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Item 1 – Cover Page
Registered As: No Fate BWWM, LLC | Doing Business As NFWM | CRD No. 317406
Form ADV Part 2A – Firm Disclosure Brochure
8105 Rasor Blvd., Box #87
Plano, TX 75024
(214) 379-3333
March 31, 2026
the firm.
Additional
information about NFWM
is available on
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business
practices of NFWM (“the firm”). If you have any questions about the contents of this Disclosure Brochure,
please contact us at (214) 379-3333 or by email at johnh@nofatebwwm.com. The information in this Disclosure
Brochure has not been approved or verified by the U.S. Securities and Exchange Commission (“SEC”) or by any
state securities authority. Registration of an investment advisor does not imply any specific level of skill or
training. This Disclosure Brochure provides information about the firm to assist you in determining whether to
the SEC’s website at
retain
www.Advisorinfo.sec.gov by searching our CRD number 317406.
Page 1 of 38
Item 2 – Material Changes
There are no material changes to disclose since the previous annual filing on March 29, 2025.
At any time, the current Disclosure Brochure is available on the SEC’s Investment Advisor Public Disclosure
website at www.Advisorinfo.sec.gov by searching the firm name or CRD number 317406. A copy of this
Disclosure Brochure may be requested at any time, by contacting (214) 379-3333 or by email at
johnh@nofatebwwm.com.
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Disclosure Brochure
Item 3 – Table of Contents
Item 1 – Cover Page .................................................................................................................................................................................... 1
Item 2 – Material Changes .......................................................................................................................................................................... 2
Item 3 – Table of Contents .......................................................................................................................................................................... 3
Item 4 – Advisory Business ........................................................................................................................................................................ 4
Item 5 – Fees and Compensation ................................................................................................................................................................. 7
Item 6 – Performance-Based Fees and Side-By-Side Management ............................................................................................................ 9
Item 7 – Types of Clients ............................................................................................................................................................................ 9
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ..................................................................................................... 9
Item 9 – Disciplinary Information ............................................................................................................................................................. 15
Item 10 – Other Financial Industry Activities and Affiliations ................................................................................................................. 15
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............................................................ 16
Item 12 – Brokerage Practices ................................................................................................................................................................... 16
Item 13 – Review of Accounts .................................................................................................................................................................. 21
Item 14 – Client Referrals and Other Compensation ................................................................................................................................ 22
Item 15 – Custody ..................................................................................................................................................................................... 22
Item 16 – Investment Discretion ............................................................................................................................................................... 23
Item 17 – Voting Client Securities ............................................................................................................................................................ 23
Item 18 – Financial Information ................................................................................................................................................................ 23
Appendix 1 – Wrap Fee Program Brochure…………………………………………………………..................................…….…….. 24
ADV 2B – Individual Disclosure Brochure (John O. Hetzel)………………………………………………………………………….. 30
Privacy Policy…………………………………………………...….……………………………………………….………………….. 36
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Disclosure Brochure
Item 4 – Advisory Business
Firm Information
No Fate BWWM, LLC (“NFWM”) was organized in 2020 as a Texas limited liability company; the single
managing member, John O. Hetzel has over 20 years of experience in the financial services industry. This
disclosure brochure provides information regarding the qualifications, business practices and details of the
advisory services and the applicable fees.
NFWM has entered into a sub-advisory agreement with sK Advisors Network, LLC for the management of
client accounts.
From time to time, clients may hold securities for which NFWM does not recommend buy or sell transactions;
however, due to either capital gains considerations, or the client’s instructions, the client may choose to hold the
security and to have it considered in the client’s overall portfolio allocation. In these cases, Advisor will attempt
to identify which category the security is most appropriately allocated to and will then consider it as part of that
category when analyzing the client’s overall portfolio allocation and rebalancing needs.
Principal Owners
John O. Hetzel, CFA, CFP®, AIFA® (CRD No. 4147688) serves as the President, Wealth Advisor and Chief
Compliance Officer. In addition to his industry experience and professional designation that are further detailed
in his individual disclosure brochure (beginning on page 30), Mr. Hetzel has an MBA in Finance from Southern
Methodist University – Cox School of Business and a BS in Engineering – Industrial Distribution from Texas
A&M University.
Mr. Hetzel is also the controlling managing member of sK Advisor Network, an SEC registered investment
advisor organized in Texas to serve as a collective of multiple smaller RIAs that together can achieve greater
industry scale and shared services.
Advisory Services Offered
NFWM provides fee-based investment advisory services primarily to individual Clients and high-net worth
individuals. Services are also available to businesses and financial institutions. Accounts are managed based on
the individual goals, objectives, time horizon, and risk tolerance of each Client.
Assets are managed on a discretionary or non-discretionary basis, as selected on the written asset management
agreement.
• Discretionary Authority – Client grants NFWM ongoing and continuous discretionary authority to
execute its investment recommendations without the Client's prior approval of each specific transaction.
Under this authority, Client shall allow NFWM to purchase and sell securities and instruments in this
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Disclosure Brochure
Account(s), arrange for delivery and payment in connection with the foregoing, select and retain sub-
advisors, and act on behalf of the Client in all matters necessary or incidental.
• Non-Discretionary Authority – NFWM will not execute any investment recommendations without
Client’s prior approval (verbal or written).
Investment Advisor Representatives are restricted to providing services and charging fees based in accordance
with the descriptions detailed in this document and the account agreement. However, the exact service and fees
charged to a particular Client are dependent upon the Investment Advisor Representatives that are working with
the Client. Investment Advisor Representatives will consider the individual needs of each Client when
providing investment advice. Investment strategies and recommendations are tailored to the individual needs of
each Client but generally consist of an asset allocation consistent with:
1. Income with Capital Preservation. Designed as a longer-term accumulation account, this investment
objective is considered generally the most conservative. Emphasis is placed on generation of current
income with minimal risk of capital loss. Lowering the risk generally means lowering the potential
income and overall return.
2. Income with Moderate Growth. This investment objective emphasizes generation of current income
with a secondary focus on moderate capital growth.
3. Growth with Income. This investment objective emphasizes modest capital growth with some focus on
generation of current income.
4. Growth. This investment objective emphasizes achieving high long-term growth and capital
appreciation. There is little focus on generation of current income.
5. Aggressive Growth. This investment objective emphasizes aggressive growth and maximum capital
appreciation, with no focus on generation of current income. This objective has a very high level of risk
and is for investors with a longer timer horizon.
At no time will NFWM accept or maintain custody of a Client’s funds or securities. All Client assets will be
managed within their designated brokerage account with a qualified custodian, pursuant to the Client
investment advisory agreement on a discretionary or non-discretionary basis.
Investment advice is not limited to certain investment types.
•
• A minimum total investment amount of $500,000 is generally required but, a lesser amount will be
considered.
• Advisory services are tailored to the individual need of each Client.
• Clients may place reasonable restrictions on investing in certain types of securities.
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Disclosure Brochure
Wrap Fee Program
NFWM is the sponsor of a wrap fee program. A wrap fee program includes securities transaction fees together
with its investment advisory fees. Depending on the level of trading required for the Client’s account[s] in a
particular year, the Client may pay more or less in total fees than if the Client paid its own transaction fees.
Please see Appendix 1 –Wrap Fee Program Brochure, which is included as a supplement to this Disclosure
Brochure.
Retirement Plan Rollovers
When NFWM provides investment advice regarding retirement plan accounts or individual retirement accounts,
the firm is acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act
(ERISA) and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts.
The way NFWM makes money creates a conflict of interest; however, NFWM is required to act in a client’s
best interest. More specifically, NFWM must meet a professional standard of care when making investment
recommendations (give prudent advice); never put the firm’s financial interests ahead of a client’s interest (give
loyal advice); and, avoid misleading statements.
