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Firm Brochure
(Part 2A of Form ADV)
101 Village Parkway NE
Building 1, Suite 200
Marietta, GA 30067
PHONE: 770-984-2312
FACSIMILE: 770-984-3770
EMAIL: kbaer@baerwealth.com
WEBSITE: www.BaerWealth.com
This brochure provides information about the qualifications and business practices
of Baer Wealth Management. Being registered as a registered investment adviser
does not imply a certain level of skill or training. If you have any questions about the
contents of this brochure, please contact us at 770-984-2312 or by email
kbaer@baerwealth.com. The information in this brochure has not been approved or
verified by the United States Securities and Exchange Commission, or by any state
securities authority.
Additional information about Baer Wealth Management (IARD#150555) is available
on the SEC’s website at www.adviserinfo.sec.gov
April 24, 2025
Baer Wealth Management
Item 2: Material Changes
The Material Changes section of this brochure will be updated annually or when material
changes occur since the previous release of the Firm Brochure.
•
Since the last filing of this brochure on March 24, 2025, the following has been updated:
Typo fixed in Item 5 asset management fee schedule.
Whenever you would like to receive a complete copy of our Firm Brochure, please contact
us by telephone at 770-984-2312 or by email at kbaer@baerwealth.com.
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Item 3: Table of Contents
Form ADV – Part 2A – Firm Brochure
Item 1: Cover Page
Firm Brochure .......................................................................................................................................... i
Item 2: Material Changes ...................................................................................................................... i
Item 3: Table of Contents .................................................................................................................... ii
Item 4: Advisory Business .................................................................................................................. 3
Item 5: Fees and Compensation ....................................................................................................... 6
Item 6: Performance-Based Fees and Side by Side Management ......................................... 8
Item 7: Types of Clients ....................................................................................................................... 8
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................ 8
Item 9: Disciplinary Information ..................................................................................................... 9
Item 10: Other Financial Industry Activities and Affiliations ............................................. 10
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading ................................................................................................................................................... 10
Item 12: Brokerage Practices ......................................................................................................... 11
Item 13: Review of Accounts ........................................................................................................... 12
Item 14: Client Referrals and Other Compensation ................................................................ 12
Item 15: Custody .................................................................................................................................. 13
Item 16: Investment Discretion ..................................................................................................... 13
Item 17: Voting Client Securities ................................................................................................... 14
Item 18: Financial Information ...................................................................................................... 14
Baer Wealth Management
Item 4: Advisory Business
Baer-Dressler, LLC was formed in January 2000. In 2007 the name was changed to Baer Wealth
Management, LLC. In 2014 Molly B Investment Group, LLC was formed and purchased Baer
Wealth Management, LLC. Molly B Investment Group, LLC’s principal owner is Molly E. Baer.
Types of Advisory Services
Kenny Baer is Chief Compliance Officer.
PORTFOLIO MANAGEMENT
BWM offers discretionary asset management services to advisory Clients. BWM will offer Clients
ongoing asset management services through determining individual investment goals, time
horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset
allocation, portfolio monitoring and the overall investment program will be based on the above
factors. The Client will authorize BWM discretionary authority to execute selected investment
program transactions as stated within the Investment Advisory Agreement.
If client impose any written restrictions on BWM in the management of the client’s investment
portfolios, the client has been notified such restrictions may adversely affect the composition
and performance of the client’s investment portfolio.
Agreements may not be assigned without written client consent.
ALTERNATIVE INVESTMENTS
BWM may provide investment advice and due diligence about certain privately issued securities
for those clients who represent they are accredited investors and who otherwise meet certain
investor standards. (To qualify as an accredited investor, you must have a net worth, not
including your primary residence of at least $1 million; or have an income exceeding $200,000 in
each of the two most recent years or joint income with a spouse exceeding $300,000 for those
years and a reasonable expectation of the same income level in the current year.) BWM will
collect all available information—marketing materials, auditing reports, balance sheets, offering
memorandum, subscription agreement, review historical records and access opportunities and
risks for investment now and for the years ahead. Prepare and seek answers to relevant due
diligent questions. Interview manager and/or make site visit. Consider the time horizon and the
sponsor’s strength over an extended period of time. Due diligence will continue throughout the
duration of the investment. BWM will meet with the client at least on an annual basis for the
duration of the investment.
