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Item 1: Cover Page for Part 2A of Form ADV: Firm Brochure
October 28, 2025
12410 Milestone Center Drive, Suite 175
Germantown, MD 20876
Firm Contact:
Melissa Price
Chief Compliance Officer
Firm Website Address:
www.my-wealthmgmt.com
This brochure provides information about the qualifications and business practices of MY Wealth
Management, Inc. If you have any questions about the contents of this brochure, please contact us by
telephone at 301-330-7900 or email admin@my-wealthmgmt.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 MY Wealth Management, Inc. is also available on the SEC’s website at
www.adviserinfo.sec.gov by searching CRD #168566.
Please note that the use of the term “registered investment adviser” and description of MY Wealth
Management, Inc. and/or our associates as “registered” does not imply a certain level of skill or
training. You are encouraged to review this Brochure and Brochure Supplements for our firm’s
associates who advise you for more information on the qualifications of our firm and our employees.
Item 2: Material Changes to Our Part 2A of Form ADV: Firm Brochure
MY Wealth Management, Inc. is required to advise you of any material changes to our Firm Brochure
(“Brochure”) from our last annual update, identify those changes on the cover page of our Brochure
or on the page immediately following the cover page, or in a separate communication accompanying
our Brochure. We must state clearly that we are discussing only material changes since the last
annual update of our Brochure, and we must provide the date of the last annual update of our
Brochure.
Since our firm’s last annual amendment filing on October 31, 2024, please see below regarding the
following material changes.
•
•
•
Our firm has updated our fee schedule:
First $1,500,000, 0.89%
$1,500,001 and above, 0.40%
Minimum fee of $4,000
Our firm has included the Wrap Asset Management and Asset Management(2020) fee schedules.
Please note, these fee schedules are only offered to legacy clients who have already engaged us for
these service offerings. See item 5 of our firm’s Form ADV Part 2A or reach out to MY Wealth
Management, Inc. for any additional questions.
Our firm has updated our Form CRS to clarify our various fee structures. Please see attached Form
CRS for these changes or reach out to MY Wealth Management, Inc. for any additional questions.
ADV Part 2A – Firm Brochure
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MY Wealth Management, Inc.
Item 3: Table of Contents
Contents
Item 1: Cover Page for Part 2A of Form ADV: Firm Brochure ............................................................................................... 1
Item 2: Material Changes to Our Part 2A of Form ADV: Firm Brochure ............................................................................ 2
Item 3: Table of Contents ...................................................................................................................................................................... 3
Item 4: Advisory Business .................................................................................................................................................................... 4
Item 5: Fees & Compensation ............................................................................................................................................................. 5
Item 6: Performance-Based Fees & Side-By-Side Management ............................................................................................ 8
Item 7: Types of Clients & Account Requirements ..................................................................................................................... 8
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss .................................................................................... 8
Item 9: Disciplinary Information ..................................................................................................................................................... 10
Item 10: Other Financial Industry Activities & Affiliations ................................................................................................... 10
Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading .............................. 11
Item 12: Brokerage Practices ............................................................................................................................................................ 12
Item 13: Review of Accounts or Financial Plans ....................................................................................................................... 15
Item 14: Client Referrals & Other Compensation ..................................................................................................................... 16
Item 15: Custody .................................................................................................................................................................................... 16
Item 16: Investment Discretion ....................................................................................................................................................... 16
Item 17: Voting Client Securities ..................................................................................................................................................... 17
Item 18: Financial Information ........................................................................................................................................................ 17
ADV Part 2A – Firm Brochure
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MY Wealth Management, Inc.
Item 4: Advisory Business
We offer Asset Management, Financial Planning & Consulting, and Retirement Plan Consulting. We are
dedicated to providing individuals and other types of clients with a wide array of investment advisory
services. Our firm has been in business as an investment adviser since 2013 and is wholly owned by
Jeffrey Yeakle.
The purpose of this Brochure is to disclose the conflicts of interest associated with the investment
transactions, compensation and any other matters related to investment decisions made by our firm
or its representatives. As a fiduciary, it is our duty to always act in the client’s best interest. This is
accomplished in part by knowing our client. Our firm has established a service-oriented advisory
practice with open lines of communication for clients to help meet their financial goals while
remaining sensitive to risk tolerance and time horizons. Working with clients to understand their
investment objectives while educating them about our process, facilitates the kind of working
relationship we value.
