Fidelity Brokerage, LLC. Also, Fidelity provides discount brokerage rates that are generally lower than
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retail investor rates. Fidelity services described in this paragraph generally benefit you and your
account.
2. SERVICES THAT MAY NOT DIRECTLY BENEFIT YOU. Fidelity also makes available to us other products
and services that benefit us, but may not directly benefit you or your account. These products and
services assist us in managing and administering our clients’ accounts, such as software and
technology that may:
● Assist with back-office functions, recordkeeping, and client reporting of our clients’ accounts.
● Provide access to client account data (such as duplicate trade confirmations and account
statements).
Investment research.
● Provide pricing and other market data.
● Assist with back-office functions, recordkeeping, and client reporting.
●
● Access to Fidelity’s trading desk for Advisors.
● Access to block trading.
3. SERVICES THAT GENERALLY BENEFIT ONLY US. By using Fidelity, we will be offered other services
intended to help us manage and further develop our business enterprise. These services include:
● Educational conferences and events.
● Consulting on technology, compliance, legal, and business needs.
● Publications and conferences on practice management and business succession.
● Vendor discounts to purchase business services, such as consulting, marketing and branding,
technology support and other similar business services.
4. YOUR BROKERAGE AND CUSTODY COSTS. Fidelity charges brokerage commissions and transaction
fees for effecting certain securities transactions (i.e., transaction fees are charged for certain no-load
mutual funds, commissions are charged for individual equity and debt securities transactions).
Fidelity enables MWA to obtain many no-load mutual funds without transaction charges and other
no-load funds at nominal transaction charges. Fidelity’s commission rates are generally considered
discounted from customary retail commission rates. However, the commissions and transaction fees
charged by Fidelity may be higher or lower than those charged by other custodians.
As part of its fiduciary duties to clients, MWA endeavors at all times to put the interests of its clients first.
Clients should be aware, however, that the receipt of economic benefits by MWA or its related persons in and
of itself creates a potential conflict of interest and may indirectly influence MWA’s choice of Fidelity for custody
and brokerage services.
Altruist
MWA offers investment advisory services through the custodial platform offered by Altruist Financial LLC, an
unaffiliated SEC-registered broker-dealer and FINRA/SIPC member (“Altruist”). Custody, clearing, and
execution services are provided by Altruist as a self-clearing broker-dealer. MWA’s clients establish brokerage
accounts through Altruist. MWA maintains an institutional relationship with Altruist whereby Altruist provides
certain benefits to MWA, including a fully digital account opening process, a variety of available investments,
and integration with software tools that can benefit MWA and its clients. MWA is not affiliated with Altruist.
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Charles Schwab & Company, Inc.
Clients can establish brokerage accounts with the Schwab Advisor Services division of Charles Schwab &
Company, Inc. (“Schwab”). Schwab provides MWA with access to its institutional trading and custody services,
which are typically not available to Schwab retail investors. These services generally are available to
independent investment advisors on an unsolicited basis, at no charge to them so long as a pre-determined
minimum amount of the advisor’s clients’ assets are maintained at Schwab Advisor Services. These services
are not contingent upon MWA committing to Schwab any specific amount of business (assets in custody or
trading commissions). Schwab’s brokerage services include the execution of securities transactions, custody,
research, and access to mutual funds and other investments that are otherwise generally available only to
institutional investors or would require significantly higher minimum initial investment.
Schwab Advisor Services also makes available to MWA other products are services that benefit MWA but may
not directly benefit clients’ accounts. Many of these products and services can be used to service all or some
substantial number of MWA’s accounts, including accounts not maintained Schwab.
Schwab’s products and services that assist MWA in managing and administering clients’ accounts include
software and other technology that (i) provides access to client account data (such as trade confirmations and
account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple client
accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of MWA’s fees from some
of its accounts; and (v) assist with back-office functions, recordkeeping and client reporting.