The fees for these services are detailed in Item 5 of this brochure.
ERISA PLAN SERVICES
BWM provides service to qualified retirement plans including 401(k) plans, 403(b) plans,
pension and profit sharing plans, cash balance plans, and deferred compensation plans. BWM
Limited Scope ERISA 3(21) Fiduciary.
may act as either a 3(21) or 3(38) advisor:
BWM may serve as a limited scope ERISA 3(21) fiduciary
that can advise, help and assist plan sponsors with their investment decisions on a non-
discretionary basis. As an investment advisor BWM has a fiduciary duty to act in the best interest
of the Client. The plan sponsor is still ultimately responsible for the decisions made in their plan,
though using BWM can help the plan sponsor delegate liability by following a diligent process.
1.
Fiduciary Services are:
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•
•
Provide non-discretionary investment advice to the Client about asset classes and investment
alternatives available for the Plan in accordance with the Plan’s investment policies and
objectives. Client will make the final decision regarding the initial selection, retention,
removal and addition of investment options. BWM acknowledges that it is a fiduciary as
defined in ERISA section 3 (21) (A) (ii).
•
Assist the Client in the development of an investment policy statement (“IPS”). The IPS
establishes the investment policies and objectives for the Plan. Client shall have the ultimate
responsibility and authority to establish such policies and objectives and to adopt and amend
the IPS.
•
Provide non-discretionary investment advice to the Plan Sponsor with respect to the
selection of a qualified default investment alternative for participants who are automatically
enrolled in the Plan or who have otherwise failed to make investment elections. The Client
retains the sole responsibility to provide all notices to the Plan participants required under
ERISA Section 404(c) (5) and 404(a)-5.
•
Assist in monitoring investment options by preparing periodic investment reports that
document investment performance, consistency of fund management and conformance to the
guidelines set forth in the IPS and make recommendations to maintain, remove or replace
investment options.
Meet with Client on a periodic basis to discuss the reports and the investment
recommendations.
2.
•
Non-fiduciary Services are:
•
Assist in the education of Plan participants about general investment information and the
investment alternatives available to them under the Plan. Client understands BWM’s
assistance in education of the Plan participants shall be consistent with and within the scope
of the Department of Labor’s definition of investment education (Department of Labor
Interpretive Bulletin 96-1). As such, BWM is not providing fiduciary advice as defined by
ERISA 3(21)(A)(ii) to the Plan participants. Advisor will not provide investment advice
concerning the prudence of any investment option or combination of investment options for
a particular participant or beneficiary under the Plan.
Assist in the group enrollment meetings designed to increase retirement plan participation
among the employees and investment and financial understanding by the employees.
BWM may provide these services or, alternatively, may arrange for the Plan’s other providers to
offer these services, as agreed upon between Advisor and Client.
3.
BWM has no responsibility to provide services related to the following types of assets (“Excluded
•
Assets”):
•
•
•
•
•
•
Employer securities;
Real estate (except for real estate funds or publicly traded REITs);
Stock brokerage accounts or mutual fund windows;
Participant loans;
Non-publicly traded partnership interests;
Other non-publicly traded securities or property (other than collective trusts and similar
vehicles); or
Other hard-to-value or illiquid securities or property.
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not
be included in calculation of Fees paid to BWM on the ERISA
Excluded Assets will
Agreement.
3(38) Investment Manager.
Specific services will be outlined in detail to each plan in the 408(b)2 disclosure.
BWM can also act as an ERISA 3(38) Investment Manager in which
it has discretionary management and control of a given retirement plan’s assets. BWM would
then become solely responsible and liable for the selection, monitoring and replacement of the
plan’s investment options.
1.
•
Fiduciary Services are:
•
BWM has discretionary authority and will make the final decision regarding the initial
selection, retention, removal and addition of investment options in accordance with the
Plan’s investment policies and objectives.
•
Assist the Client with the selection of a broad range of investment options consistent with
ERISA Section 404(c) and the regulations thereunder.
•
Assist the Client in the development of an investment policy statement (“IPS”). The IPS
establishes the investment policies and objectives for the Plan.
Provide discretionary investment advice to the Plan Sponsor with respect to the selection of a
qualified default investment alternative for participants who are automatically enrolled in
the Plan or who have otherwise failed to make investment elections. The Client retains the
sole responsibility to provide all notices to the Plan participants required under ERISA
Section 404(c) (5).