Description of the Types of Advisory Services We Offer
Asset Management:
As part of our Asset Management service, a portfolio is created, consisting of individual stocks, bonds,
exchange traded funds (“ETFs”), options, mutual funds and other public and private securities or
investments. The client’s individual investment strategy is tailored to their specific needs and may
include some or all of the previously mentioned securities. Portfolios will be designed to meet a
particular investment goal, determined to be suitable to the client’s circumstances. Once the appropriate
portfolio has been determined, portfolios are continuously and regularly monitored, and if necessary,
rebalanced based upon the client’s individual needs, stated goals and objectives.
Financial Planning & Consulting:
MY Wealth offers a complimentary financial planning session to help clients prepare for retirement
and assess the viability of their current retirement expectations.
Retirement Plan Consulting:
Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing
basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing,
monitoring and reviewing their company's participant-directed retirement plan. As the needs of the
plan sponsor dictate, areas of advising could include: investment options, plan structure and
participant education.
•
Retirement Plan Consulting services typically include:
•
•
Establishing an Investment Policy Statement – Our firm will assist in the development of a
statement that summarizes the investment goals and objectives along with the broad
strategies to be employed to meet the objectives.
Investment Options – Our firm will work with the Plan Sponsor to evaluate existing
investment options and make recommendations for appropriate changes.
Asset Allocation and Portfolio Construction – If applicable, our firm will develop strategic
asset allocation models to aid Participants in developing strategies to meet their investment
objectives, time horizon, financial situation and tolerance for risk.
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MY Wealth Management, Inc.
•
Investment Monitoring – Our firm will monitor the performance of the investments and notify
the client in the event of over/underperformance and in times of market volatility.
In providing services for retirement plan consulting, our firm does not provide any advisory services
with respect to the following types of assets: employer securities, real estate (excluding real estate
funds and publicly traded REITs), participant loans, non-publicly traded securities or assets, other
illiquid investments, or brokerage window programs (collectively, “Excluded Assets”).
All retirement plan consulting services shall be in compliance with the applicable state laws
regulating retirement consulting services. This applies to client accounts that are retirement or other
employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974,
as amended (“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to
provide services to such accounts, our firm acknowledges its fiduciary standard within the meaning
of Section 3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with
respect to the provision of services described therein.
Tailoring of Advisory Services
We offer individualized investment advice to clients utilizing our Asset Management services.
Additionally, we offer general investment advice to clients utilizing our Retirement Plan Consulting.
Each Asset Management client has the opportunity to place reasonable restrictions on the types of
investments to be held in the portfolio. Restrictions on investments in certain securities or types of
securities may not be possible due to the level of difficulty this would entail in managing the account.
Participation in Wrap Fee Programs
Our firm has legacy wrap fee accounts, which are managed on an individualized basis according to the
client’s investment objectives, financial goals, risk tolerance, etc. Clients who have already engaged
our firm for this service have received our Appendix 1 to Form ADV 2A: Wrap Fee Program Brochure.
Our firm does not offer wrap accounts to new or existing clients that are not already in the legacy
wrap fee program.
Regulatory Assets Under Management
, 2025, our firm manages $ 141,631,000 on a discretionary basis and $ 14,551,000 on
st
As of July 31
a non-discretionary basis.
Item 5: Fees & Compensation
How We Are Compensated for Our Advisory Services
Asset Management:*
Assets Under Management (AUM)
Annual %
*Minimum Annual Fee $4,000, Fees are calculated on a tiered basis
First $1,500,000
$1,500,001 and above
0.89%
0.40%
Annuities are not included in calculations of AUM when determining breakpoint.
ADV Part 2A – Firm Brochure
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MY Wealth Management, Inc.
Fees to be assessed will be outlined in the advisory agreement to be signed by the client. Annualized
fees are billed on a pro-rata basis monthly in arrears based on the value of the account(s) on the last
day of the month. Fees are negotiable and will be deducted from client account(s). Please note our
firm has the right to waive the minimum annual fee. Unless otherwise noted in writing, our firm bills
on cash. In rare cases, our firm will agree to directly invoice. As part of this process, Clients
understand the following:
a)
b)
c)
The client’s independent custodian sends statements at least quarterly showing the market
values for each security included in the Assets and all account disbursements, including the
amount of the advisory fees paid to our firm;
Clients will provide authorization permitting our firm to be directly paid by these terms. Our
firm will send an invoice directly to the custodian; and
If our firm sends a copy of our invoice to the client, a legend urging the comparison of
information provided in our statement with those from the qualified custodian will be
included.
