Overview
- Headquarters
- New York, NY
- Total Firm Assets
- $263 million
- Average High-Net-Worth Client Portfolio Size
- $2.3 million
Fee Structure
Primary Fee Schedule (FORM ADV PART 2A)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $500,000 | 0.90% |
| $500,001 | $1,000,000 | 0.80% |
| $1,000,001 | $2,500,000 | 0.70% |
| $2,500,001 | $5,000,000 | 0.60% |
| $5,000,001 | $10,000,000 | 0.50% |
| $10,000,001 | and above | 0.40% |
Minimum Annual Fee: $900
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $8,500 | 0.85% |
| $5 million | $34,000 | 0.68% |
| $10 million | $59,000 | 0.59% |
| $50 million | $219,000 | 0.44% |
| $100 million | $419,000 | 0.42% |
Clients
- High-Net-Worth Share of Firm Assets
- 41.68%
- Number of High-Net-Worth Clients
- 47
- Total Client Accounts
- 1,118
- Discretionary Accounts
- 1,118
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Investment Advisor Selection
Regulatory Filings
- SEC CRD Number
- 337328
Primary Brochure: FORM ADV PART 2A (2026-06-30)
View Document Text
NerdWallet Wealth Partners, LLC
123 William Street
21st Floor
New York, NY 10038
917-275-7821
www.nerdwalletwealthpartners.com
June 30, 2026
Form ADV Part 2A
Firm Brochure
This Brochure provides information about the qualifications and business practices of NerdWallet Wealth
Partners, LLC (“NWWP”). If you have any questions about the contents of this Brochure, please contact us
at 917-275-7821. The information in this Brochure has not been approved or verified by the United States
Securities and Exchange Commission or any state securities authority.
NerdWallet Wealth Partners, LLC is registered as an Investment Adviser with the SEC. Registration of an
Investment Adviser does not imply any level of skill or training.
Additional information about NWWP is available on the SEC’s website at www.adviserinfo.sec.gov, which
can be found using the Firm’s CRD# 337328.
Item 2: Material Changes
Form ADV Part 2 requires registered investment advisers to amend their brochure and notify clients of any
material changes. Because our initial SEC registration became effective on June 13, 2025, this filing
represents our first Annual Updating Amendment. Since the filing of our initial Form ADV Part 2
brochure, we have made the following material changes:
● Discretionary Investment Management. We clarified that the firm provides investment
management services on a discretionary basis. The updated disclosure explains that Clients authorize
us to make investment decisions on their behalf, including the authority to trade securities, rebalance
portfolios, and implement investment strategies without obtaining prior approval for each
transaction. The scope of our discretionary authority remains subject to the Client agreement and any
reasonable investment restrictions imposed by the Client.
● Use of Third-Party Advisers. We disclosed that, as part of our discretionary investment
management services, the firm may engage third-party investment advisers, to manage all or a
portion of Client assets. We further disclose that the firm currently engages third-party advisers to
implement an ESG model portfolio strategy and an options-based borrowing strategy that utilizes
synthetic loan contract economics. We confirmed that the firm retains responsibility for determining
the suitability of any sub-advised strategy for a Client and for providing ongoing monitoring and
supervision of both the Client’s account and the sub-adviser. See Item 4 for additional information.
● Fee Treatment for Third-Party Adviser Managed Assets. We clarified that fees charged by third-
party advisers are separate from, and in addition to, the advisory fees charged by us. We also
disclosed that assets managed by a third-party adviser are included when calculating our advisory
fee in accordance with the fee schedule described in the Investment Management Services section of
this brochure. We confirmed that the use of a third-party adviser does not increase the firm’s advisory
fee rate, that Clients compensate third-party advisers directly, and that the firm does not receive
compensation, directly or indirectly, from any third-party adviser. See Item 5 for additional
information.
● Fee Schedule Update. We have updated the fee schedule for our Investment Management Services.
Specifically, we introduced an annual flat fee of $900 for accounts with assets under $100,000, billed
quarterly in arrears.
We also revised the asset range associated with the first tier of our assets-under-management fee
schedule. The 0.90% annual advisory fee, which previously applied to accounts below $500,000,
now applies to accounts with assets between $100,000 and $500,000. The advisory fee rate for this
tier has not changed. All other asset tiers and corresponding advisory fees remain unchanged.
In addition, the Investment Management Services section was updated to clarify how billing for
assets-under-management fees is calculated. Specifically, we clarified that advisory fees are
calculated based on the market value of assets under management as of the last day of the applicable
quarter, using the applicable annualized fee rate prorated based on the actual number of days in the
quarter to determine the quarterly advisory fee. For additional information on advisory fees, refer to
Item 5.
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These changes do not modify the fee arrangements of existing clients. Each client’s Investment
Management Agreement continues to govern the applicable advisory fees.
● Strategy-Specific Risks. We added separate, strategy-specific risk disclosures in Item 8, including
one addressing risks associated with ESG model strategies and another addressing risks associated
with options-based and derivatives strategies. See Item 8 for more information.
● Client Referrals. We updated our referral arrangements to disclose that we now maintain referral
relationships with both affiliated and unaffiliated promoters, who are compensated based on lead-
generation activities. Prospective clients are under no obligation to engage NWWP for advisory
services. See Item 14 for additional information.