2.
•
Non-fiduciary Services are:
•
Assist in the education of Plan participants about general investment information and the
investment alternatives available to them under the Plan. Client understands the BWM’s
assistance in education of the Plan participants shall be consistent with and within the scope
of the Department of Labor’s definition of investment education (Department of Labor
Interpretive Bulletin 96-1). As such, the BWM is not providing fiduciary advice as defined by
ERISA to the Plan participants. BWM will not provide investment advice concerning the
prudence of any investment option or combination of investment options for a particular
participant or beneficiary under the Plan.
Assist in the group enrollment meetings designed to increase retirement plan participation
among the employees and investment and financial understanding by the employees.
BWM may provide these services or, alternatively, may arrange for the Plan’s other providers to
offer these services, as agreed upon between BWM and Client.
3.
BWM has no responsibility to provide services related to the following types of assets (“Excluded
•
Assets”):
•
•
•
•
•
Employer securities;
Real estate (except for real estate funds or publicly traded REITs);
Stock brokerage accounts or mutual fund windows;
Participant loans;
Non-publicly traded partnership interests;
Other non-publicly traded securities or property (other than collective trusts and similar
vehicles); or
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•
not
Other hard-to-value or illiquid securities or property.
be included in calculation of Fees paid to the Adviser on the ERISA
Excluded Assets will
Agreement.
BWM has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts:
$294,329,000
Date Calculated:
December 31, 2024
$0
Item 5: Fees and Compensation
Method of Compensation and Fee Schedule
From
To
Quarterly Fee
PORTFOLIO MANAGEMENT
BWM offers discretionary direct asset management services to advisory Clients. BWM charges an
Annual Fee
annual investment advisory fee based on the total assets under management as follows:
$0
$1,000,001
$2,000,001
$3,000,001
$5,000,001
$1,000,000
$2,000,000
$3,000,000
$5,000,000
+
1.00%
0.75%
0.60%
0.40%
0.20%
0.25%
0.1875%
0.15%
0.10%
0.05%
This is a blended fee schedule; the asset management fee is calculated by applying different rates
to different portions of the portfolio. BWM may group certain related Client accounts for the
End of the Quarter Balance Example
purposes of achieving the minimum account size and determining the annualized fee.
A Client with $3,000,000 under management would pay $5,875 on a quarterly basis.
First $1,000,000 x 0.0025 = $2,500
Next $1,000,000 x 0.001875= $1,875
Next $1,000,000 x 0.0015 = $1,500
There will be a minimum annual fee of $5,000 or 3% whichever is lower.
The annual fee may be negotiable. Fees are billed quarterly in advance based on the amount of
assets managed as of the last business day of the quarter, meaning we bill you before the three-
month period has started. If $25,000 or more of cash and/or securities are deposited or
withdrawn, a prorated fee will be charged on the net value of the deposit and/or withdrawn as of
the date of the activity. Fees are usually deducted from a designated client account to facilitate
billing. The client must consent in advance to direct debiting of their investment account.
Quarterly advisory fees deducted from the clients' account by the custodian will be reflected in
the client’s brokerage statement provided by the custodian. Lower fees for comparable services
may be available from other sources.
Clients may terminate their account within five (5) business days of signing the Investment
Advisory Agreement for a full refund. BWM or the client may terminate advisory services at any
time with written notice as disclosed in the Investment Advisory Agreement. In the event of
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termination, any paid but unearned fees will be refunded to the client. Client shall be given thirty
(30) days prior written notice of any increase in fees.
ALTERNATIVE INVESTMENTS
BWM will charge clients a fee of no more than 2% annually based on assets held in the selected
alternative investments for accounts up to $15,000,000. Over $15,000,000 fees are negotiable.
The annual Fee may be negotiable. Fees are billed quarterly in advance based on the amount of
assets in the account as of the last business day of the quarter. Quarterly advisory fees deducted
from the clients' account by the custodian will be reflected in the client’s brokerage statement
provided by the custodian. Lower fees for comparable services may be available from other
sources.
Investment management fees are billed quarterly in advance, meaning we bill you before the
three-month period has started. Fees are usually deducted from a designated client account to
facilitate billing. The client must consent in advance to direct debiting of their investment
account.