Wrap Asset Management:
Wrap Asset Management is only offered to legacy clients who have already engaged us for this service
offering. We will continue to honor the terms and conditions of executed Wrap Asset Management
Agreements with legacy clients but are no longer offering a wrap fee account option for new or
existing clients in other advisory accounts.
Assets Under Management Annual %
Wrap Asset Management Fee Schedule:
1.25%
0.85%
0.75%
0.50%
0.35%
0.30%
First $250,000
Next $250,000
Next $500,000
Next $500,000
Next $1,000,000
Next $1,000,000
Asset Management(2020):
Asset Management(2020) is only offered to legacy clients who have already engaged us for this
service offering. We will continue to honor the terms and conditions of executed Asset
Management(2020) Agreements with legacy clients.
Assets Under Management Annual %
Asset Management(2020) Fee Schedule:
1.20%
0.70%
0.50%
0.30%
First $500,000
Next $500,000
Next $2,000,000
Next $2,000,000
The minimum annual fee is $3,200.
ADV Part 2A – Firm Brochure
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MY Wealth Management, Inc.
Retirement Plan Consulting:
Our Retirement Plan Consulting services are billed on an hourly or flat fee basis, or a fee based on the
percentage of Plan assets under management. The total estimated fee, as well as the ultimate fee
charged, is based on the scope and complexity of our engagement with the client. The maximum
hourly fee to be charged will not exceed $300. Our flat fees range from $750 to $10,000. Fees based
on a percentage of managed Plan assets will not exceed 0.75%. The fee-paying arrangements for
Retirement Plan Consulting service will be determined on a case-by-case basis and will be detailed
in the signed consulting agreement.
Other Types of Fees & Expenses
Non-Wrap Clients will incur transaction fees for trades executed by their chosen custodian, via
individual transaction charges. These transaction fees are separate from our firm’s advisory fees and
will be disclosed by the chosen custodian. Charles Schwab & Co. Inc. (“Schwab”) and Altruist Financial
LLC (“Altruist”) do not charge transaction fees for U.S. listed equities and exchange traded funds.
Clients may also pay holdings charges imposed by the chosen custodian for certain investments,
charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be
disclosed in the fund’s prospectus (e.g., fund management fees, distribution fees, surrender charges,
variable annuity fees, IRA and qualified retirement plan fees, mark-ups and mark-downs, spreads
paid to market makers, fees for trades executed away from custodian, wire transfer fees and other
fees and taxes on brokerage accounts and securities transactions). Our firm does not receive a portion
of these fees.
Legacy Wrap fee clients have received our Form ADV, Part 2A, Appendix 1 (the “Wrap Fee Program
Brochure”). Wrap fee clients will not incur transaction costs for trades. More information about this
is disclosed in our separate Wrap Fee Program Brochure.
Termination & Refunds
Either party may terminate the advisory agreement signed with our firm for Asset Management
services in writing at any time. Upon notice of termination, pro-rata advisory fees for services
rendered to the point of termination will be charged. If advisory fees cannot be deducted, our firm
will send an invoice for due advisory fees to the client.
We historically charged our Wrap Asset Management advisory fees quarterly in advance. In the event
that you wish to terminate our services, we will refund the unearned portion of our advisory fee to
you. You need to contact us or your custodian in writing and state that you wish to terminate our
services. Upon notification of your termination, we will proceed to close out your account and process
a pro-rata refund of unearned advisory fees.
Either party to a Retirement Plan Consulting Agreement may terminate at any time by providing
written notice to the other party. Full refunds will only be made in cases where cancellation occurs
within 5 business days of signing an agreement. After 5 business days from initial signing, either party
must provide the other party 30 days written notice to terminate billing. Billing will terminate 30
days after receipt of termination notice. Clients will be charged on a pro-rata basis, which takes into
account work completed by our firm on behalf of the client. Clients will incur charges for bona fide
advisory services rendered up to the point of termination (determined as 30 days from receipt of said
written notice) and such fees will be due and payable.
ADV Part 2A – Firm Brochure
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MY Wealth Management, Inc.
Commissionable Securities Sales
Our firm and representatives do not sell securities for a commission in advisory accounts.
Item 6: Performance-Based Fees & Side-By-Side Management
We do not accept performance-based fees.