Client Account Management
Prior to engaging NFWM to provide investment advisory services, each Client is required to enter into an
investment advisory agreement that defines the terms, conditions, authority, and responsibilities.
Assets Under Management
Assets under management will be amended at least annually.
Assets under Management (03/20/2026)
Discretionary
$309,532,141
Non-Discretionary
$2,331,469
Total
$311,863,610
Financial Planning Services
NFWM, through its Investment Advisor Representatives, generally provides financial planning as part of a
comprehensive asset management engagement. Examples of the type of planning available include the
following:
• College / Education – Planning to pay the future college/education expenses of a child or grandchild.
• Divorce or Separation Planning – Planning for the financial impact of divorce or separation such as
change in income, retirement benefits and tax considerations. Providing alternatives to collaborative
divorce attorneys to reapportion joint assets.
• Estate Planning – Planning that focuses on the most efficient and tax-friendly option to pass on an
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Disclosure Brochure
estate to a spouse, other family members or a charity.
• Insurance Needs – Planning for the financial needs of survivors to satisfy such financial obligations as
housing, dependent child-care and spousal arrangements as well as education.
• Investment Planning – Planning an investment strategy consistent with particular objectives, time
horizons and risk tolerances.
• Retirement – Planning an investment strategy to provide inflation-adjusted income for life.
• Personal –Debt management, personal liability, estate planning and financial goals.
• Tax and Cash Flow – Income tax and spending analysis and planning for past, current and future years.
The impact of various investments on the client’s current income tax and future tax liability can be
illustrated.
Hourly Consulting Services
NFWM does not provide services on an hourly basis.
Item 5 – Fees and Compensation
Investment Management
Fees are paid quarterly in advance subject to the below negotiable fee schedule:
Assets Under Management
Annual Percentage Fee
Any Amount
.10%
+
Less than $500,000
$500,000 to $3,000,000
$3,000,000 to $5,000,000
Above $5,000,000
$1,250 per quarter
$2,500 per quarter
$3,750 per quarter
$5,000 per quarter
• Clients will receive quarterly statements from the Custodian that provides details of the advisory fees.
• The investment advisory fee in the first period of service is pro-rated from the inception date of the
•
account[s] to the end of the first quarter.
If the advisory agreement is terminated before the end of the quarterly period, Client is entitled to a pro-
rated refund of any pre-paid quarterly advisory fee based on the number of days remaining in the quarter
after the termination date.
• Asset management fees are exclusive of and in addition to, brokerage fees, transaction fees, and other
related costs and expenses.
• The firm will not have the authority or responsibility to value portfolio securities.
• Fees can be waived, in whole or in part, for clients who are members of the family or friends. In
certain other circumstances, fees and account minimums are negotiable and therefore, fees can vary
from client to client.
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Disclosure Brochure
Mutual Fund Share Class Disclosures
NFWM strives to select the lowest cost share class available; however, certain mutual fund share classes charge a
12b-1 fee that generally amounts to an additional .25% expense ratio or more. The purpose of 12b-1 fees, as
approved by the SEC, are to cover marketing expenses and shareholder services such as support services and
“other expenses” such as legal, accounting and the administrative functions of the custodian. When selecting a
mutual fund, Investment Advisor Representatives have a fiduciary duty to choose the share class that helps
manage the overall fee structure of the account. The entire fee structure includes such fees as the asset
management fee, the expense ratio and ticket charges.
• Mutual funds typically offer multiple share classes, including lower-cost share classes that do not charge
•
12b-1 fees and are therefore usually less expensive.
Investment Advisor Representatives will consider investing Client funds in 12b-1 fee-paying share
classes even when a lower-cost share class is available as appropriate to account for the overall fee
structure and tax considerations as well as attributes of a fund not available for lesser fees.
Compensation for Sales of Securities
NFWM does not receive commission compensation for advisory services.
Money Managers and Product Sponsors
Investment advisor representatives will, on occasion, have an opportunity to attend a training event or
participate in a due diligence visit where the Money Manager or Product Sponsor will cover the associated
travel expenses such as airfare, hotel and meals. Training opportunities are often held at luxury resorts where
amenities such as golf, spas and entertainment are provided. Such accommodations represent a conflict of
interest that can influence the evaluation of the Money Manager or Product sponsor based on factors other
than the quality of services.
Industry Professionals
When it is in the best interests of the client, NFWM can introduce the services of other professionals for
certain non-investment purposes (i.e., attorneys and accountants). Introductions represent a conflict of
interest because they create a relationship where the other professional has an implied obligation to introduce
potential new clients to NFWM. Clients are under no obligation to engage the services of any such
professional. If the client engages any such professional, and a dispute arises, any recourse will be
exclusively from and against the engaged professional.
Additional Compensation
NFWM can receive an economic benefit for providing advisory services from sources other than the
client. Economic benefits include sales awards and gifts, an occasional meal, as well as entertainment such
as a concert, show or sporting event. Such compensation is not directly related to the advice or services
provided to a particular client, but it does create a conflict of interest that can influence the selection of
services based on the compensation received.
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Disclosure Brochure
Other Fees and Expenses
Clients will incur transaction charges for trades executed in their accounts. These transaction fees are separate
from our fees. Also, Clients will pay the following separately incurred expenses, which we do not receive any
part of: charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed
in the fund’s prospectus (i.e., fund management fees and other fund expenses). If a Client’s assets are invested in
mutual funds or other pooled investment products, Clients should be aware that there will be two layers of
advisory fees and expenses for those assets. Client will pay an advisory fee to the fund manager and other
expenses as a shareholder of the fund. Client will also pay Advisor the advisory fee with respect to those assets.
Most of the mutual funds available in the program may be purchased directly. Therefore, Clients could generally
avoid the second layer of fees by not using the management services of NFWM and by making their own
investment decisions. Further information regarding fees assessed by a mutual fund is available in the
appropriate prospectus.
Termination
A contract between NFWM and a Client may be cancelled at any time with thirty (30) days prior written notice.
Item 6 – Performance-Based Fees and Side-By-Side Management
NFWM does not accept performance-based fees, fees based on a share of capital gains on or capital
appreciation of the assets of a Client (such as a Client that is a hedge fund or other pooled investment vehicle).
NFWM also does not participate in side-by-side management, where an advisor manages accounts that are both
charged a performance-based fee and accounts that are charged another type of fee, such as an hourly or flat fee
or an asset-based fee.
Item 7 – Types of Clients
The advisory services offered by NFWM are available for individuals, individual retirement accounts (“IRAs”),
banks and thrift institutions, pension and profit-sharing plans, including plans subject to Employee Retirement
Income Security Act of 1974 (“ERISA”), trusts, estates, charitable organizations, state and municipal
government entities, corporations and other business entities.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
NFWM emphasizes continuous and regular account supervision. As part of our asset management service, we
generally engage a sub-advisory to manage a portfolio, consisting of individual stocks or 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. Each portfolio will be initially designed to meet a particular investment goal,
which we determine to be suitable to the Client’s circumstances. Once the appropriate portfolio has been
determined, it is subject to review and if necessary, rebalanced based upon the Client’s individual needs, stated
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Disclosure Brochure
goals and objectives. Each Client can place reasonable restrictions on the types of investments to be held in the
portfolio.
Principal Investment Strategies
NFWM primarily recommends diversified low-cost mutual funds and ETFs model portfolio through a sub-
advisory relationship.
• Indexed Based Models – broadly diversified, low-cost models built to track known indexes
• Evidence Based Models – broadly diversified, low-cost models that overweight factors shown to
enhance expected returns.