● IRA Rollover Recommendations. We updated Item 4 of our brochure to incorporate our IRA
Rollover Fiduciary Acknowledgment. This means that when we provide you with investment advice
about whether to roll over retirement plan assets, we act as a fiduciary under the Employee
Retirement Income Security Act (ERISA). We also updated Item 5 to include IRA Rollover
considerations, which explain the other available options and disclose the conflicts of interest
associated with these recommendations. For more information regarding IRA rollovers, please refer
to Items 4 and 5 of our Brochure.
● Brokerage Practices Update. We updated Item 12 for clarity to better describe our custodial
arrangements, the services provided by recommended broker-dealers, and related conflicts of
interest. See Item 12 for more information.
● Account Reviews. We updated Item 13 to clarify that client accounts are monitored on an ongoing
basis and reviewed at least annually to help ensure that investments and asset allocations remain
aligned with clients’ goals and objectives.
● Client Referrals and Other Compensation Disclosure Update. We updated Item 14 for clarity to
better describe the economic benefits we receive from recommended broker-dealers and custodians
and the related conflicts of interest. See Item 14 for more information.
● Discontinued Service. We have discontinued our standalone financial planning service.
Accordingly, we have removed this service and all related references to it, including references to
the third-party provider that previously assisted in preparing those standalone financial plans. We
continue to offer comprehensive financial planning as part of our Investment Management Services.
Since our last Form ADV Part 2 brochure filing dated April 1, 2026, we made the following material
changes:
● Alternative Investments. We updated the brochure to clarify that the firm may recommend certain
alternative investments, including private funds sponsored or managed by third parties. We also
added additional disclosure regarding the associated fees and risks of such investments. For more
information, please see Item 4 (Advisory Business), Item 5 (Fees and Compensation), and Item 8
(Methods of Analysis, Investment Strategies and Risk of Loss).
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● Other Financial Industry Activities and Affiliations. We updated Item 10 to clarify that
NerdWallet or its affiliates earn referral fees, lead generation fees, advertising revenue, or other
compensation when Clients referred or directed by NWWP transact on affiliated websites. This
creates a conflict of interest because NWWP has an incentive to direct Clients to NerdWallet-
affiliated resources over third-party alternatives. Clients are under no obligation to use the services
of NerdWallet or any of its affiliates. See Items 10 and 12 for more information.
● Brokerage Practice & Economic Benefits. We updated Items 12 and 14 to clarify that certain
products and services made available by Broker/Custodians benefit NWWP by supporting its
operations, technology, compliance, and administrative functions, which creates a conflict of interest
because it provides an incentive to recommend Broker/Custodians based on benefits received by the
firm rather than solely on services available to clients. However, these products and services or
“economic benefits” are not considered to be part of a soft dollar arrangement. NWWP does not
participate in any soft dollar arrangements. Refer to Items 12 and 14 for more information.
● Brokerage Practices & Wrap Fee Programs. We updated the disclosure regarding wrap fee
arrangements to clarify that, while NWWP does not maintain a wrap fee program, in certain
circumstances it recommends third-party advisers that participate in wrap fee programs, which
results in certain clients paying different prices for the same or similar securities transactions than
clients who do not participate in wrap fee arrangements. See Item 12 for more information.
● Client Referrals and Other Compensation. Clarified that NerdWallet and its affiliates market
NWWP’s services through affiliated websites, creating a conflict of interest because NerdWallet has
a financial incentive to grow NWWP’s business. Clients are under no obligation to engage NWWP
for advisory services. See Item 12 for more information.
● Artificial Intelligence. We updated the disclosure to describe the Firm's use of approved AI
technologies to support certain operational and client service functions, as well as the controls and
human oversight the Firm maintains over the use of AI. See Item 8 for more information.
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Item 3: Table of Contents
Item 2: Material Changes
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Item 3: Table of Contents
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Item 4: Advisory Business
6
Item 5: Fees and Compensation
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Item 6: Performance-Based Fees and Side-By- Side Management
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Item 7: Types of Clients
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Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
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Item 10: Other Financial Industry Activities and Affiliations
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Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
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Item 12: Brokerage Practices
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Item 13: Review of Accounts
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Item 14: Client Referrals and Other Compensation
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Item 15: Custody
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Item 16: Investment Discretion
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Item 17: Voting Client Securities
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Item 18: Financial Information
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Item 4: Advisory Business
Description of Advisory Firm
NerdWallet Wealth Partners, LLC (“NWWP”, “Firm” or “Adviser”) is an SEC-registered investment adviser
formed in May 2025 and is the successor to the business of Future You Wealth, LLC, which was founded
in 2019 and acquired by NWWP on June 13, 2025. NWWP is a subsidiary of NerdWallet, Inc.
(“NerdWallet”). As of December 31, 2025, NWWP had $262,843,327 in discretionary assets under
management and no non-discretionary assets under management.
Types of Advisory Services
Investment Management Services
We are in the business of managing individually tailored investment portfolios, including the selection of
investment strategies and asset allocations designed to reflect each Client’s financial circumstances and
objectives. We provide investment management services on a discretionary basis, meaning Clients authorize
us to make investment decisions such as buying or selling securities, rebalancing, and implementing
investment strategies without obtaining prior approval for each transaction. The scope of our discretionary
authority is defined in the Client agreement and may be subject to reasonable restrictions the Client imposes.