Item 7: Types of Clients & Account Requirements
We have the following types of clients:
•
•
•
•
Individuals and High Net Worth Individuals;
Trusts, Estates or Charitable Organizations;
Pension and Profit Sharing Plans; and
Corporations, Limited Liability Companies and/or Other Business Types
While MY Wealth does not require a minimum account value for us to manage client accounts, we do
charge a minimum annual fee of $4,000.
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
Methods of Analysis
We use the following methods of analysis in formulating our investment advice and/or managing
client assets:
Fundamental Analysis:
•
Technical Analysis
We attempt to measure the intrinsic value of a security by looking
at economic and financial factors (including the overall economy, industry conditions, the
financial condition of the company, its products, and the experience and expertise of the
company's management) to determine the value of the company and whether its stock is
underpriced or overpriced. Fundamental analysis does not attempt to anticipate market
movements. This presents a potential risk, as the price of a security can move up or down
along with the overall market regardless of the economic and financial factors considered in
evaluating the stock. In addition, there is a risk that information obtained may be incorrect
and the analysis may not provide an accurate estimate of earnings, which may be the basis
for a stock's value. If securities prices adjust rapidly to new information, utilizing
fundamental analysis may not result in favorable performance.
•
: We analyze past market movements and apply that analysis to the
present in an attempt to recognize recurring patterns of investor behavior and potentially
predict future price movement. Technical analysis does not consider the underlying financial
condition of a company. This presents a risk in that a poorly-managed or financially unsound
company may underperform regardless of market movement.
Quantitative Analysis
•
: We use a statistical analysis in an attempt to obtain more accurate
measurements of a company's quantifiable data, such as the value of a share price or earnings
per share, volatility of returns, and trailing performance, and predict changes to that data. A
risk in using quantitative analysis is that the analysis used may be based on assumptions that
prove to be incorrect.
Qualitative Analysis
•
: We subjectively evaluate non-quantifiable factors such as quality and
tenure of management, investment and business strategies, and strength of research and
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MY Wealth Management, Inc.
development factors not readily subject to measurement, and predict changes to share price
based on that data. A risk is using qualitative analysis is that our subjective judgment may
prove incorrect.
Fund Analysis
•
: We look at the experience and track record of the manager of the fund 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 fund construction, and the fund's
investment mandate and strategy. A risk of fund 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, 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, which could make the holding(s) less suitable for the client's portfolio.
Our analysis methods rely on the assumption that the companies whose securities we purchase
and sell, the rating agencies that review these securities, and other publicly-available sources of
information about these securities, are providing accurate and unbiased data. While we are alert
to indications that data may be incorrect, there is always a risk that our analysis may be
compromised by inaccurate or misleading information.
Investment Strategies We Use:
We use the following strategies in managing client accounts. Investment strategies and advice
may vary depending upon each client's specific financial situation. As such, we determine
investments and allocations based upon the client's predefined objectives, risk tolerance, time
horizon, financial horizon, financial information, liquidity needs, and other various suitability
factors. The client's restrictions and guidelines may affect the composition of his/her portfolio.
Long-Term Purchases
•
: We purchase securities with the idea of holding them in the client's
account for a year or longer. Typically we use this strategy when we believe the securities to
be currently undervalued and/or we want exposure to a particular asset class over time,
regardless of the current projection for this class. Long term purchases may be affected by
unforeseen long term changes in the company in which the client is invested or in the overall
market. Another risk in a long-term purchase strategy is that by holding the security for a
long length of time, we may not take advantage of short-term gains that could be profitable
to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value
before the decision to sell is made.
Short-Term Purchases
•
: We purchase securities with the expectation that they will be sold
within a relatively short period of time, generally less than one year, to take advantage of the
securities' short-term price fluctuations. Short term trading generally involves a greater
degree of risk than long term trading due to market volatility over a short period of time. We
may use short-term trading (in general, selling securities within 30 days of purchasing the
same securities) as an investment strategy when managing clients' accounts. Short-term
trading is not a fundamental part of our overall investment strategy, but we may use this
strategy occasionally when we determine that it is suitable given a client's stated investment
objectives and tolerance for risk.