Mutual funds and ETFs do not offer protection from market volatility. NFWM invests for the long-term and
does not engage in market timing. Advisor generally does not recommend individual stocks or bonds, but
certain exceptions will be made in cases where the stocks were obtained before becoming a client or are
requested by the client. We monitor individual stock exposure in the overall portfolio.
Upon the request of a client, Advisor may agree to provide a limited review of client assets for which we do not
have discretionary authority in the context of the overall plan.
Risk of Loss
Investing in securities involves certain investment risks. Securities can fluctuate in value or lose value up to the
entire principal amount invested. Clients should be prepared to bear the potential risk of loss. NFWM will
assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted
above. However, there is no guarantee that a Client will meet their investment goals. While the methods of
analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will
increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value
and may have negative investment performance. NFWM monitors economic indicators to determine if
adjustments to strategic allocations are appropriate.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client's account. NFWM shall rely on the financial and other information provided by the Client or
their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform NFWM of any changes in financial condition, goals
or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each
Client in advance of investing Client accounts. NFWM will work with each Client to determine their tolerance
for risk as part of the portfolio construction process. The firms’ methods of analysis and investment strategies
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Disclosure Brochure
do not represent any significant or unusual risks however all strategies have inherent risks and performance
limitations. Clients should be aware of the following types of risks that apply to investing and are encouraged
to discuss the specific risks applicable to their account holdings:
• Market Risk – the risk that the value of securities may go up or down, sometimes rapidly or
unpredictably, due to factors affecting securities markets generally or particular industries.
• Interest Rate Risk – the risk that fixed income securities will decline in value because of an increase in
interest rates; a bond or a fixed income fund with a longer duration will be more sensitive to changes in
interest rates than a bond or bond fund with a shorter duration.
• Credit Risk – the risk that an investor could lose money if the issuer or guarantor of a fixed income
security is unable or unwilling to meet its financial obligations.
• Business Risk – the measure of risk associated with a particular security. It is also known as unsystematic
risk and refers to the risk associated with a specific issuer of a security. Generally speaking, all businesses
in the same industry have similar types of business risk. More specifically, business risk refers to the
possibility that the issuer of a particular company stock or a bond may go bankrupt or be unable to pay the
interest or principal in the case of bonds.
• Taxability Risk – the risk that a security that was issued with tax-exempt status could potentially lose that
status prior to maturity. Since municipal bonds carry a lower interest rate than fully taxable bonds, the
bond holders would end up with a lower after-tax yield than originally planned.
• Call Risk – the risk specific to bond issues and refers to the possibility that a debt security will be called
prior to maturity. Call risk usually goes hand in hand with reinvestment risk because the bondholder must
find an investment that provides the same level of income for equal risk. Call risk is most prevalent when
interest rates are falling, as companies trying to save money will usually redeem bond issues with higher
coupons and replace them on the bond market with issues with lower interest rates.
• Inflationary Risk – the risk that future inflation will cause the purchasing power of cash flow from an
investment to decline.
• Liquidity Risk – the possibility that an investor may not be able to buy or sell an investment as and when
desired or in sufficient quantities because opportunities are limited.
• Reinvestment Risk – the risk that falling interest rates will lead to a decline in cash flow from an
investment when its principal and interest payments are reinvested at lower rates.
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Disclosure Brochure
• Social/Political – the possibility of nationalization, unfavorable government action or social changes
resulting in a loss of value.
• Legislative Risk – the risk of a legislative ruling resulting in adverse consequences.
• Currency/Exchange Rate Risk – the risk of a change in the price of one currency against another.
• Pandemic Risk – Large-scale outbreaks of infectious disease that can greatly increase morbidity and
mortality over a wide geographic area, crossing international boundaries, and causing significant
economic, social, and political disruption.
• ETF Risks, including Net Asset Valuations and Tracking Error – ETF performance may not exactly
match the performance of the index or market benchmark that the ETF is designed to track because the
ETF will incur expenses and transaction costs not incurred by any applicable index or market
benchmark; certain securities comprising the index or market benchmark tracked by the ETF may, from
time to time, temporarily be unavailable; and supply and demand in the market for either the ETF and/or
for the securities held by the ETF may cause the ETF shares to trade at a premium or discount to the
actual net asset value of the securities owned by the ETF.
• Mutual Fund Risks – A risk exists that the investment strategies employed by the mutual funds will not
meet the stated investment objectives the fund is seeking to obtain. Mutual funds may invest in equities,
fixed income, derivatives, and other asset classes; the risks associated with such investments are
described in the fund’s prospectus. The performance of a mutual fund may not exactly match the
performance of the index or market benchmark that the fund is designed to track due to the mutual fund
incurring expenses and transaction costs not incurred by any applicable index or market benchmark.
• Restrictions on Transferability of Certain Mutual Funds – The mutual funds sponsored by DFA are
generally only available through registered investment Advisors. Advisor uses and recommends DFA
mutual funds. If a client terminates Advisors’ services, they may be unable to transfer their securities to
a retail account or to another broker-dealer, and they may be unable to purchase additional shares of
those mutual funds they currently own. If they determine to sell their mutual funds, they may be subject
to tax consequences.
• Portfolio Inactivity Risk – Advisor maintains procedures for reviewing client portfolios and for making
changes to a client’s account holdings. There may be periods where Advisor determines that changes to
a client’s portfolio are unnecessary. Clients will remain responsible for paying Advisor’s fees during all
periods and are solely responsible for determining whether the Advisor’s services remain appropriate for
them.
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Disclosure Brochure
• Real Estate Investment Trust Risk – To the extent that a client invests in REITs, it is subject to risks
generally associated with investing in real estate, such as (i) possible declines in the value of real estate,
(ii) adverse general and local economic conditions, (iii) possible lack of availability of mortgage funds,
(iv) changes in interest rates, and (v) environmental problems. In addition, REITs are subject to certain
other risks related specifically to their structure and focus such as: dependency upon management skills;
limited diversification; the risks of locating and managing financing for projects; heavy cash flow
dependency; possible default by borrowers; the costs and losses of self-liquidation of one or more
holdings; the possibility of failing to maintain exemptions from securities registration; and, in many
cases, relatively small market capitalization, which may result in less market liquidity and greater price
volatility.
• Interval Fund Repurchase Offers Risk – NFWM can recommend or purchase interval funds. Subject
to applicable law, one or more of these funds may place limitations on the percentage of outstanding
shares that may be repurchased in each period. If a repurchase offer is oversubscribed, the fund will
repurchase the shares tendered on a pro rata basis, and shareholders will have to wait until the next
repurchase offer to make another repurchase request. As a result, shareholders may be unable to
liquidate all, or a given percentage, of their investment in the fund during a repurchase offer. Some
shareholders, in anticipation of proration, may tender more shares than they wish to have repurchased in
a quarter, thereby increasing the likelihood that proration will occur. A shareholder may be subject to
market and other risks, and the net asset value of shares tendered in a repurchase offer may decline
between the repurchase request deadline and the date on which the net asset value for tendered shares is
determined. In addition, the repurchase of shares by the fund may be a taxable event to shareholders.
• Foreign Securities Risk – Mutual funds in a client’s portfolio can invest in foreign securities. Foreign
securities are subject to additional risks not typically associated with investments in domestic securities.
These risks may include, among others, currency risk, country risks (political, diplomatic, regional
conflicts, terrorism, war, social and economic instability, currency devaluations and policies that have
the effect of limiting or restricting foreign investment or the movement of assets), different trading
practices, less government supervision, less stringent accounting standards, less publicly available
information, limited trading markets and greater volatility. To the extent that underlying funds invest in
issuers located in emerging markets, the risk may be heightened by political changes, changes in
taxation, or currency controls that could adversely affect the values of these investments. Emerging
markets have been more volatile than the markets of developed countries with more mature economies.