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 circumstances are established, we develop a Client's personal investment policy or an investment
plan with an asset allocation target, and we create and manage a portfolio based on that policy and those
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 tax considerations. Clients may impose reasonable
restrictions on investing in certain securities, types of securities, or industry sectors. Fees pertaining to this
service are outlined in Item 5 of this brochure.
As part of our discretionary investment management services, we may engage third-party investment
advisers, referred to as sub-advisers, to manage all or a portion of a Client’s portfolio on a discretionary
basis pursuant to a defined investment strategy. For additional information regarding our selection and
monitoring of sub-advisers, please refer to the section titled Selection of Other Advisers.
As part of our investment management services, we offer comprehensive financial planning. This involves
working one-on-one with a planner over an extended period of time and is included as a part of our
investment management services at no additional cost.
Clients will be taken through establishing their goals and values around money. They will be required to
provide information to help complete the following areas of analysis: net worth, cash flow, employee benefit,
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
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changes to their current situation will be reviewed with the Client. Clients will receive a written or an
electronic report, providing the Client with a detailed financial plan designed to achieve his or her stated
financial goals and objectives. If a follow-up meeting is required, we will meet at the Client's convenience.
The plan and the Client's financial situation and goals will be monitored throughout the year and follow-up
phone calls and emails will be made to the Client to confirm that any agreed upon action steps have been
carried out. On an annual basis, there will be a full review of this plan to ensure its accuracy and ongoing
appropriateness. Any needed updates will be implemented at that time.
The Client and adviser will work together to select specific areas to cover. These areas may include, but are
not limited to, the following:
● 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
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 money market funds) for such reserves, plus strategies to save desired amounts.
● 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
grandchildren (if appropriate).
● 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.
● 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 during your
retirement years.
● 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
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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”).
Client Tailored Services and Client Imposed Restrictions
We offer the same suite of services to all investment management Clients. However, specific Client financial
plans and their implementation are dependent upon the Client Investment Policy Statement which outlines
each Client’s current situation and is used to construct a Client specific plan to aid in the selection of a
portfolio that matches restrictions, needs, and targets.
Selection of Other Advisers
We may recommend or select third-party investment advisers, (“third-party advisers”)to manage all or a
portion of a Client’s portfolio. We currently engage third-party advisers for the implementation of (1) a
specialized ESG model portfolio strategy, and (2) an options-based borrowing strategy that structures option
positions to reflect synthetic loan contract economics. These strategies require specialized research, data
sourcing, or options execution infrastructure that the third-party adviser provides.
The firm currently engages Ethic, Inc. for the implementation of its ESG model portfolio strategy and
SyntheticFi for the implementation of its options-based borrowing strategy.
When we select a third-party adviser for a Client, we remain responsible for determining whether the strategy
is appropriate for the Client based on the Client’s financial goals, risk tolerance, time horizon, and any
reasonable restrictions. We also retain responsibility for the ongoing monitoring and supervision of both the
Client’s account and the third-party adviser. This includes reviewing the third-party adviser’s performance,
assessing the continued suitability of the strategy for the Client, and confirming that the third-party adviser
is managing the Client’s assets in accordance with the selected mandate.
Certain third-party advised strategies are implemented on a discretionary, model-driven basis. Once a
Client’s account is allocated to a particular investment strategy managed by a third-party adviser, the third-
party adviser is responsible for implementing and periodically rebalancing the portfolio or positions in
accordance with the applicable strategy parameters, without considering the individual investment
objectives, risk tolerance, liquidity needs, or tax circumstances of each Client account. With respect to
options-based borrowing strategies, the third-party adviser exercises discretionary authority over the
selection, execution, and management of option positions once a Client’s account is allocated to the strategy.
The firm remains responsible for determining the initial and ongoing suitability of each strategy for the
Client.
We continue to serve as the Client’s primary adviser and main point of contact. All financial planning,
portfolio oversight, and advisory communications are conducted through our firm.
In addition to the strategies discussed above, the firm may recommend certain alternative investments or
private funds sponsored or managed by third parties, as further described in Items 5 and 8 of this brochure.
Additional information about the material risks associated with ESG investing, options-based strategies, and
alternative investments is provided in Item 8 of this brochure.
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IRA Rollover Fiduciary Acknowledgment
As part of our investment advisory services, we may recommend that you roll over assets from an employer-
sponsored retirement plan (such as a 401(k) plan) into an Individual Retirement Account (“IRA”) that we
manage. Under applicable federal law, such a recommendation may be interpreted as a conflict of interest
because the rollover would increase the amount of assets that we manage and, in turn, increase our advisory
fees.
However, when we provide you with investment advice about whether to roll over retirement plan assets,
we act as a fiduciary under the Employee Retirement Income Security Act (ERISA). As a fiduciary, we
address any conflicts of interest in giving rollover recommendations by following the requirements of the
U.S. Department of Labor’s Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”), which means we
must:
● Provide investment advice that meets a professional standard of prudence and care;
● Act in your best interest and never put our financial interests ahead of yours;
● Avoid misleading statements about conflicts of interest, fees, and investments;
● Follow policies and procedures designed to ensure we give investment advice that is in your best
interest;
● Receive not more than reasonable fees for our services;
● Give you clear information about material conflicts of interest; and
● Maintain rollover procedures subject to an annual review.
We will only recommend a rollover when we believe, based on your individual circumstances, that it is in
your best interest. You are under no obligation to act on our advice.
Item 5: Fees and Compensation
We charge either a flat fee or an asset-under-management fee depending on your account size. The following
describes the fees and compensation associated with our Investment Management Services.