Schwab Advisor Services also offers other services intended to help MWA manage and further develop its
business enterprise. These services include: (i) compliance, legal and business consulting; (ii) publications and
conferences on practice management and business succession; and (iii) access to employee benefits
providers, human capital consultants and insurance providers. Schwab Advisor Services will discount or waive
fees it would otherwise charge for some of these services or pay all or part of the fees of a third-party
providing these services to MWA. Schwab Advisor Services will also provide other benefits such as educational
events or occasional business entertainment of MWA personnel. While as a fiduciary, MWA endeavors to act
in its clients’ best interests, MWA’s recommendation that clients maintain their assets in accounts at Schwab
will take into account availability of some of the foregoing products and services and other arrangements not
solely on the nature of cost or quality of custody and brokerage services provided by Schwab, which creates
a conflict of interest.
Brokerage for Client Referrals
We receive no referrals from a custodian, broker-dealer or third party in exchange for using that custodian,
broker-dealer or third party.
Clients Directing Which Broker/Dealer/Custodian to Use
Our firm recommends Clients establish account(s) at Fidelity, Altruist, and/or Schwab to execute transactions
through. We will assist with establishing your account(s) at Fidelity, Altruist, and/or Schwab however, we will
not have the authority to open accounts on the Client's behalf. Not all investment advisers require their Clients
to use their recommended custodian. By recommending that Clients use Fidelity, Altruist, and/or Schwab we
may be unable to achieve most favorable execution of Client transactions, and this practice may cost Clients
more money. We base our recommendations on the factors disclosed in Item 12 herein and will only
recommend custodians if we believe it's in the best interest of the Client.
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If Clients do not wish to utilize our recommended custodian, we permit Clients to direct brokerage. We will be
added to your account through a limited trading authority. However, due to restraints from not having access
to an institutional platform, we are unable to achieve most favorable execution of Client transactions. Clients
directing brokerage may cost Clients more money. For example, in a directed brokerage account, the Client
may pay higher brokerage commissions because we may not be able to aggregate orders to reduce
transaction costs, or the Client may receive a higher transaction price at their selected custodian versus our
recommended custodian.
Aggregating (Block) Trading for Multiple Client Accounts
Aggregating orders, batch trading, or block trading is a process where trades for the same securities are
purchased or sold for several clients at approximately the same time. We do not engage in block trading. It
should be noted that implementing trades on a block or aggregate basis may be less expensive for client
accounts; however, it is our trading policy to implement all client orders on an individual basis. Therefore, we
do not aggregate or “block” client transactions. Considering the types of investments we hold in advisory client
accounts, we do not believe clients are hindered in any way because we trade accounts individually. This is
because we develop individualized investment strategies for clients and holdings will vary. Our strategies are
primarily developed for the long-term and minor differences in price execution are not material to our overall
investment strategy.
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Item 13: Review of Accounts
Periodic Reviews
Clients will have their account(s) reviewed regularly on a quarterly basis by Andrew Thompson, Owner,
Founder, CEO and CCO. The account(s) are reviewed with regards to the Client’s investment objectives and
risk tolerance levels.
Triggers of Reviews
Events that may trigger a special review would be unusual performance, addition or deletions of Client-
imposed restrictions, excessive draw-down, volatility in performance, or buy and sell decisions from the firm
or per Client's needs.
Review Reports
Clients will receive trade confirmations from the custodian(s) for each transaction in their accounts as well as
monthly or quarterly statements and annual tax reporting statements from their custodian showing all activity
in the accounts, such as receipt of dividends and interest.
MWA does not provide written performance or holdings reports to Clients outside of what is provided directly
by their custodian.
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Item 14: Client Referrals and Other Compensation
Compensation Received by Thompson Wealth Solutions, LLC dba Meta Wealth Advisory
MWA is a fee-only firm that is compensated solely by its Clients. MWA does not receive commissions or other
sales-related compensation. Except as mentioned in Item 12 above, we do not receive any economic benefit,
directly or indirectly, from any third party for advice rendered to our Clients.
Client Referrals from Solicitors
MWA does not, directly or indirectly, compensate any person who is not advisory personnel for Client
referrals.