Margin Transactions
•
: If granted authority by a client, we may purchase securities for a client
with money borrowed from a client's brokerage account, in which case the security serves as
ADV Part 2A – Firm Brochure
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MY Wealth Management, Inc.
collateral on the loan. When a client buys on margin, that means the client is borrowing
money (interest is payable) from a broker to purchase securities. Margin trading allows a
client to buy more stock than he/she would be able to normally. When the client sells the
security in a margin account, the proceeds go to the broker against the repayment of the loan
until it is fully paid. There may also be restriction called the maintenance margin, which is the
minimum account balance a client must maintain before the broker will force the client to
deposit more funds or sell stock to pay down the loan (a "margin call"). If for any reason the
client does not meet a margin call, the broker has the right to sell the client's securities to
increase account equity until the maintenance margin has been achieved. The broker may not
be required to consult the client before selling. Margin trading is not a fundamental part of
our overall investment strategy, but we may use this strategy very occasionally when given
authority and we determine that it is suitable given a client's stated investment objectives
and tolerance for risk.
Option Writing
•
: We may use options as an investment strategy. An option is a contract that
gives the buyer the right, but not the obligation, to buy or sell an asset (such as a share of
stock) at a specific price on or before a certain date. An option, just like a stock or bond, is a
security. An option is also a derivative, because it derives its value from an underlying asset.
We may also utilize funds which utilize options strategies. The two types of options are calls
and puts. A "call" gives MY Wealth Management the right to buy an asset at a certain price
within a specific period of time. We will buy a call if we believe that the stock will increase
substantially before the option expires. A "put" gives the holder the right to sell an asset at a
certain price within a specific period of time. MY Wealth Management will buy a "put" if we
believe that the price of the stock will fall before the option expires. Option writing is not a
fundamental part of MY Wealth Management’s overall investment strategy, but we may use
this strategy very occasionally when given authority and we determine that it is suitable given
a client's stated investment objectives and tolerance for risk.
Please Note
:
Investing in securities involves risk of loss that clients should be prepared to bear. While the stock
market may increase and your account(s) could enjoy a gain, it is also possible that the stock
market may decrease and your account(s) could suffer a loss. It is important that you understand
the risks associated with investing in the stock market, are appropriately diversified in your
investments, and ask us any questions you may have.
Item 9: Disciplinary Information
There are no legal or disciplinary events that are material to a client’s or prospective client’s
evaluation of our advisory business or the integrity of our management.
Item 10: Other Financial Industry Activities & Affiliations
Our firm or our management persons have a material relationship with the following related
person(s) as follows:
1. Insurance Company or Agency
Representatives of our firm are insurance agents/brokers. They may offer insurance
products and receive customary fees as a result of insurance sales. A conflict of interest may
arise as these insurance sales may create an incentive to recommend products based on the
compensation adviser and/or our supervised persons may earn and may not necessarily be
in the best interests of the client.
ADV Part 2A – Firm Brochure
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MY Wealth Management, Inc.
Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal
Trading
As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material
facts and to act solely in the best interest of each of our clients at all times. Our fiduciary duty is the
underlying principle for our firm’s Code of Ethics, which includes procedures for personal securities
transaction and insider trading. Our firm requires all representatives to conduct business with the
highest level of ethical standards and to comply with all federal and state securities laws at all times.
Upon employment with our firm, and at least annually thereafter, all representatives of our firm will
acknowledge receipt, understanding and compliance with our firm’s Code of Ethics. Our firm and
representatives must conduct business in an honest, ethical, and fair manner and avoid all circumstances
that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure
is provided to give all clients a summary of our Code of Ethics. If a client or a potential client wishes to
review our Code of Ethics in its entirety, a copy will be provided promptly upon request.
Our firm recognizes that the personal investment transactions of our representatives demands the
application of a Code of Ethics with high standards and requires that all such transactions be carried out
in a way that does not endanger the interest of any client. At the same time, our firm also believes that if
investment goals are similar for clients and for our representatives, it is logical, and even desirable, that
there be common ownership of some securities.
1
In order to prevent conflicts of interest, our firm has established procedures for transactions effected by
. In order to monitor compliance with our personal
our representatives for their personal accounts
trading policy, our firm has pre-clearance requirements and a quarterly securities transaction reporting
system for all of our representatives.
Neither our firm nor a related person recommends, buys or sells for client accounts, securities in
which our firm or a related person has a material financial interest without prior disclosure to the
client.
Related persons of our firm may buy or sell securities and other investments that are also
recommended to clients. In order to minimize this conflict of interest, our related persons will place
client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which
is available upon request.