Investment Management Services
Flat Fee
Our standard Adviser flat fee is calculated as follows:
Account Value
Annual Advisory Fee
Below $100,000
$900
Our flat fees are billed quarterly in arrears and are generally deducted directly from the Client’s custodial
account pursuant to the Client’s authorization.
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Assets Under Management Fee
Our standard Adviser assets under management fee is based on the market value of the assets under
management and is calculated as follows:
Account Value
Annual Advisory Fee
$100,000 - $499,999
0.90%
$500,000 - $999,999
0.80%
$1,000,000 - $2,499,999
0.70%
$2,500,000 - $4,999,999
0.60%
$5,000,000 - $9,999,999
0.50%
$10,000,000 and Above
0.40%
The annual advisory fee is negotiable and paid quarterly in arrears. For assets under management fees, the
advisory fee is calculated based on the market value of assets under management as of the last day of the
applicable quarter. The applicable annualized fee rate is prorated based on the actual number of days in the
quarter to determine the quarterly advisory fee.
Please note that if a Client does not receive the Firm’s Disclosure Brochure at least 48 hours prior to signing
the investment advisory agreement, the agreement may be terminated by the Client within five (5) business
days of signing the agreement without incurring advisory fees.
NWWP retains the discretion to negotiate, reduce, or waive fees on a client-by-client basis, which may result
in fees that differ from the standard fee schedules described above. In addition, NWWP may combine the
account values of family members living in the same household for purposes of determining the applicable
advisory fee. For example, NWWP may combine account values for spouses, minor children, joint accounts,
and other related accounts. Combining account values may increase the total assets eligible for breakpoint
pricing, which could result in a lower overall advisory fee.
Advisory fees are directly debited from Client accounts. Accounts initiated or terminated during a calendar
quarter will be charged a pro-rated fee based on the amount of time remaining in the billing period. An
account may be terminated with written notice at least 30 calendar days in advance. Since fees are paid in
arrears, no refund will be needed upon termination of the account.
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.
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Item 12 further describes the factors that we consider in selecting or recommending broker-dealers for
Client’s transactions and determining the reasonableness of their compensation (e.g., commissions).
We 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.
Selection of Other Advisers
Clients who utilize a strategy managed by a third-party adviser will pay the third-party adviser’s fee in
addition to the advisory fee charged by our firm. third-party adviser fees are separate from, and in addition
to, our advisory fees and may be billed directly by the third-party adviser or deducted from the Client’s
custodial account.
Assets managed by a third-party adviser are included in the calculation of our advisory fee. Our advisory
fee is determined according to the fee schedule described in the Investment Management Services section of
this brochure. As a result, Clients who participate in a strategy managed by a third-party adviser will pay
both our advisory fee and the third-party adviser’s fee.
In addition to our advisory fee and any third-party adviser fees, Clients may incur charges from custodians,
broker-dealers, mutual funds, exchange-traded funds, and other third-party service providers. These fees are
not included in our advisory fee and are paid by the Client. We do not receive any portion of the fees charged
by third-party advisers or other third-party providers.
Third-party advisers are selected based solely on the best interests of the Client, and Clients will receive all
required disclosure documents for any third-party adviser that manages assets in their account.
Third-party adviser fees may vary based on the specific investment strategy selected and related strategy
features. For certain options-based strategies, third-party adviser fees may be calculated based on the
notional size of option positions or synthetic loan exposure rather than the value of assets invested, and such
fees may be charged on a periodic basis. Clients should refer to the applicable third-party adviser’s Form
ADV Part 2A and the Client’s advisory agreement for additional information regarding specific fee
arrangements, calculation methodologies, and billing practices.
IRA Rollover Considerations
As part of our investment advisory services, we may recommend that you move assets from your employer’s
retirement plan to an Individual Retirement Account (“IRA”) that we manage. If you choose to roll over
assets to an IRA that we manage, we will charge an ongoing, asset-based advisory fee as described in your
advisory agreement. You are under no obligation to roll over your plan assets, and if you do, you are not
required to have them managed by us.
Under ERISA, our rollover recommendation may be considered a conflict of interest because the rollover
would increase the amount of assets that we manage and, in turn, increase our advisory fees. To satisfy our
ERISA fiduciary obligations and avoid a conflict of interest, we follow the requirements of PTE 2020-02.
When deciding whether to roll over your retirement plan assets, you should carefully consider the following
options that may be available to you:
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1. Leave the assets in your current employer’s plan (if permitted).
2. Roll the assets over to a new employer’s plan (if you change jobs and a plan is available).
3. Take a cash distribution (which may result in taxes and penalties).
4. Roll the assets over into an IRA (with our firm or another financial institution).
Each option has advantages and disadvantages which we can help you evaluate. In choosing an option, you
might consider such factors as the fees and expenses associated with your employer’s retirement plan
compared to those of a new employer plan or IRA; the investment choices available under a new plan or
IRA; any services available under your employer’s plan compared to a new employer plan or IRA; available
distribution and withdrawal features; the creditor protections of an employer-provided retirement plan versus
an IRA; the tax treatment of a rollover or distribution; the effect of a rollover on required minimum
distributions; and other factors that may apply to you. We encourage you to review these factors carefully
and consult with your tax advisor or attorney before making a decision.
Item 6: Performance-Based Fees and Side-By- Side Management
We do not receive performance-based fees and do not engage in side-by-side management.