ERISA PLAN SERVICES
The annual fees are based on the market value of the Included Assets and will not exceed 1.25%.
Fees may be charged quarterly or monthly in arrears or in advance based on the assets as
calculated by the custodian or record keeper of the Included Assets (without adjustments for
anticipated withdrawals by Plan participants or other anticipated or scheduled transfers or
distribution of assets) on the last business day of the previous quarter or month. If the services
to be provided start any time other than the first day of a quarter or month, the fee will be
prorated based on the number of days remaining in the quarter or month. If this Agreement is
terminated prior to the end of the fee period, BWM shall be entitled to a prorated fee based on
the number of days during the fee period services were provided or Client will be due a prorated
refund of fees for days services were not provided in the billing cycle.
The fee schedule, which includes compensation of BWM for the services is described in detail in
Schedule A of the ERISA Plan Agreement. The Plan is obligated to pay the fees, however the Plan
Sponsor may elect to pay the fees. Client may elect to be billed directly or have fees deducted
from Plan Assets. BWM does not reasonably expect to receive any additional compensation,
directly or indirectly, for its services under this Agreement. If additional compensation is
received, BWM will disclose this compensation, the services rendered, and the payer of
compensation. BWM will offset the compensation against the fees agreed upon under this
Client Payment of Fees
Agreement.
Investment management fees are billed quarterly in advance, meaning that we invoice you
before the billing period. Fees are usually deducted from a designated Client account to facilitate
billing. The Client must consent in advance to direct debiting of their investment account.
BWM, in its sole discretion, may waive its maximum fee and/or charge a lesser investment
advisory fee based upon certain criteria (e.g., historical relationship, type of assets, anticipated
future earning capacity, anticipated future additional assets, dollar amounts of assets to be
Additional Client Fees Charged
managed, related accounts, account composition, negotiations with clients, etc.).
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Custodians may charge transaction fees on purchases or sales of certain mutual funds and
exchange-traded funds. These transaction charges are usually small and incidental to the
purchase or sale of a security. The selection of the security is more important than the nominal
Prepayment of Client Fees
fee that the custodian charges to buy or sell the security.
External Compensation for the Sale of Securities to Clients
Investment management fees are billed quarterly in advance.
BWM does not receive any external compensation for the sale of securities to Clients, nor do any
of the investment advisor representatives of BWM.
Item 6: Performance-Based Fees and Side by Side Management
Fees are not based on a share of the capital gains or capital appreciation of managed securities.
BWM does not use a performance-based fee structure because of the conflict of interest.
Performance based compensation may create an incentive for BWM to recommend an
investment that may carry a higher degree of risk to the Client.
Item 7: Types of Clients
BWM generally provides financial and investment advice to individuals, high net worth
individuals and pension and profit sharing plans and these client relationships vary in scope and
length of service.
The minimum portfolio value is generally set at $500,000. BWM reserves the right to accept
accounts with lower assets balances. Minimum annual fees may apply. BWM or a Manager may,
at its discretion, make exceptions to the foregoing or negotiate special fee arrangements where
BWM or the Manager deem appropriate under the circumstances.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Security analysis methods may include fundamental analysis, technical analysis, and cyclical
analysis. Investing in securities involves risk of loss that clients should be prepared to bear. Past
performance is not a guarantee of future returns.
Fundamental analysis involves evaluating a stock using real data such as company revenues,
earnings, return on equity, and profits margins to determine underlying value and potential
growth. Technical analysis involves evaluating securities based on past prices and volume.
Cyclical analysis involves analyzing the cycles of the market.
Based on BWM’s review of the investment philosophy of each Manager, its performance in
various market conditions, its personnel, and its fees structure and the client’s objectives, BWM
chooses the appropriate Manager(s). BWM makes no claims or guarantees as to the future
performance of the Manager(s).
The investment strategy for a specific client is based upon the objectives stated by the client
during consultations. The client may change these objectives at any time.
Fundamental analysis may involve interest rate risk, market risk, business risk, and financial
risk. Risks involved in technical analysis are inflation risk, reinvestment risk, and market risk.
Cyclical analysis involves inflation risk, market risk, and currency risk.