Likewise, related persons of our firm buy or sell securities for themselves at or about the same time they
buy or sell the same securities for client accounts. In order to minimize this conflict of interest, our
related persons will place client interests ahead of their own interests and adhere to our firm’s Code of
Ethics, a copy of which is available upon request. Further, our related persons will refrain from buying
or selling securities that will be bought or sold in client accounts unless done so after the client execution
or concurrently as a part of a block trade.
1
For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse,
his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our
associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect
beneficial interest in.
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MY Wealth Management, Inc.
Item 12: Brokerage Practices
Custodian & Brokers Used
Item 15
Our firm does not maintain custody of client assets (although our firm may be deemed to have
Custody
custody of client assets if given the authority to withdraw assets from client accounts. See
, below). Client assets must be maintained in an account at a “qualified custodian,” generally
a broker-dealer or bank. Our firm recommends that clients use the Schwab Advisor Services division
of Charles Schwab & Co. Inc. (“Schwab”) and Altruist Financial LLC (“Altruist”), both FINRA-registered
broker-dealers, member SIPC, as the qualified custodians. Our firm is independently owned and
operated, and not affiliated with Schwab or Altruist, also referred to as (“the custodians”). The
custodians will hold client assets in a brokerage account and buy and sell securities when instructed.
While our firm recommends that clients use the custodians, clients will decide whether to do so and
open an account with the custodians by entering into an account agreement directly with them. Our
firm does not open the account. Even though the account is maintained at the custodians, our firm
can still use other brokers to execute trades, as described in the next paragraph.
How Brokers/Custodians Are Selected
•
Our firm seeks to recommend a custodian/broker who will hold client assets and execute
transactions on terms that are overall most advantageous when compared to other available
providers and their services. A wide range of factors are considered, including, but not limited to:
•
•
•
•
•
combination of transaction execution services along with asset custody services (generally
without a separate fee for custody)
capability to execute, clear and settle trades (buy and sell securities for client accounts)
capabilities to facilitate transfers and payments to and from accounts (wire transfers, check
requests, bill payment, etc.)
breadth of investment products made available (stocks, bonds, mutual funds, exchange
traded funds (ETFs), etc.)
availability of investment research and tools that assist 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 them
•
•
•
reputation, financial strength and stability of the provider
prior service to our firm and our other clients
Products & Services Available from Schwab
availability of other products and services that benefit our firm, as discussed below (see
“
”)
Custody & Brokerage Costs
Broker-dealers used by MY Wealth generally do not charge separately for custody services but may
be compensated by charging commissions or other fees to clients on trades. In addition to potential
commissions, broker-dealers often charge a flat dollar amount as a “prime broker” or “trade away”
fee for each trade that our firm has executed by a different broker-dealer but where the securities
bought or the funds from the securities sold are deposited (settled) into a Schwab or Altruist account.
These fees are in addition to the potential commissions or other possible compensation paid to the
executing broker-dealer. Because of this, in order to minimize client trading costs, our firm has
custodians selected (Schwab and Altruist) execute most trades for the accounts.
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MY Wealth Management, Inc.
Products & Services Available from Schwab
Schwab Advisor Services is Schwab’s business serving independent investment advisory firms like
our firm. They provide our firm and clients with access to its institutional brokerage – trading,
custody, reporting and related services – many of which are not typically available to Schwab retail
customers. Schwab also makes available various support services. Some of those services help
manage or administer our client accounts while others help manage and grow our business. Schwab’s
support services are generally available on an unsolicited basis (our firm does not have to request
them) and at no charge to our firm. The availability of Schwab’s products and services is not based
on the provision of particular investment advice, such as purchasing particular securities for clients.
Here is a more detailed description of support services:
Services that Benefit Clients
Schwab’s institutional brokerage services include access to a broad range of investment products,
execution of securities transactions, and custody of client assets. The investment products available
through Schwab include some to which our firm might not otherwise have access or that would
require a significantly higher minimum initial investment by firm clients. Schwab’s services
described in this paragraph generally benefit clients and their accounts.
Services that May Not Directly Benefit Clients
•
Schwab and Altruist also make available other products and services that benefit our firm but may
not directly benefit clients or their accounts. These products and services assist in managing and
administering our client accounts. They include investment research that may be used to service all
or some substantial number of client accounts, including accounts not maintained with the broker-
dealer. In addition to investment research, Schwab also makes available software and other
technology that:
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•
•
•
provides access to client account data (such as duplicate trade confirmations and account
statements);
facilitates trade execution and allocate aggregated trade orders for multiple client accounts;
provides pricing and other market data;
facilitates payment of our fees from our clients’ accounts; and
assists with back-office functions, recordkeeping and client reporting.