Item 7: Types of Clients
We provide advisory services to individuals, high net-worth individuals and charitable organizations.
While we do not have a minimum account size for Investment Management services, we do impose a
minimum annual fee of $900 for accounts with assets under $100,000, billed quarterly in arrears.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Our primary method of investment analysis is fundamental analysis.
Fundamental analysis
Fundamental analysis involves analyzing individual companies and their industry groups, such as a
company’s financial statements, details regarding the company’s product line, the experience, and expertise
of the company’s management, and the outlook for the company’s industry. The resulting data is used to
measure the true value of the company’s stock compared to the current market value. The risk of fundamental
analysis is that the 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.
Passive Investment Management
We primarily practice passive investment management. Passive investing involves building portfolios that
are comprised of various distinct asset classes. The asset classes are weighted in a manner to achieve the
desired relationship between correlation, risk, and return. Funds that passively capture the returns of the
desired asset classes are placed in the portfolio. The funds that are used to build passive portfolios are
typically index mutual funds or exchange-traded funds.
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Passive investment management is characterized by low portfolio expenses (i.e. the funds inside the portfolio
have low internal costs), minimal trading costs (due to infrequent trading activity), and relative tax efficiency
(because the funds inside the portfolio are tax efficient and turnover inside the portfolio is minimal).
In contrast, active management involves a single manager or managers who employ some method, strategy
or technique to construct a portfolio that is intended to generate returns that are greater than the broader
market or a designated benchmark.
Alternative Investments
In certain circumstances, we may recommend alternative investments, including privately offered
investment vehicles, private funds, and private credit investments sponsored or managed by third-party
advisers or investment sponsors, to qualifying clients. These investments are generally available only to
clients who meet applicable eligibility and suitability requirements, including accredited investor standards
where applicable.
Alternative investments are typically less liquid, more complex, and subject to different risks than traditional
publicly traded investments. Clients should carefully review all offering documents and related disclosures
associated with any alternative investment recommendation.
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 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.
● ESG Risk: Investing in Environmental, Social, and Governance (“ESG”) model strategies relies on
third-party ESG research, data, and scoring methodologies provided by external providers. ESG
screening may limit the number and type of investments available for selection, which can increase
concentration risk and may result in portfolios that are less diversified than broad market portfolios.
ESG scores and classifications reflect subjective judgments and can vary across providers for the
same issuer, which introduces model-interpretation risk.
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ESG data sets and sustainability metrics may evolve over time, and changes to underlying data,
scoring methodologies, or sustainability frameworks may occur after investment decisions are
implemented. ESG screening does not remove the risk of loss, including the risk of permanent loss
of capital. Portfolios constructed using ESG models may perform differently than portfolios without
ESG screening due to differences in investment selection, exclusions, sector exposure, and market
conditions.
Additional ESG-related risks are described in the disclosure documents of any engaged sub-adviser,
including the sub-adviser’s Form ADV Part 2A, which will be provided to Clients prior to or at the
time assets are allocated. Clients are encouraged to review these disclosures carefully.
● ESG Model Implementation Risk: Certain ESG model strategies offered through the firm are
implemented by third-party sub-advisers that apply proprietary sustainability models and data
frameworks. For example, the firm engages a sub-adviser to implement an ESG model strategy that
incorporates sustainability priorities such as climate-related considerations, human rights factors, and
corporate leadership and management characteristics.
These sustainability priorities may be reflected in Client portfolios through exclusionary screens,
inclusionary criteria, factor tilts, or a combination of such approaches. Once a Client’s account is
allocated to an ESG model strategy, sustainability criteria are applied uniformly across all accounts
allocated to that strategy and are not customized at the individual security-selection level for each
Client.
From time to time, including at portfolio rebalancing, the sub-adviser may adjust sustainability
settings or implementation parameters due to updates in underlying data, changes to model
methodologies, or efforts to maintain portfolio construction constraints such as estimated tracking
error targets. As a result, portfolio holdings, sector exposure, and other characteristics may change
over time, and ESG model portfolios may perform differently than non-ESG portfolios or
benchmarks.
● Sub-Adviser Tax Strategy Risk: Certain sub-advised strategies may include tax-loss harvesting or
tax-transition features implemented at the account level. These tax management techniques are
applied solely to the assets managed by the sub-adviser and do not take into account a Client’s other
accounts, holdings, or overall tax situation. Sub-advisers do not provide tax advice, and Clients are
encouraged to consult with a qualified tax professional regarding the tax implications of any
investment strategy.
● Options-Based Borrowing Strategy Risk: Certain investment strategies offered through the firm
are designed to provide liquidity or financing exposure by structuring option positions intended to
reflect the economic characteristics of a loan (commonly referred to as a “synthetic loan” or “box
strategy”). These strategies do not involve the Client entering into a traditional loan arrangement and
do not provide the legal rights, protections, or obligations associated with conventional borrowing.
Options-based borrowing strategies involve the use of exchange-traded or over-the-counter
derivatives and expose Clients to risks associated with options trading, including leverage, margin
requirements, counterparty risk, liquidity risk, valuation risk, execution risk, interest-rate sensitivity,
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and regulatory risk. Due to the use of derivatives and leverage, losses associated with these strategies
may exceed the amount of capital initially allocated to the strategy.