All investments involve varying degrees of risk, and it should not be assumed that future performance of
any specific investment or investment strategy will be profitable or equal any specific performance
level(s). Investing in securities and other investments involve a risk of loss that each Client should
understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor.
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Types of Investments
NFWM generally manages Client portfolios that consist of mutual funds, Exchange Traded Equities (ETFs) and
individual securities.
• Mutual Funds – a pool of funds collected from many investors for the purpose of investing in securities
such as stocks, bonds, money market instruments and similar assets.
o Open-End Mutual Funds – a type of mutual fund that does not have restrictions on the amount of
shares the fund will issue and will buy back shares when investors wish to sell. Investing in mutual
funds carries the risk of capital loss and thus Clients may lose money investing in mutual funds.
All mutual funds have costs that lower investment returns. The funds can be of bond “fixed
income” nature (lower risk) or stock “equity” nature.
o Alternative Strategy Mutual Funds – Certain mutual funds available in the program invest
primarily in alternative investments and/or strategies. Investing in alternative investments and/or
strategies may not be suitable for all investors and involves special risks, such as risks associated
with commodities, real estate, leverage, selling securities short, the use of derivatives, potential
adverse market forces, regulatory changes and potential illiquidity. There are special risks
associated with mutual funds that invest principally in real estate securities, such as sensitivity to
changes in real estate values and interest rates and price volatility because of the fund’s
concentration in the real estate industry.
• Equity – An investment that generally refers to buying shares of stocks in return for receiving a future
payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities
may fluctuate in response to specific situations for each company, industry conditions and the general
economic environment.
• Exchange Traded Funds (ETFs) – An ETF is a portfolio of securities invested to track a market index
similar to an index mutual fund, but the shares are traded on an exchange like an equity. An ETF share
price fluctuates intraday depending on market conditions instead of having a net asset value (NAV) that
is calculated once at the end of the day. The shares may trade at a premium or discount; and as a result,
investors pay more or less when purchasing shares and receive more or less than when selling shares.
The supply of ETF shares is regulated through a mechanism known as creation and redemption that
involves large, specialized investors, known as authorized participants (APs). Authorized participants
are large financial institutions with a high degree of buying power, such as market makers, banks or
investment companies that provide market liquidity. When there is a shortage of shares in the market,
the authorized participant creates more (creation). Conversely, the authorized participant will reduce
shares in circulation (redemption) when supply falls short of demand. Multiple authorized participants
help improve the liquidity of a particular ETF and stabilize the share price. To the extent that authorized
participants cannot or are otherwise unwilling to engage in creation and redemption transactions, shares
of an ETF tend to trade at a significant discount or premium and may face trading halts and delisting
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Disclosure Brochure
from the exchange. The performance of ETFs is subject to market risk, including the complete loss of
principal. ETFs also have a trading risk based on cost inefficiency if the ETFs are actively traded and a
liquidity risk if the ETFs has a large price spread and low trading volume. In addition, investors buying
or selling shares in the secondary market pay brokerage commissions, which may be a significant
proportional cost not incurred by mutual funds.
• Cash Positions – Based on perceived or anticipated market conditions and/or events, certain assets can
be taken out of the market and held in a defensive cash position. All cash may be included as assets
subject to the agreed upon advisory fee. NFWM, generally invest Client’s cash balances in money
market funds, FDIC Insured Certificates of Deposit, high-grade commercial paper and/or government
backed debt instruments. Ultimately, the firm tries to achieve a reasonable return on our Client’s cash
balances through relatively low-risk conservative investments.
• Multi-Year Guaranteed Annuity (MYGA) - A MYGA, or Multi-Year Guaranteed Annuity, is a fixed
annuity offering a guaranteed interest rate for a specified period, typically 3 to 10 years. It functions
similarly to a Certificate of Deposit (CD), but instead of being offered by a bank, it is provided by an
insurance company. Reported quarter-end values may be slightly off due to the estimation of values.
Additional types of investments will be considered per Client for asset allocation and risk management purposes.
Item 9 – Disciplinary Information
There are no legal, regulatory, or disciplinary events involving NFWM or any of its Supervised Persons.
Item 10 – Other Financial Industry Activities and Affiliations
Insurance Agency Affiliations
• None
Broker/Dealer
• None
Futures Commission Merchant, Commodity Pool Operator, Commodity Trading Advisor
• None
Selection of other Investment Advisers
NFWM recommends sK Advisor Network, LLC (CRD No. 317533) as a sub-advisor for asset allocation models,
to meet the investment objectives and risk profile for clients of NFWM. sK Advisor Network and NFWM are
affiliated separate legal entities under common control and management of Mr. Hetzel.
Other Material Relationship or Arrangements
• None
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Disclosure Brochure
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Code of Ethics
NFWM has implemented a Code of Ethics (the “Code”) that defines our fiduciary commitment to each Client.
This Code applies to all persons associated with the firm (our “Supervised Persons”). The Code was developed
to provide general ethical guidelines and specific instructions regarding our duties to you, our Client. NFWM
and its Supervised Persons owe a duty of loyalty, fairness, and good faith towards each Client. It is the
obligation of the firm’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to
the general principles that guide the Code. The Code covers a range of topics that address employee ethics and
conflicts of interest. To request a copy of our Code, please contact us at (214) 379-3333 or by email at
johnh@nofatebwwm.com.
Personal Trading with Material Interest
NFWM does not act as principal in any transactions. In addition, the firm does not act as the general partner of
a fund or advise an investment company. NFWM does not have a material interest in any securities traded in
Client accounts.
Personal Trading in Same Securities as Clients
NFWM allows our Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Owning the same securities, we recommend (purchase or sell) to you presents a
conflict of interest that, as fiduciaries, we must disclose to you and mitigate through policies and procedures.
As noted above, we have adopted a Code of Ethics to address insider trading (material non-public information
controls); gifts and entertainment; outside business activities and personal securities reporting.
Personal Trading at Same Time as Client
Supervised Persons may not purchase or sell any security immediately prior to or immediately after a
transaction being implemented for an advisory account, thereby preventing an employee from benefiting from
transactions placed on behalf of advisory accounts.
Item 12 – Brokerage Practices
NFWM will generally not allow advisory clients to determine the broker-dealer to be used for execution and
custody. Rather, the Company will generally require that clients establish brokerage accounts with National
Financial Services LLC, and Fidelity Brokerage Services LLC (together with all affiliates, "Fidelity") or
Charles Schwab & Co., Inc. (Schwab) a registered broker-dealer, member FINRA/SIPC, to maintain custody
of clients’ assets and to effect trades for their accounts.
Fidelity Brokerage Services LLC
Fidelity provides "platform" services. The platform services include, among others, brokerage, custodial, trade
execution, clearance, settlement of transactions, administrative support, record keeping and related services that
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Disclosure Brochure
are intended to support intermediaries like the NFWM in conducting business and in serving the best interests
of their clients but that may benefit the NFWM.
Fidelity charges brokerage commissions and transaction fees for effecting certain securities transactions (i.e.,
transactions fees are charged for certain no-load mutual funds, commissions are charged for individual equity
and debt securities transactions). Fidelity enables the Company to obtain many no-load mutual funds without
transaction charges and other no-load funds at nominal transaction charges. Fidelity's commission rates are
generally considered discounted from customary retail commission rates. However, the commissions and
transaction fees charged by Fidelity may be higher or lower than those charged by other custodians and broker-
dealers.