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BWM generally follows a long-term strategy, meaning it will purchase securities with the
expectation that the value of those securities will grow over a relatively long period of time,
generally greater than one year. BWM also generally selects Managers who follow a similar
strategy.
• Management Risk:
All investment programs have certain risks that are borne by the investor. Our investment
approach constantly keeps the risk of loss in mind. Investors face the following investment risks
and should discuss these risks with BWM:
•
The overall risk that the investment choices of the person(s) managing
the client portfolio may underperform to their relevant benchmarks causing the overall
Interest-rate Risk
performance of the account to also underperform.
• Market Risk
: Fluctuations in interest rates may cause investment prices to fluctuate.
For example, when interest rates rise, yields on existing bonds become less attractive,
causing their market values to decline.
•
: The price of a security, bond, or mutual fund may drop in reaction to
tangible and intangible events and conditions. This type of risk is caused by external
factors independent of a security’s particular underlying circumstances. For example,
Inflation Risk
political, economic and social conditions may trigger market events.
: When any type of inflation is present, a dollar today will buy more than a
• Currency Risk
dollar next year, because purchasing power is eroding at the rate of inflation.
• Reinvestment Risk
: Overseas investments are subject to fluctuations in the value of the dollar
against the currency of the investment’s originating country. This is also referred to as
exchange rate risk.
• Business Risk
: This is the risk that future proceeds from investments may have to be
reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates
to fixed income securities.
• Liquidity Risk
: These risks are associated with a particular industry or a particular
company within an industry. For example, oil-drilling companies depend on finding oil
and then refining it, a lengthy process, before they can generate a profit. They carry a
higher risk of profitability than an electric company which generates its income from a
steady stream of customers who buy electricity no matter what the economic
environment is like.
• Financial Risk
: Liquidity is the ability to readily convert an investment into cash.
Generally, assets are more liquid if many traders are interested in a standardized product.
For example, Treasury Bills are highly liquid, while real estate properties are not.
: Excessive borrowing to finance a business’ operations increases the risk of
profitability, because the company must meet the terms of its obligations in good times
and bad. During periods of financial stress, the inability to meet loan obligations may
result in bankruptcy and/or a declining market value.
Item 9: Disciplinary Information
In the last ten (10) years, BWM and its management have not been involved in any criminal or
civil action or have not been involved in legal or disciplinary events related to past or present
investment clients.
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Item 10: Other Financial Industry Activities and Affiliations
Neither BWM nor its employees are registered representatives of a broker-dealer or registered
or has an application pending to register as a futures commission merchant, commodity pool
operator, or a commodity trading advisor.
As part of the services of BWM, Kenneth Baer is a licensed insurance agent. From time to time,
they will offer clients services from those activities and receive commission for the sale of the
insurance products. Less than 10% of their time is spent in the insurance practices.
These represent a conflict of interest because it gives an incentive to recommend products and
services based on the commission and/or fee amount received. This conflict is mitigated by
disclosures, procedures, and the firm’s Fiduciary obligation to place the best interest of the
clients first and clients are not required to purchase any products or services. Clients have the
option to purchase these products or services through another insurance agent or tax
professional of their choosing.
BWM does not utilize the services of Third Party Money Managers to manage client accounts.
Item 11: Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
The employees of BWM have committed to a Code of Ethics (“Code”). The purpose of our Code is
to set forth standards of conduct expected of BWM employees and addresses conflicts that may
arise. The Code defines acceptable behavior for employees of BWM. The Code reflects BWM and
its supervised persons’ responsibility to act in the best interest of their client.
One area which the Code addresses is when employees buy or sell securities for their personal
accounts and how to mitigate any conflict of interest with our clients. We do not allow any
employees to use non-public material information for their personal profit or to use internal
research for their personal benefit in conflict with the benefit to our clients.
BWM’s policy prohibits any person from acting upon or otherwise misusing non-public or inside
information. No advisory representative or other employee, officer or director of BWM may
recommend any transaction in a security or its derivative to advisory clients or engage in
personal securities transactions for a security or its derivatives if the advisory representative
possesses material, non-public information regarding the security.
BWM’s Code is based on the guiding principle that the interests of the client are our top priority.
BWM’s officers, directors, advisors, and other employees have a fiduciary duty to our clients and
must diligently perform that duty to maintain the complete trust and confidence of our clients.