The structure, availability, and effectiveness of options-based borrowing strategies may be impacted
by market liquidity, changes in interest rates or volatility, broker-dealer or exchange rules, margin
requirements, and regulatory developments. There can be no assurance that such strategies will
achieve their intended economic outcome or that they will be more cost-effective or efficient than
traditional borrowing alternatives.
● Options Strategy Implementation and Monitoring Risk: Options-based strategies are
implemented and managed by third-party sub-advisers in accordance with predefined strategy
parameters. Once a Client’s account is allocated to such a strategy, option positions are established
and adjusted at the strategy level and are not customized to reflect the individual investment
objectives, tax circumstances, or liquidity needs of each Client account. The firm remains responsible
for evaluating the appropriateness of the strategy for each Client and for monitoring the ongoing
suitability of the strategy over time.
Sub-advisers engaged by the firm do not provide legal or tax advice in connection with options-
based strategies. Clients are encouraged to consult their own legal and tax advisors regarding the
implications of participating in such strategies.
● Alternative Investment and Private Credit Risk: Certain alternative investments, including
private funds and private credit investments, involve a high degree of risk and may be speculative.
These investments are generally illiquid, are not publicly traded, and may be subject to limited
transparency, valuation uncertainty, leverage, concentration risk, counterparty risk, default risk, and
reduced regulatory oversight. Private credit investments are subject to risks associated with borrower
defaults, declining collateral values, changes in interest rates, economic downturns, and limited
secondary market liquidity. Investors in alternative investments may experience substantial or
complete loss of invested capital and may be unable to redeem or transfer their interests for extended
periods of time.
Risks Associated with Securities
Apart from the general risks outlined above which apply to all types of investments, specific securities
may have other risks.
● 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.
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● 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 rate risk, reinvestment risk, inflation risk, market risk, call or
redemption risk, credit risk, and liquidity and valuation 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
or below their net asset value; (ii) trading of an ETF’s shares may be halted if the listing exchange’s
officials deem such action appropriate, the shares are de-listed 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.
● Investment Companies Risk. 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).
Artificial Intelligence
NWWP utilizes certain artificial intelligence ("AI") technologies to support operational, administrative, and
client service functions. The Firm uses AI-powered tools to assist with meeting transcription, note taking,
meeting summarization, research assistance, document drafting, and other administrative efficiencies.
As part of these services, information discussed during client meetings is processed by approved third-party
technology providers to generate meeting notes, summaries, action items, and related work product. AI tools
assist Firm personnel in organizing information and generating preliminary content; however, AI is not used
to independently provide investment advice, exercise investment discretion, determine investment strategies,
or make final investment decisions regarding client accounts. All investment recommendations, portfolio
management decisions, and client communications remain subject to review and oversight by NWWP
personnel.
The Firm recognizes that AI-generated outputs can contain inaccuracies, omissions, or other errors.
Accordingly, Firm personnel review AI-generated work product before relying on it in connection with
advisory services.
NWWP maintains policies, procedures, and controls designed to govern the use of AI technologies and
address information security, confidentiality, vendor oversight, and regulatory compliance considerations.
The Firm limits the use of AI tools to approved platforms and implements safeguards designed to protect
client information. NWWP conducts due diligence on AI service providers and seeks to utilize providers
that maintain contractual and technical controls designed to protect confidential information and limit the
use of client data for AI model training.
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Item 9: Disciplinary Information
NWWP and its management have not been involved in legal or disciplinary events that are material to a
Client’s or prospective Client’s evaluation of NWWP or the integrity of its management.
Item 10: Other Financial Industry Activities and Affiliations
No NWWP employee is registered, or has an application pending to register, as a broker-dealer or a
registered representative of a broker-dealer.
No NWWP employee is registered, or has an application pending to register, as a futures commission
merchant, commodity pool operator or a commodity trading adviser.
Affiliated Entities
NWWP is an indirect subsidiary of NerdWallet, Inc. which operates platforms that deliver guidance through
educational content, tools and calculators, and product marketplaces so that consumers and small to medium
sized businesses may learn about, compare, and shop for financial products online. NerdWallet or an affiliate
earns referral fees, lead generation fees, advertising revenue, or other compensation, if Clients we direct to
NerdWallet or a NerdWallet affiliate for education or information or other resources transacts with the
service providers on NerdWallet’s or such NerdWallet affiliate’s website. NerdWallet and its affiliates also
market NWWP services to their users on the NerdWallet or NerdWallet affiliate websites to generate
additional Clients for our services. This creates a conflict of interest, because our relationship with
NerdWallet and its affiliates influences our decision to direct clients to NerdWallet's editorial content over
third-party options, which benefits NerdWallet.
NWWP is also under common control with NerdWallet Advisory LLC doing business as NerdWallet
Advisors (“NerdWallet Advisory”), an SEC registered investment adviser and wholly-owned subsidiary of
NerdWallet. NerdWallet Advisory operates an online platform called “Advisors Match,” which uses an
algorithm to provide automated investment advisory services to users (“Users”) by referring or “matching”
them with registered investment advisers or other matching services.
Daniel Ryan Sterling, CEO of NWWP, receives compensation from the sale of his book, You’re Making
Other People Rich. The book is marketed at www.ryansterling.com. NWWP’s advisory clients may
purchase a copy of Mr. Sterling’s book on the internet.
James Timothy Bashall is a licensed accountant but does not provide accounting advice when advising
NWWP clients. Clients are in no way required to utilize the services of any representative of NWWP in their
capacity as an accountant.