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Item 15: Custody
All accounts are held by an independent Custodian selected by the Client. With the exception of MWA’s ability
to debit fees, and the ability to disburse or transfer certain funds to third parties pursuant to Standing Letters
of Authorization executed by Clients, MWA does not otherwise have custody of the assets in the account.
MWA has the ability to directly deduct its advisory fees from Client’s custodial account. When doing so ,(1) the
Custodian sends quarterly statements to the client showing all disbursements for the custodian account,
including the amount of our advisory fees, and (2) the client provides written authorization permitting us to
be paid directly from their accounts held by the Custodian.
MWA can establish a standing letter of instructions or other similar asset transfer authorization arrangements
(“SLOA”) with qualified custodians in order for us to disburse funds to accounts as specifically designated by
the client. With a SLOA a client can typically authorize first-party and/or third-party transfers. If transfers are
third-party, MWA complies with each of the requirements and conditions enumerated below:
1. The client provides an instruction to the qualified custodian, in writing, that includes the client’s
signature, the third party’s name, and either the third party’s address or the third party’s account
number at a custodian to which the transfer should be directed.
2. The client authorizes MWA, in writing, either on the qualified custodian’s form or separately, to direct
transfers to the third party either on a specified schedule or from time to time.
3. The client’s qualified custodian performs appropriate verification of the instruction, such as a
signature review or other method to verify the client’s authorization, and provides a transfer of funds
notice to the client promptly after each transfer.
4. The client has the ability to terminate or change the instruction to the client’s qualified custodian.
5. MWA has no authority or ability to designate or change the identity of the third party, the address, or
any other information about the third party contained in the client’s instruction.
6. MWA maintains records showing that the third party is not a related party of MWA or located at the
same address as MWA.
7. The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction
and an annual notice reconfirming the instruction.
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Item 16: Investment Discretion
For those Client accounts where we provide Investment Management Services, MWA has discretionary
authority and limited power of attorney to determine the securities and the amount of securities to be bought
or sold for a Client’s account without having to obtain prior Client approval for each transaction. Investment
discretion is explained to Clients in detail when an advisory relationship has commenced. At the start of the
advisory relationship, the Client will execute a Limited Power of Attorney, which will grant our firm discretion
over the account(s). Additionally, the discretionary relationship will be outlined in the Advisory Contract and
signed by the Client. Clients may limit our discretion by requesting certain restrictions on investments.
However, approval of such requests are at the firm’s sole discretion.
If you enter into non-discretionary arrangements with our firm, we will obtain your approval prior to the
execution of any transactions for your account(s). You have an unrestricted right to decline to implement any
advice provided by our firm on a non-discretionary basis.
Clients can grant MWA discretionary authority (without first consulting with client) to establish and/or
terminate a relationship with a third-party manager for purposes of managing the client’s account(s) or a
portion of the account(s) determined by MWA.
When clients grant discretionary authority to establish or terminate a third-party manager relationship, client
also grants the third-party manager selected by MWA with the discretionary authority (in the sole discretion
of the third-party manager without first consulting with the client) to make all decisions to buy, sell or hold
securities, cash or other investments for such portion of the account managed by the third-party manager.
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Item 17: Voting Client Securities
We do not vote Client proxies. Therefore, Clients maintain exclusive responsibility for: (1) voting proxies, and
(2) acting on corporate actions pertaining to the Client’s investment assets. The Client shall instruct the Client’s
qualified custodian to forward to the Client copies of all proxies and shareholder communications relating to
the Client’s investment assets. If the Client has any questions on a particular proxy vote, they may contact us
at the number listed on the cover of this brochure.
In most cases, you will receive proxy materials directly from the account custodian. However, in the event we
were to receive any written or electronic proxy materials, we would forward them directly to you by mail,
unless you have authorized our firm to contact you by electronic mail, in which case, we would forward you
any electronic solicitation to vote proxies.
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Item 18: Financial Information
We have no financial commitment that impairs our ability to meet contractual and fiduciary commitments to
our Clients, nor have we been the subject of any bankruptcy proceeding. We do not have custody of Client
funds or securities, except as disclosed in Item 15 above, or require or solicit prepayment of more than $1,200
in fees six months or more in advance.
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