When a conflict arises, it is our obligation to put the client’s interests over the interests of either
employees or the company.
The Code applies to “access” persons. “Access” persons are employees who have access to non-
public information regarding any clients' purchase or sale of securities, or non-public
information regarding the portfolio holdings of any reportable fund, who are involved in making
securities recommendations to clients, or who have access to such recommendations that are
non-public.
The firm will provide a copy of the Code to any client or prospective client upon request.
BWM and its employees do not recommend to clients securities in which we have a material
financial interest.
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BWM and its employees may buy or sell securities that are also held by clients. In order to
mitigate conflicts of interest such as front running, employees are required to disclose all
reportable securities transactions as well as provide BWM with copies of their brokerage
statements.
The Chief Compliance Officer of BWM is Kenneth Baer. He reviews all employee trades each
month. The personal trading reviews ensure that the personal trading of employees does not
affect the markets and that clients of the firm receive preferential treatment. While most
employee trades are in products such as mutual funds, government securities, bonds or are small
in size, they may still impact the securities markets.
BWM does not maintain a firm proprietary trading account and does not have a material
financial interest in any securities being recommended and therefore no conflicts of interest
exist.
Item 12: Brokerage Practices
BWM will recommend the use of a particular broker-dealer based on their duty to seek best
execution for the client, meaning they have an obligation to obtain the most favorable terms for a
client under the circumstances. The determination of what may constitute best execution and
price in the execution of a securities transaction by a broker involves a number of considerations
and is subjective. Factors affecting brokerage selection include the overall direct net economic
result to the portfolios, the efficiency with which the transaction is affected, the ability to effect
the transaction where a large block is involved, the operational facilities of the broker-dealer, the
value of an ongoing relationship with such broker and the financial strength and stability of the
broker. BWM will select appropriate brokers based on a number of factors including but not
limited to their relatively low transaction fees and reporting ability. BWM relies on its broker to
provide its execution services at the best prices available. Lower fees for comparable services
may be available from other sources. Clients pay for any and all custodial fees in addition to the
advisory fee charged by BWM. BWM does not receive any portion of the trading fees.
BWM will recommend the use of Charles Schwab, Reliance Trust Company, and Ascensus Trust.
• Directed Brokerage
.
• Best Execution
In circumstances where a client directs BWM to use a certain broker-dealer, BWM still has
a fiduciary duty to its clients. The following may apply with Directed Brokerage: BWM's
inability to negotiate commissions, to obtain volume discounts, there may be a disparity
in commission charges among clients, and potential conflicts of interests arising from
brokerage firm referrals.
Investment advisors who manage or supervise client portfolios on a discretionary basis
have a fiduciary obligation of best execution. The determination of what may constitute
best execution and price in the execution of a securities transaction by a broker involves a
number of considerations and is subjective. Factors affecting brokerage selection include
the overall direct net economic result to the portfolios, the efficiency with which the
transaction is effected, the ability to effect the transaction where a large block is involved,
the operational facilities of the broker-dealer, the value of an ongoing relationship with
such broker and the financial strength and stability of the broker. The firm does not
receive any portion of the trading fees.
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• Soft Dollar Arrangements
The Securities and Exchange Commission defines soft dollar practices as arrangements
under which products or services other than execution services are obtained by BWM
from or through a broker-dealer in exchange for directing client transactions to the
broker-dealer. As permitted by Section 28(e) of the Securities Exchange Act of 1934, BWM
receives economic benefits as a result of commissions generated from securities
transactions by the broker-dealer from the accounts of BWM. These benefits include both
proprietary research from the broker and other research written by third parties.
BWM does not receive any soft dollar benefits.
BWM is authorized in its discretion to aggregate purchases and sales and other transactions
made for the account with purchases and sales and transactions in the same securities for other
Clients of BWM. All clients participating in the aggregated order shall receive an average share
price with all other transaction costs shared on a pro-rated basis.
Item 13: Review of Accounts
Account reviews are performed at least quarterly by Investment Advisor Representatives of
BWM. Account reviews are performed more frequently when market conditions dictate.
Other conditions that may trigger a review of client accounts are changes in the tax laws, new
investment information, and changes in a client's own situation.