Recommendations or Selections of Other Investment Advisers
We may recommend or select third-party investment advisers to manage all or a portion of a Client’s
portfolio. These third-party advisers serve as sub-advisers to our firm and are not affiliated with us.
Additional information regarding our use of sub-advisers, including our role in selecting and monitoring
them, is provided in Item 4 of this brochure. Information regarding fees associated with sub-advised
strategies is provided in Item 5, and material risks associated with such strategies are described in Item 8.
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Item 11: Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
As a fiduciary, our firm and its associates have 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 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. Additionally,
NWWP requires adherence to its Insider Trading Policy, and the CFA Institute's Asset Manager Code of
Professional Conduct and Code of Ethics and Standards of Professional Conduct.
Code of Ethics Description
This code does not attempt to identify all possible conflicts of interest, and literal compliance with each of
its specific provisions will not shield associated persons from liability for personal trading or other conduct
that violates a fiduciary duty to advisory Clients. A summary of the Code of Ethics' Principles is outlined
below.
●
Integrity - Associated persons shall offer and provide professional services with integrity.
● Objectivity - Associated persons shall be objective in providing professional services to Clients.
● Competence - Associated 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 - Associated 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 - Associated 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 - Associated persons' conduct in all matters shall reflect the credit of the profession.
● Diligence - Associated persons shall act diligently in providing professional services.
We periodically review and amend our Code of Ethics to ensure that it remains current. 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 associates 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, etc.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest
Our firm and its “related persons” may buy or sell securities similar to, or different from, those we
recommend to Clients for their accounts. To reduce or eliminate certain conflicts of interest involving the
Firm or personal trading, our policy may require that we restrict or prohibit associates’ transactions in
specific reportable securities transactions. Any exceptions or trading pre-clearance must be approved by the
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firm principal in advance of the transaction in an account, and we maintain the required personal securities
transaction records per regulation.
Trading Securities At/Around the Same Time as Client’s Securities
From time to time, our firm or its “related persons” may buy or sell securities for themselves at or around
the same time as Clients. We will not trade non-mutual fund securities 5 days prior to the same security for
Clients.
Item 12: Brokerage Practices
Custodian and Broker Selection
NerdWallet Wealth Partners LLC (“NWWP”) does not serve as your broker or maintain custody of your
assets that we manage. Client assets must be maintained with a “qualified custodian,” generally a broker-
dealer or bank. In certain instances, we recommend, but do not require that clients use the brokerage and
custodial services of Charles Schwab & Co., Inc. (“Schwab”) or Apex Clearing Corporation (“Apex”) (each
referred to herein as “Broker/Custodian”), each a registered broker-dealer and member SIPC.
While we may recommend that clients use Schwab or Apex as Broker/Custodian, clients ultimately decide
whether to do so and open accounts directly with the Broker/Custodian by entering into account agreements
with them.
Conflicts of interest associated with this arrangement are described below and in Item 14 (Client Referrals
and Other Compensation). Clients should consider these conflicts when selecting a Broker/Custodian
because the services available through a particular custodian may differ from those available through other
custodians.
How We Select Brokers/Custodians
When recommending a broker-dealer or custodian, we seek to select firms that we believe provide high-
quality custodial and execution services at competitive pricing. In evaluating Broker/Custodians, we
consider several factors, including:
● ability to execute securities transactions
● access to investment products
● quality and reliability of custodial and trading services
● ability to facilitate transfers, wires, and other account services
● availability of technology, trading platforms, and operational tools
● pricing, commissions, and transaction costs
● reputation, financial strength, and stability
● service responsiveness and support
In considering these factors, we seek to determine whether the Broker/Custodian can provide overall services
and execution capabilities that are consistent with our duty to seek best execution for client transactions.
Brokerage and Trading Costs
Broker/Custodians generally do not charge separate custody fees but are compensated by charging
commissions, markups or markdowns, transaction fees, or other charges on trades executed in client
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accounts. In some cases, Broker/Custodians may offer commission-free trading for certain securities, such
as many U.S. exchange-listed equities and exchange-traded funds. Broker/Custodians may also earn revenue
through other means, including interest earned on uninvested cash balances or payment for order flow.
Clients should understand that transaction costs and other charges vary depending on the Broker/Custodian
used.
Products and Services Available to Us from Broker/Custodians
Broker/Custodians make available to us certain products and services that assist us in managing and
administering client accounts. These services may include:
trading and portfolio management technology
● custody of client assets
● execution of securities transactions
● access to investment products
●
● market data and pricing services
● account access systems and reporting tools
● software and technology that facilitate trading, account administration, and client reporting
systems that allow us to bill advisory fees directly from client accounts
These services generally benefit clients by facilitating the efficient management and administration of their
accounts. Certain products and services available from Broker/Custodians also benefit our firm by
supporting our operations, technology, compliance, and administrative functions, which creates a conflict of
interest as described below.
Broker/Custodians also make available certain services that benefit our firm but may not directly benefit
client accounts. These services typically include technology support, practice management resources,
educational conferences or events, and other business support services. In some cases, Broker/Custodians
provide these services directly or arrange for third-party vendors to provide them to us, sometimes at a
discounted cost or without charge.
The availability of these services creates a conflict of interest because it provides an incentive for us to
recommend a Broker/Custodian based on the benefits received by our firm rather than solely on the services
available to clients.