As part of the arrangement, Fidelity may also make available, at no additional charge, certain research and
brokerage services, including research services obtained by Fidelity directly from independent research
companies, as selected by the Company (within specified parameters). These research and brokerage services
would be used by the Company to manage accounts for which it has investment discretion. Services provided
by Fidelity may include research (including mutual fund research, third-party research, and Fidelity's
proprietary research), brokerage, clearing, custody, and access to mutual funds and other investments that are
available only to institutional investors or would require a significantly higher minimum initial investment.
Research and brokerage services presently include: access to a full array of proprietary and third-party
investment offerings, spanning alternatives, structured products, separately managed accounts and mutual
funds; comprehensive technology integration, training and support; Integrated Trust Services offering
efficient, custody and clearing; business-building solutions ranging from marketing support to client
management tools; integrated charitable and foundation services through Fidelity Charitable Services; and
leading retirement programs and offerings to help the Company meet both the asset accumulation and income
distribution needs of its clients. The Company may also receive additional services from Fidelity. Without this
arrangement, the Company might be compelled to purchase the same or similar services at its own expense.
Charles Schwab & Co., Inc.
NFWM can also recommend that clients establish brokerage accounts with Charles Schwab & Co., Inc.
(Schwab) a registered broker-dealer, member FINRA/SIPC, to maintain custody of clients’ assets and to
effect trades for their accounts. Schwab provides access to its institutional trading and custody services,
which are typically not available to Schwab retail investors. These services generally are available to
independent investment advisors on an unsolicited basis, at no charge to them so long as a total of at least
$10 million of the advisor’s clients’ assets are maintained in accounts at Schwab the firm Services.
Schwab’s services include brokerage services that are related to the execution of securities transactions,
custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and
other investments that are otherwise generally available only to institutional investors or would require a
significantly higher minimum initial investment.
For client accounts maintained in its custody, Schwab generally does not charge separately for custody
services but is compensated by account holders through commissions or other transaction-related or asset-
based fees for securities trades that are executed through Schwab or that settle into Schwab accounts.
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Disclosure Brochure
While, as a fiduciary, the firm endeavors to act in its clients’ best interests, recommendations that clients
maintain their assets in accounts at Schwab may be based in part on the benefits received and the availability
of some of the foregoing products and services and other arrangements, not solely on the nature, cost or
quality.
Clients should be aware that for accounts where Schwab serves as the custodian, the firm is limited to
offering services and investment vehicles that are approved by Schwab and may be prohibited from offering
services and investment vehicles that may be available through other broker/dealers and custodians, some of
which may be more suitable for a client’s portfolio than the services and investment vehicles offered through
Schwab. Clients should understand that not all investment Advisors recommend that clients custody their
accounts and trade through specific broker/dealers.
• Institutional Intelligent Portfolios®
When consistent with client’s investment objectives, Advisor can offer asset management services
through the Institutional Intelligent Portfolios® program (the “Program”), an automated investment
program through which clients are invested in a range of investment strategies that Advisor constructed
and manages, each consisting of a portfolio that can include ETFs, mutual funds, and a cash allocation.
The client’s portfolio is held in a brokerage account opened by the client at Charles Schwab & Co., Inc.
(“CS&Co.”). Advisor uses the Institutional Intelligent Portfolios® platform (“Platform”), offered by
Schwab Performance Technologies (“SPT”), a software provider to independent investment advisors
and an affiliate of CS&Co., to operate the Program. Advisor is independent of and not owned by,
affiliated with, or sponsored or supervised by SPT, CS&Co., or their affiliates (CS&Co. and its affiliates
are sometimes collectively referred to as “Schwab”). Advisor, and not Schwab, is the client’s investment
Advisor and primary point of contact with respect to the Program. As between Advisor and Schwab,
Advisor is solely responsible, and Schwab is not responsible, for determining the appropriateness of the
Program for the client, choosing a suitable investment strategy and portfolio for the client’s investment
needs and goals, and managing that portfolio on an ongoing basis. Clients can instruct Advisor to
exclude up to three mutual funds or ETFs from their portfolio.
Advisor contracted with SPT to provide Advisor with the Platform, which consists of technology and
related trading and account management services for the Program. The Platform enables Advisor to
make the Program available to clients online and includes a system that automates certain key parts of
its investment process (the “System”). The System includes an online questionnaire that helps Advisor
determine the client’s investment objectives and risk tolerance and select an appropriate investment
strategy and portfolio. Advisor will recommend a portfolio via the System in response to the client’s
answers to the online questionnaire. The client may then indicate an interest in a portfolio that is one
level less or more conservative or aggressive than the recommended portfolio, but Advisor then makes
the final decision and selects a portfolio based on all the information it has about the client. The System
also includes an automated investment engine through which Advisor manages the client’s portfolio on
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Disclosure Brochure
an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and
elects).
Advisor charges clients a fee for its services under the Program as part of the fees described under
Item5, Fees and Compensation. Advisor’ fees are not set or supervised by Schwab. Advisor does not pay
SPT or Schwab fees for the Platform as long as it maintains $100 million in client assets in accounts at
Schwab that are not enrolled in the Program. This arrangement presents a conflict of interest, as it
provides an incentive for Advisor to recommend that clients maintain their accounts at Schwab. Advisor
would therefore generally recommend to clients that they maintain accounts at Schwab if that is
consistent with the considerations discussed in Item 12 below, which mitigates this conflict of interest.
Clients enrolled in the Program are limited in the universe of investment options available to them. For
example, the investment options available are limited to ETFs, mutual funds, and cash/cash equivalents,
whereas Advisor can recommend various other types of securities in its other services. Clients will have
access to their accounts and a financial interface online but can also confer with Advisor with respect to
their account. Please also refer to Item 8 below with respect to the investment risks associated with the
Program, including mutual fund and ETF risk.
Rebalancing
The System will rebalance a client’s account periodically by generating instructions to Schwab
to buy and sell shares of funds and depositing or withdrawing funds through the “Sweep
Program”, considering the asset allocation for the client’s investment strategy. Rebalancing trade
instructions can be generated by the System when (i) the percentage allocation of an asset class
varies by a set parameter established by Advisor, (ii) Advisor decides to change the ETFs or
their percentage allocations for an investment strategy or (iii) Advisor decides to change a
client’s investment strategy, which could occur, for example, when a client makes changes to
their investment profile or imposes or modifies restrictions on the management of their account.
Accounts below $5,000 may deviate farther than the set parameters as well as the target
allocation of the selected investment profile. Rebalancing below $5,000 may impact the ability to
maintain positions in selected asset classes due to the inability to buy or sell at least one share of
an ETF or mutual fund. For example, withdrawal requests may require entire asset classes to be
liquidated to generate and disburse the
requested cash.
Sweep Program
Each investment strategy involves a cash allocation (“Cash Allocation”) that will be held in a
sweep program at Charles Schwab Bank (the “Sweep Program”). The Cash Allocation will be a
minimum of 4% of an account’s value to be held in cash, and may be higher, depending on the
investment strategy chosen for a client. The Cash Allocation will be accomplished through
enrollment in the Sweep Program, which is sponsored by Schwab. By enrolling in the Program,
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Disclosure Brochure
clients consent to having the free credit balances in their brokerage accounts at Schwab swept
into deposit accounts (Deposit Accounts) at Charles Schwab Bank (Schwab Bank) through the
Sweep Program.
Schwab Bank is an FDIC-insured depository institution that is a Schwab affiliate. The Sweep
Program is a required feature of the Program. If the Deposit Account balances exceed the Cash
Allocation for a client’s investment strategy, the excess over the rebalancing parameter will be
used to purchase securities as part of rebalancing. If clients request cash withdrawals from their
accounts, this likely will require the sale of fund positions in their accounts to bring their Cash
Allocation in line with the target allocation for their chosen investment strategy. If those clients
have taxable accounts, those sales may generate capital gains (or losses) for tax purposes. In
accordance with an agreement with Schwab, Schwab Bank has agreed to pay an interest rate to
depositors participating in the Sweep Program that will be determined by reference to an index.