Clients receive account statements no less than quarterly for managed accounts. Account reports
are issued by the Advisor’s custodian. Client receives confirmations of each transaction in
account from Custodian and an additional statement during any month in which a transaction
occurs.
Item 14: Client Referrals and Other Compensation
BWM receives additional economic benefits from external sources as described above in Item 12.
BWM may, from time to time, enter into agreements with individuals and organizations
(“referring party”) that refer Clients to BWM in exchange for compensation. This activity will
either be considered an endorsement or testimonial, depending on if the referring party is a
Client of BWM. For all Clients introduced by a referring party, BWM may pay that referring party
a fee pursuant to a previously executed agreement. While the specific terms of each agreement
may differ, the compensation will be based upon BWM’s engagement of new Clients and is
calculated using a fixed fee, or a varying percentage of the fees paid to BWM by such Clients. Any
such fee shall be paid solely from BWM’s investment management fee and shall not result in any
additional charge to the Client. BWM ensures that referring parties are registered with all
appropriate jurisdictions or exempt from registration as investment advisers or investment
adviser representatives.
Each referred Client to BWM under such an arrangement will receive a copy of this brochure and
a written disclosure clearly and prominently disclosing if the referring party is a current Client or
investor, the compensation that will be paid by BWM to the referring party and any material
conflicts of interest. The referring party is required provide this disclosure at the time the
endorsement or testimonial is disseminated and will obtain the Client’s signature acknowledging
Advisory Firm Payments for Client Referrals
receipt of BWM’s disclosure brochure and the written disclosure
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BWM may enter into referral agreements pursuant to which it compensates third-party
intermediaries for client referrals that result in the provision of investment advisory services by
BWM. BWM will disclose these referral arrangements to affected investors, and any cash
solicitation agreements will comply with Rule 206(4)-3 under the Advisers Act. Referring Parties
introducing clients to BWM may receive compensation from BWM, such as a retainer, a flat fee
per referral and/or a percentage of introduced capital. Such compensation will be paid pursuant
to a written agreement with the referring party and generally may be terminated by either party
from time to time. The cost of any such fees will be borne entirely by BWM and not by any
affected client.
Item 15: Custody
All assets are held at qualified custodians, which means the custodians provide account
statements directly to clients at their address of record at least quarterly. Clients are urged to
compare the account statements received directly from their custodians to the performance
report statements prepared by BWM.
BWM is deemed to have constructive custody solely because advisory fees are directly deducted
from client’s accounts by the custodian on behalf of BWM.
BWM is also deemed to have limited custody due to its Third-Party Standing Letters of
Authorization (“SLOA”).
BWM and its qualified custodian meet the following seven (7) conditions in order to avoid
maintaining full custody and be subject to the surprise exam requirement:
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 BWM, 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.
BWM 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.
BWM maintains records showing that the third party is not a related party nor located at
the same address as BWM.
7.
The Client’s qualified custodian sends the Client, in writing, an initial notice confirming the
instruction and an annual notice reconfirming the instruction.
Item 16: Investment Discretion
BWM requires discretionary authority to manage securities accounts on behalf of Clients. BWM
has the authority to determine, without obtaining specific Client consent, the securities to be
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bought or sold, and the amount of the securities to be bought or sold. The client will authorize
BWM discretionary authority to execute selected investment program transactions as stated
within the Investment Advisory Agreement.
BWM allows Client’s to place certain restrictions, as outlined in the Client’s Investment Policy
Statement or similar document. Such restrictions could include only allowing purchases of
socially conscious investments. These restrictions must be provided to BWM in writing.
The client approves the custodian to be used and the commission rates paid to the custodian.
BWM does not receive any portion of the transaction fees or commissions paid by the client to
the custodian on certain trades.
Item 17: Voting Client Securities
BWM does not vote proxies on securities. Clients are expected to vote their own proxies. The
client will receive their proxies directly from the custodian of their account or from a transfer
agent.
When assistance on voting proxies is requested, BWM generally does not research particular
proxy proposals.
Item 18: Financial Information
A balance sheet is not required to be provided because BWM does not serve as a custodian for
client funds or securities and BWM does not require prepayment of fees of more than $1,200 per
client and six months or more in advance.
BWM has no condition that is reasonably likely to impair our ability to meet contractual
commitments to our clients.
Neither BWM nor its management has had any bankruptcy petitions in the last ten years.
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