Services that Generally Benefit Only Our Firm
Broker-dealers engaged also offers other services intended to help manage and further develop
our business enterprise. These services include:
•
•
•
•
educational conferences and events
technology, compliance, legal, and business consulting;
publications and conferences on practice management and business succession; and
access to employee benefits providers, human capital consultants and insurance providers.
Broker-dealers engaged may provide some of these services themselves. In other cases, broker-
dealers arrange for third-party vendors to provide the services to our firm. Broker-dealers may also
discount or waive fees for some of these services or pay all or a part of a third party’s fees. Broker-
dealers may also provide our firm with other benefits, such as occasional business entertainment for
our personnel.
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MY Wealth Management, Inc.
Irrespective of direct or indirect benefits to our clients, our firm strives to enhance the client
experience, help clients reach their goals and put client interests before that of our firm or associated
persons.
Our Interest in Broker-Dealers’ Services.
The availability of these services from Schwab benefits our firm because our firm does not have to
produce or purchase them. Our firm does not have to pay for these services, and they are not
contingent upon committing any specific amount of business to Schwab in trading commissions or
assets in custody.
In light of our arrangements with Schwab, a conflict of interest exists as our firm may have incentive
to require that clients maintain their accounts with Schwab or Altruist based on our interest in
receiving services that benefit our firm rather than based on client interest in receiving the best value
in custody services and the most favorable execution of transactions. As part of our fiduciary duty to
our clients, our firm will endeavor at all times to put the interests of our clients first. Clients should
be aware, however, that the receipt of economic benefits by our firm or our related persons creates
a potential conflict of interest and may indirectly influence our firm’s choice of Schwab and Altruist as
custodial recommendations. Our firm examined this potential conflict of interest when our firm chose
to recommend Schwab and Altruist and have determined that the recommendation is in the best interest
of our firm’s clients and satisfies our fiduciary obligations, including our duty to seek best execution.
In seeking best execution, the determinative factor is not the lowest possible cost, but whether the
transaction represents the best qualitative execution, taking into consideration the full range of a
broker-dealer’s services, including the value of research provided, execution capability, commission
rates, and responsiveness. Although our firm will seek competitive rates, to the benefit of all clients,
our firm may not necessarily obtain the lowest possible commission rates for specific client account
transactions. Our firm believes that the selection of Schwab and Altruist as custodians and brokers is
the best interest of our clients. It is primarily supported by the scope, quality and price of their
services, and not services that only benefit our firm.
Soft Dollars
Our firm does not receive soft dollars in excess of what is allowed by Section 28(e) of the Securities
Exchange Act of 1934. The safe harbor research products and services obtained by our firm will
generally be used to service all of our clients but not necessarily all at any one particular time.
Client Brokerage Commissions
We do not use client brokerage commissions to obtain research or other products or services. The
aforementioned research and brokerage services are used by our firm to manage accounts for which
we have investment discretion. Without this arrangement, our firm might be compelled to purchase
the same or similar services at our own expense.
Procedures to Direct Client Transactions in Return for Soft Dollars
We do not direct client transactions to a particular broker-dealer in return for soft dollar benefits.
Brokerage for Client Referrals
Our firm does not receive brokerage for client referrals.
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MY Wealth Management, Inc.
Directed Brokerage
Neither we nor any of our firm’s related persons have discretionary authority in making the
determination of the brokers with whom orders for the purchase or sale of securities are placed for
execution, and the commission rates at which such securities transactions are effected. We routinely
request that a client directs us to execute through a specified broker-dealer. Our firm recommends
the use of Schwab or Altruist. Each client will be required to establish their account(s) with Schwab or
Altruist if not already done. Please note that not all advisers have this requirement.
Permissibility of Client-Directed Brokerage
We do not allow client-directed brokerage outside our custodial recommendations.
Special Considerations for ERISA Clients
A retirement or ERISA plan client may direct all or part of portfolio transactions for its account
through a specific broker or dealer in order to obtain goods or services on behalf of the plan. Such
direction is permitted provided that the goods and services provided are reasonable expenses of the
plan incurred in the ordinary course of its business for which it otherwise would be obligated and
empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services
purchased are not for the exclusive benefit of the plan.