• Compensation to Schwab under the Program
Clients do not pay fees to SPT or brokerage commissions or other fees to Schwab as part of the
Program. However, Schwab receives other revenues including but not specifically limited to the
following which is subject to change: (i) the profit earned by Charles Schwab Bank, on the
allocation to the Schwab Intelligent Portfolios Sweep Program described in the Schwab
Intelligent Portfolios Sweep Program Disclosure Statement; (ii) investment advisory and/or
administrative service fees (or unitary fees) received by Charles Schwab Investment
Management, Inc., a Schwab affiliate, from Schwab ETFs™ Schwab Funds® and Laudus
Funds® that Advisor selects to buy and hold in the client’s brokerage account; (iii) fees received
by Schwab from third-party ETFs that participate in the Schwab ETF OneSource™ program and
mutual funds in the Schwab Mutual Fund Marketplace® (including certain Schwab Funds and
Laudus Funds) in the client’s brokerage account for services Schwab provides; and (iv)
remuneration Schwab may receive from the market centers where it routes ETF trade orders for
execution.
Soft Dollars - Soft dollars are revenue programs offered by broker/dealers whereby an advisor enters
into an agreement to place security trades with the broker in exchange for research and other services.
The custodian makes available various products and services designed to assist the firm in managing and
administering Client accounts. These services include software and other technology that provide access
to Client account data (such as trade confirmation and account statements); facilitation of trade
execution (and research reports or other information about particular companies or industries; economic
surveys, data and analyses; financial publications; portfolio evaluation services; financial database
software and services; computerized news and pricing services; quotation equipment for use in running
software used in investment decision-making. These support services are provided as economic benefits
based on the overall relationship without a minimum production level or value of assets held with the
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Disclosure Brochure
custodian. Consequently, it is not the result of soft dollar arrangements or any other express
arrangements that involve the execution of Client transactions as a condition to receive the services.
Brokerage Referrals - NFWM does not receive any compensation from any third party in connection
with the recommendation for establishing a brokerage account.
Transaction Fees -The Custodian charges brokerage commissions and transaction fees for effecting
certain securities transactions (i.e., transaction fees are charged for certain no-load mutual funds,
commissions are charged for individual equity and debt securities transactions). The Custodian enables
NFWM to obtain many no-load mutual funds without transaction charges and other no-load funds at
nominal transaction charges. The Custodian’s commission rates are generally discounted from
customary retail commission rates. However, the commission and transaction fees charged by the
Custodians may be higher or lower than those charged by other custodians and broker/dealers.
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. Accordingly, although we will seek competitive rates, to the benefit of all
Clients, we may not necessarily obtain the lowest possible commission rates for specific Client account
transactions.
Aggregation and Allocating Trades - In making investment decisions for accounts, securities
considered for investment by one account may also be appropriate for another account managed by the
Advisor. On occasions when the purchase or sale of a security is deemed to be in the best interest of
more than one client account, if the Advisor has a policy of aggregating trades for its clients the Advisor
may aggregate or “batch” orders for the purchase or sale of securities for all such client accounts to the
extent consistent with best execution and the terms of the relevant Investment Advisory Agreements.
Such combined trades may be used to facilitate best execution, including negotiating more favorable
prices, obtaining more timely or equitable execution or reducing overall commission charges. Portfolio
models managed by the subadvisor are aggregated on a pro-rata basis within each model.
Item 13 – Review of Accounts
Client target allocations are monitored on a daily basis using third party technology tools and subject to
quarterly performance reviews. In addition, annual client reviews include a review of the client’s investment
objective, risk tolerance and time horizon as well as any significant life changes (Marriage, divorce, child). The
appropriateness of a wrap fee program will also be considered during the annual review.
All Clients (in person, via telephone or video conference) are encouraged to review financial planning issues (to
the extent applicable), investment objectives and account performance with their Investment Advisor
Representative. Reviews may be conducted more or less frequently at the Client’s request. Accounts may also
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Disclosure Brochure
be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial
situation, and/or large deposits or withdrawals in the Client’s account. The Client is encouraged to notify
NFWM if changes occur in the Client’s personal financial situation that might adversely affect the Client’s
investment plan. Additional reviews may be triggered by material market, economic or political events.
Clients will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements
are sent directly from the Custodian to the Client. The Client can also establish electronic access to the
Custodian’s website so they can view these reports and their account activity. Client brokerage statements will
include all positions, transactions and fees relating to the Client’s account[s].
Item 14 – Client Referrals and Other Compensation
NFWM is a fee-based advisory firm, that is compensated by its Clients to provide investment advice and not
from any investment product or someone other than the Client. NFWM does not receive commissions or other
economic benefit or compensation from product sponsors, broker/dealers or any un-related third party.
Client Referrals from Solicitors
NFWM does not engage paid solicitors for Client referrals.
Item 15 – Custody
NFWM does not accept or maintain actual custody of funds or securities. As disclosed in item 12 (Brokerage
Practices) above, NFWM recommends either Fidelity or Schwab to clients for custody and brokerage services.
There is no direct link between the participation in the program and the investment advice provided to Clients,
although the Company receives economic benefits through its participation in the program that are typically not
available to retail investors.
Either custodian may make available other products and services that benefit us, but that may not directly benefit
our clients' accounts. Many of these products and services are used to service all or some substantial number of
our client accounts. These benefits include the following products and services (provided without cost or at a
discount):
• Provide access to client account data (such as trade confirmations and account statements);
• Facilitate trade execution and allocate aggregated trade orders for multiple client accounts;
• Provide research, pricing and other market data;
• Facilitate payment of our fees from clients' accounts; and assist with back-office functions, record keeping
and client reporting;
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Disclosure Brochure
• Receipt of duplicate client statements and confirmations; and The ability to have advisory fees deducted
directly from our client's accounts.
Other services may be offered to help us manage and further develop our business enterprise. These services can
include, but are not necessarily limited to: (1) compliance, legal and business consulting; (2) publications and
conferences on practice management and business succession; (3) assistance with back- office functions, record
keeping and client reporting; and (4) access to funds with no transaction fees and to certain institutional money
managers. Fidelity may make available, arrange and/or pay third party vendors for the types of services rendered
to the Company. Fidelity may discount or waive fees it would otherwise charge for some of these services or
pay all or a part of the fees of a third party providing these services to the Company. The custodians may also
provide other benefits such as educational events or occasional de minimus business entertainment of our
personnel. All business entertainment will be guided by our Code of Ethics.
Item 16 – Investment Discretion
Clients can determine to engage NFWM to provide investment advisory services on a discretionary basis. Prior
to NFWM assuming discretionary authority over a Client’s account, the Client shall be required to execute an
Investment Advisory Agreement, naming NFWM as the Client’s attorney and agent in fact, granting NFWM
full authority to buy, sell, or otherwise effect investment transactions involving the assets in the Client’s name
found in the discretionary account.
Item 17 – Voting Client Securities
NFWM does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements
directly from the Custodian. NFWM does not assist in answering questions relating to proxies, Clients retains
the sole responsibility for proxy decisions and voting.
Item 18 – Financial Information
Neither NFWM, nor its management, have any adverse financial situations to disclose and have not been
subject to a bankruptcy or financial compromise.
• NFWM does not collect advance fees of $1,200 or more for services to be performed six months or
more in the future.