We seek to manage this conflict by recommending Broker/Custodians based primarily on the scope, quality,
and competitiveness of their custodial and execution services.
These products and services are not considered soft dollars. NWWP does not participate in soft dollar
arrangements.
Trade Execution
We do not aggregate client trades. In most cases, trades are executed through the Broker/Custodian where
client accounts are maintained.
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While we do not maintain a wrap fee program, in certain circumstances we recommend that clients engage
a third-party sub-adviser that participates in a wrap fee program, which results in certain clients paying
different prices for the same or similar securities transactions than clients who do not participate in wrap fee
arrangements.
Item 13: Review of Accounts
As part of our Investment Management Services, Client accounts are monitored on an ongoing basis by the
assigned investment adviser representative responsible for the Client relationship. In addition, annual
account reviews are conducted by Ryan Sterling, Chief Executive Officer, and James Bashall, Chief
Operating Officer, to help ensure Client investments and allocations remain aligned with the Client’s goals
and objectives. 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.
Clients will receive trade confirmations from the broker(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.
NWWP will not provide written reports to investment advisory Clients.
Item 14: Client Referrals and Other Compensation
NWWP compensates certain third parties, including affiliates and unaffiliated entities (collectively,
“Promoters”), in connection with marketing, referral, or lead-generation arrangements. Under these
arrangements, NWWP pays fees based on the referral of prospective client leads.
Promoters are compensated for introducing NWWP to potential clients and not based on whether an
individual ultimately enters into an advisory relationship with NWWP. Compensation is determined using
objective criteria, such as the provision of contact information or whether a prospective client meets certain
asset thresholds, and may vary based on asset level or applicable pricing tiers.
These Promoter arrangements create a conflict of interest because the Promoters have a financial incentive
to recommend NWWP over other advisers. NWWP addresses this conflict by evaluating referred Clients
based on the same suitability and onboarding standards applied to all prospective Clients. Prospective Clients
are under no obligation to engage NWWP for advisory services.
As discussed in Item 10, Other Financial Industry Activities and Affiliations, NWWP refers or directs Clients
to content or marketplaces hosted by its parent company, NerdWallet, Inc. (“NerdWallet”), or its affiliates,
which maintains content, tools, or marketplaces related to financial products and services. NerdWallet and
its affiliates earn referral fees, lead generation fees, advertising revenue, or other compensation if a Client
referred or directed by NWWP transacts on their websites.
While NWWP does not receive a direct fee or other compensation in connection with such referrals, these
arrangements nevertheless create a conflict of interest because NWWP has an incentive to direct Clients to
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NerdWallet’s or its affiliates’ resources over third-party alternatives to benefit NerdWallet and its affiliates.
Clients are under no obligation to use the services of NerdWallet or any of its affiliates.
NerdWallet and its affiliates also market NWWP’s services through NerdWallet and affiliate websites to
generate additional Clients for NWWP. This creates an additional conflict of interest because NerdWallet,
as the parent company of NWWP, has a financial incentive to grow NWWP’s business. Clients are under no
obligation to engage NWWP for advisory services.
Economic Benefits from Broker/Custodians
We receive an economic benefit from the broker-dealers and custodians we recommend, including Charles
Schwab & Co., Inc. (“Schwab”) and Apex Clearing Corporation (“Apex”) (each referred to as
“Broker/Custodian”). These Broker/Custodians make available to us certain products and services that
support our advisory business and the management and administration of client accounts.
These products and services are generally available to independent investment advisers whose clients
maintain accounts at the Broker/Custodian and may include technology, trading platforms, operational
support, market data, practice management resources, educational events, and other business support
services.
We benefit from these products and services because the cost of these services would otherwise be borne
directly by us. As a result, the availability of these services creates a conflict of interest because it provides
an incentive for us to recommend a Broker/Custodian based on the benefits received by our firm rather than
solely on the services available to clients. Economic benefits are not considered to be part of a soft dollar
arrangement. NWWP does not participate in any soft dollar arrangements.
Additional information about these products and services and the associated conflicts of interest is described
in Item 12 (Brokerage Practices).
Item 15: Custody
Your independent qualified custodian will directly debit your account(s) for the payment of our advisory
fees. Because our firm is authorized to deduct advisory fees from your account(s), we are deemed to have
“limited custody” of client funds or securities. We do not, however, maintain physical custody of your assets.
All funds and securities are held by qualified custodian.
You will receive account statements directly from the qualified custodian(s) holding your assets, generally
on at least a quarterly basis. These statements will reflect the deduction of our advisory fees from your
account(s) each billing period. We encourage you to carefully review these statements for accuracy and to
compare them with any reports you receive from us.
Item 16: Investment Discretion
For those Client accounts where we provide Investment Management Services, we maintain discretion over
Client accounts with respect to securities to be bought and sold and the amount of securities to be bought
and sold. Investment discretion is explained to Clients in detail when an advisory relationship has
22
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. Additionally, the discretionary relationship will be
outlined in the advisory contract and signed by the Client.
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 would like our opinion 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.
Item 18: Financial Information
Registered Investment Advisers are required in this Item to provide you with certain financial information
or disclosures about our financial condition. We have no financial commitment that impairs our ability to
meet contractual and fiduciary commitments to Clients, and we have not been the subject of a bankruptcy
proceeding.
We do not have custody of Client funds or securities or require or solicit prepayment of more than $1,200
in fees per Client six months in advance.
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