Aggregation of Purchase or Sale
We perform investment management services for various clients. There are occasions on which
portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same
security for numerous accounts served by our firm, which involve accounts with similar investment
objectives. Although such concurrent authorizations potentially could be either advantageous or
disadvantageous to any one or more particular accounts, they are effected only when we believe that to
do so will be in the best interest of the aected accounts. When such concurrent authorizations occur,
the objective is to allocate the executions in a manner which is deemed equitable to the accounts
involved. In any given situation, we attempt to allocate trade executions in the most equitable manner
possible, taking into consideration client objectives, current asset allocation and availability of funds
using price averaging, proration and consistently non-arbitrary methods of allocation.
Item 13: Review of Accounts or Financial Plans
We review models regularly for our clients subscribing to our Asset Management service. The nature
of these reviews is to learn whether clients’ accounts are in line with their investment objectives,
appropriately positioned based on market conditions, and investment policies, if applicable. Only our
Financial Advisors or Portfolio Managers will conduct reviews.
Retirement Plan Consulting clients receive reviews of their retirement plans for the duration of the
service. Our firm also provides ongoing services where clients are met with upon their request to
discuss updates to their plans, changes in their circumstances, etc. Retirement Plan Consulting clients
do not receive written or verbal updated reports regarding their plans unless they choose to engage
our firm for ongoing services.
We may review client accounts more frequently than described above. Among the factors which may
trigger an off-cycle review are major market or economic events, the client’s life events, requests by
the client, etc.
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MY Wealth Management, Inc.
We do not provide written reports to clients, unless asked to do so.
Item 14: Client Referrals & Other Compensation
Schwab
(see Item 12 – Brokerage Practices)
Our firm receives economic benefit from Schwab in the form of the support products and services
made available to our firm and other independent investment advisors that have their clients
maintain accounts at Schwab. These products and services, how they benefit our firm, and the related
conflicts of interest are described above
. The availability of
Schwab’s products and services is not based on our firm giving particular investment advice, such as
buying particular securities for our clients.
Altruist
Except for the arrangements outlined in Item 12 of Form ADV Part 2A, our firm has no additional
Referral Fees
arrangements to disclose.
At this time, MY Wealth does not compensate any third parties for referring clients to the Firm nor do
we refer clients to others for compensation.
Item 15: Custody
Deduction of Advisory Fees:
Our firm does not maintain physical custody of client assets. All of our clients receive at least
quarterly account statements directly from their custodians. Upon opening an account with a
qualified custodian on a client's behalf, we may send a letter to the client notifying them of the
qualified custodian's contact information. If we decide to also send account statements to clients,
such notice and account statements include a legend that recommends that the client compare the
account statements received from the qualified custodian with those received from our firm.
We encourage our clients to raise any questions with us about the custody, safety or security of their
assets. The custodians we do business with will send you independent account statements listing
your account balance(s), transaction history and any fee debits or other fees taken out of your
account.
Item 16: Investment Discretion
Our firm typically requires clients to provide our firm with investment discretion on their behalf,
pursuant to an executed investment advisory client agreement. By granting investment discretion,
we are authorized to execute securities transactions, which securities are bought and sold, and the
total amount to be bought and sold. Limitations and reasonable restrictions may be imposed by the
client in the form of specific constraints on any of these areas of discretion with our firm’s written
acknowledgement. Our firm may provide the opportunity to engage on a non-discretionary basis on
a case-by-case basis. Non-discretionary accounts are strictly offered to clients who are unable to
provide our firm with discretionary authority as a result of their employment or relevant laws and
regulations.
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MY Wealth Management, Inc.
Item 17: Voting Client Securities
We do not and will not accept the proxy authority to vote client securities. Clients will receive proxies
or other solicitations directly from their custodian or a transfer agent. In the event that proxies are
sent to our firm, we will forward them on to you and ask the party who sent them to mail them
directly to the client in the future. Clients may call, write or email us to discuss questions they may
have about particular proxy votes or other solicitations using the contact information on the cover
page of this brochure.
Item 18: Financial Information
•
We are not required to provide financial information in this Brochure because:
•
•
•
We do not require the prepayment of more than $1,200 in fees and six or more months in
advance.
We do not take custody of client funds or securities.
We do not have a financial condition or commitment that impairs our ability to meet
contractual and fiduciary obligations to clients.
We have never been the subject of a bankruptcy proceeding.
ADV Part 2A – Firm Brochure
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MY Wealth Management, Inc.