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Disclosure Brochure
Item 1 – Cover Page
Registered As: NFWM, LLC | CRD No. 317406
Appendix 1 – Wrap Fee Program Brochure
8105 Rasor Blvd., Box #87
Plano, TX 75024
(214) 379-3333
March 31, 2026
This Form ADV2A - Appendix 1 (“Wrap Fee Brochure”) provides information about the qualifications and
business practices for No Fate BWWM, LLC (“NFWM") services when offering services according to a wrap
program. This Wrap Fee Brochure shall always be accompanied by the firm’s Disclosure Brochure, which
provides complete details on the business practices of the firm. If you did not receive the firm Disclosure Brochure
or you have any questions about the contents of this Wrap Fee Brochure or the firm Disclosure Brochure, please
contact us at (214) 379-3333 or by email at johnh@nofatebwwm.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 the firm and its advisory persons are available on the SEC’s website at
www.adviserinfo.sec.gov by searching for our firm name or by our CRD No. 317406. Registration does not
imply a certain level of skill or training.
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Disclosure Brochure
Item 2 - Material Changes
If the firm amends this brochure so that it contains material changes from the last annual update, the changes
will be identified in this item.
Clients will receive, at no charge, a summary of any material changes within 120 days of the firm's fiscal year-
end and promptly (generally within 30 days) after any material changes throughout the year.
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Disclosure Brochure
Item 3 – Table of Contents
Item 1 – Cover Page ……………………………………………………………………….………..……….. 24
Item 2 – Material Changes ……………………………………………………………….……………....…. 25
Item 3 – Table of Contents ……………………………………………..………………............................… 26
Item 4 – Services, Fees and Compensation ……………………….………….………………….....…...….. 27
Item 5 – Account Requirments and Types of Clients …………….………………………………...…...… 28
Item 6 – Portfolio Manager Selection and Evaluation ……………………………………..………….….. 28
Item 7 – Client Information Provided by Portfolio Managers ………….……..………………….…..….. 28
Item 8 – Client Contact with Portfolio Managers …………………………..……….….….......………..… 28
Item 9 – Additional Information ………………………………………………........................................… 28
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Disclosure Brochure
Item 4 – Services, Fees and Compensation
NFWM provides investment advisory services where the asset management fee and ticket charges are
"wrapped" into a single payment. This Wrap Fee Program Brochure is provided as a supplement to the firm’s
Disclosure Brochure (Form ADV 2A) to provide further details of the business practices and fee structure. This
Wrap Fee Program Brochure references back to the firm’s Form ADV 2A in which this Wrap Fee Program
Brochure serves as an Appendix. Please see Item 4 – Advisory Services of the Form ADV 2A for details on the
firm’s investment philosophy and related services.
• NFWM receives investment advisory fees paid by Clients and pays the Custodian for the costs
associated with the regular trading activity.
Fees are generally paid quarterly in advance based on the prior quarter end value as indicated in Item 5 of the
ADV 2A.
• Clients will receive quarterly statements from the Custodian that provides details of the advisory fees.
• The investment advisory fee in the first period of service is pro-rated from the inception date of the
account[s] to the end of the first quarter.
• The firm will not have the authority or responsibility to value portfolio securities.
Participation in this wrap fee program may cost more or less than purchasing such services separately. For
example, a Client account with a high volume of trading is likely to benefit from the fee structure of a wrap fee
program whereas a Client with a low volume of trading is likely to benefit more from a fee structure that
charges a transaction fee per trade with a lower asset management fee or a brokerage account that does not
charge an asset management fee for active management.
NFWM pays the transaction costs for each executed trade in a wrap fee account. As a result, the firm has a
financial incentive to limit orders for wrap fee accounts to minimize transaction costs. Thus, an incentive exists
to trade less frequently in a wrap fee account, which is a conflict of interest.
Other Fees and Expenses
Mutual funds and exchange-traded funds have separate operating costs that are described in each fund's
prospectus. These fees and costs will generally be used to pay management fees, account administration (e.g.,
custody, brokerage, and account reporting), and a possible distribution fee. NFWM does not receive any of the
fees charged by a mutual fund or ETF. A Client could invest in these products directly, without the services of
NFWM , but would not receive the advisory services to assist in determining which products or features are
most appropriate for their financial situation and objectives. Accordingly, the Client should review the fees
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Disclosure Brochure
charged by the fund[s] and the fees charged by the firm to fully understand the total costs. Only advisory fees
are retained by NFWM.
The wrap fee does not cover all fees and costs. The fees not included in the wrap fee include charges imposed
directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus
(i.e. fund management fees and other expenses), mark-ups and mark-down, spreads paid to market maker, fees
(such as commission of markup) for trades executed away from the custodian at another broker/dealer, wire
transfer fees and other fees and taxes on brokerage accounts and securities transactions.
Item 5 – Account Requirements and Types of Clients
Please see Item 7 – Types of Clients in the Form ADV 2A Disclosure Brochure.
Item 6 - Portfolio Manager Selection and Evaluation
NFWM serves as the sponsor for the services under this Wrap Fee Program. The firm does not charge
performance-based fees. The selection of the wrap fee program for a Client is based on their preference for a
model-based account or open architecture as well as account minimum reuirements.
The performance of the wrap fee program is calculated by the custodian.
NFWM does not accept proxy-voting responsibility or assist in answering questions relating to proxies. Clients
retains the sole responsibility for proxy decisions and voting.
Item 7 – Client Information Provided to Portfolio Managers
NFWM is the sponsor for the Wrap Fee Program. Client information is shared by agreement with sKan
Advisor Network, LLC, the Wrap Fee Program portfolio manager.
Item 8 – Client Contact with Portfolio Managers
Clients always have direct access to the Portfolio Managers.
Item 9 – Additional Information
The backgrounds, disciplinary information (none) and other financial industry activities and affiliations is
available on the Investment Advisor Public Disclosure website at www.adviserinfo.sec.gov by searching for our
firm name or by our CRD No. 317406.
Please also see Item 9 of the firm Disclosure Brochure as well as Item 3 of each Investment Advisor
Representatives Form ADV 2B Brochure Supplement (included with this Wrap Fee Program Brochure) for
additional information on how to research the background information.
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Disclosure Brochure
NFWM has implemented a Code of Ethics that defines our fiduciary commitment to each Client. The details of
the Code of Ethics can be found under Item 11 – Code of Ethics, Participation in Client Transactions and
Personal Trading in the Disclosure Brochure (included with this Wrap Fee Program Brochure).
Client accounts are monitored on a regular and continuous basis by the Chief Compliance Officer (“CCO”).
Details of the review policies and practices are provided in Item 13 of the Form ADV Part 2A – Disclosure
Brochure.
Please see Item 14 – Other Compensation in the Form ADV Part 2A – Disclosure Brochure (included with this
Wrap Fee Brochure) for details on additional compensation that may be received by the firm or its Investment
Advisor Representatives. Each Investment Advisor Representative’s Form ADV 2B Brochure Supplement (also
included with this Wrap Fee Brochure) provides details on any outside business activities and the associated
compensation.
• NFWM does not pay a referral fee for the introduction of Clients.
• Financial information is available in Item 18 of the Form ADV Part 2A – Disclosure Brochure.
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Disclosure Brochure
Item 1 - Cover Page
Registered As: NFWM, LLC | CRD No. 317406
John O. Hetzel
Form ADV Part 2B – Firm Disclosure Brochure
8105 Rasor Blvd., Box #87
Plano, TX 75024
(214) 379-3333
March 31, 2026
This brochure supplement provides information about your Investment Advisor Representative that supplements
the firm disclosure brochure. You should have received a copy of the firm brochure that describes the investment
advisory services offered through NFWM a registered investment advisor. Please contact NFWM at the telephone
number above if you did not receive their brochure or if you have any questions about the contents of this
supplement. Additional information about your Investment Advisor Representative is available on the SEC’s
website at www.adviserinfo.sec.gov.
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Disclosure Brochure
Item 2 - Educational Background and Business Experience
This section of the brochure supplement includes the supervised person’s name, age (or year of birth), formal
education after high school, and business background (including an identification of the specific positions held)
for the preceding five years.
Name: John O. Hetzel
Year of birth: 1976
Education
The following information details your Financial Advisor’s formal education. If a degree was attained, the type
of the degree will be listed next to the name of the institution. If a degree is not listed, the Financial Advisor
attended the institution but did not attain a degree.
Southern Methodist University – Cox School of Business, MBA in Finance (2004)
University of Houston, MS (2019)
Texas A&M University, BS in Engineering – Industrial Distribution (1999)
Professional Designations
The following provides information on professional designation(s) that your Financial Advisor earned.
Certified Financial Planner™ - CFP®
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP® (with flame design)
marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States
by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). The CFP® certification is a
voluntary certification; no federal or state law or regulation requires financial planners to hold CFP®
certification. It is recognized in the United States and a number of other countries for its:
(1) high standard of professional education;
(2) stringent code of conduct and standards of practice; and,
(3) ethical requirements that govern professional engagements with clients.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following
requirements:
Education – Complete an advanced college-level course of study addressing the financial planning
subject areas that CFP Board’s studies have determined as necessary for the competent and professional
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Disclosure Brochure
delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited
United States college or university (or its equivalent from a foreign university). CFP Board’s financial
planning subject areas include insurance planning and risk management, employee benefits planning,
investment planning, income tax planning, retirement planning, and estate planning;
Examination – Pass the comprehensive CFP® Certification Examination. The examination,
administered in 10 hours over a two-day period, includes case studies and client scenarios designed to
test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial
planning to real world circumstances;
Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents
outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics
requirements in order to maintain the right to continue to use the CFP® marks:
Continuing Education – Complete 30 hours of continuing education hours every two years,
including two hours on the Code of Ethics and other parts of the Standards of Professional
Conduct, to maintain competence and keep up with developments in the financial planning field;
and,
Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The
Standards prominently require that CFP® professionals provide financial planning services at a
fiduciary standard of care. This means CFP® professionals must provide financial planning
services in the best interests of their clients. CFP® professionals who fail to comply with the
above standards and requirements may be subject to CFP Board’s enforcement process, which
could result in suspension or permanent revocation of their CFP® certification.
Chartered Financial Analyst - CFA
Issuing Organization: CFA Institute.
Designation: Chartered Financial Analyst (CFA).
Prerequisites/Experience Required: Candidate must meet one of the following requirements:
Undergraduate degree and 4 years of professional experience involving investment decision-making,
or 4 years qualified work experience (full time, but not necessarily investment related). Educational
Requirements: Self-study program (250 hours of study for each of the 3 levels). Continuing
Education: None.
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Accredited Estate Planner® - AEP®
Issuing Organization: National Association of Estate Planners & Councils. Prerequisites/Experience
Required: Must be an attorney (JD), accountant (CPA), insurance professional and financial planner
(CLU/ChFC, CFP) or trust officer (CTFA). Must be in good standing with their professional
organization and not be subject to disciplinary investigation. Must have a minimum of 5 years
experience in estate planning in one or more of the prerequisite professions. Educational
Requirements: 2 graduate level courses administered by The American College or from another
accredited graduate program as part of a master's or doctoral degree unless applicant has 15 or more
years experience as an estate planner. Continuing Education: 30 hours every 24 months, including 15
hours in estate planning. Re-certification required annually.
Chartered Financial Consultant® - ChFC®
Issuing Organization: The American College. Prerequisites/Experience: Required: 3 years of full-time
Educational
business experience within the five years preceding the awarding of the designation.
Requirements: 7 core and 2 elective courses. Continuing Education: 30 CE credits every 2 years.
Chartered Life Underwriter® - CLU®
Issuing Organization: The American College. Prerequisites/Experience Required: 3 years of full-time
business experience within the five years preceding the awarding of the designation. Educational
Requirements: 5 core and 3 elective courses. Continuing Education: 30 hours every 2 years.
Certified Fund Specialist - CFS
Issuing Organization: Institute of Business & Finance. Prerequisites/Experience Required: Candidate
must meet one of the following requirements: A bachelor's degree, or 1 year of financial services work
experience. Educational Requirements: Candidate must complete Self Study Program (6 modules).
Continuing Education: 30 hours every two years.
Accredited Investment Fiduciary Analyst - AIFA
Issuing Organization: Center for Fiduciary Studies. Prerequisites/Experience Required: AIF program
graduate and meet requirements from the AIFA matrix. Educational Requirements: Classroom
program (three-day). Continuing Education: 10 hours per year.
Certified Foundation Fiduciary - CFF
Issuing organization: National Association of Certified Financial Fiduciaries. Prerequisites/Education:
Candidate must meet one of the following requirements: 10 years of relevant work experience; or
5 years of experience with a relevant bachelor’s or graduate degree and complete the candidate
applicant profile, disclosure questionnaire and pass a criminal background check. Education
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Requirements: In-person training class. Examination type: Final designation exam (multiple choice,
online, proctored). Continuing Education Requirements: 10 hours annually.
Certified Investment Management Analyst® - CIMA
Issuing Organization: Investment Management Consultants Association. Prerequisites/Experience
Required: Candidate must meet all of the following requirements. Three years of verifiable financial
services experience and must answer no to all disclosure questions on Form U-4 that cover criminal
and regulatory violations, civil judicial actions, customer complaints, etc, or else satisfactorily justify a
yes answer. Educational Requirements: Candidate must complete the following: Self-study education
(approximately 5 months) and one-week classroom education program provided by an AACSB
accredited university business school. Continuing Education: 40 hours every 2 years.
Chartered Alternative Investment Analyst® - CAIA®
Issuing Organization: Chartered Alternative Investment Analyst Association (CAIA).
Prerequisites/Experience Required: Candidate must meet one of the following requirements:
Bachelor's or equivalent degree and more than one year of business experience in the financial
industry, or four years of experience in the financial industry. Educational Requirements: Self-Study
certification program requires the successful completion of both the Level I and Level II examinations.
Continuing Education: None.
Financial Risk Manager® - FRM®
Issuing Organization: Global Association of Risk Professional (GARP). Prerequisites/Experience
Required: None. Examination Type: Multiple choice paper exam given in two parts. Continuing
Education Requirements: Voluntary – recommend 40 hours every two years.
Business Experience
The following information details your Financial Advisor’s business experience for at least the past 5 years.
NFWM, LLC; Investment Advisor Representative
10/2021 – PRESENT
SK Advisory Network, LLC; Investment Advisor Representative
10/2021 – PRESENT
Pomona Wealth Management, LLC; Investment Advisor Representative
04/2024 - PRESENT
Beaird Harris Wealth Management; Investment Advisor Representative
06/2012 – 10/2021
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Item 3 - Disciplinary Information
This section includes any legal or disciplinary events and material to a client's or prospective client's evaluation
of the supervised person.
There are no legal or disciplinary events required to be disclosed in response to this item. Any such
disciplinary information would be available at www.adviserinfo.sec.gov.
Item 4 - Other Business Activities
This section includes any relationship between the advisory business and the supervised person’s other financial
industry activities that create a material conflict of interest with clients and describes the nature of the conflict
and generally how it is addressed. If the supervised person is actively engaged in any investment-related business
or occupation, including if the supervised person is registered, or has an application pending to register, as a
broker-dealer, registered representative of a broker-dealer, futures commission merchant (“FCM”), commodity
pool operator (“CPO”), commodity trading advisor (“CTA”), or an associated person of an FCM, CPO, or CTA,
the business relationship, if any, between the advisory business and the other business is disclosed below.
Dually Registered Investment Advisor Representative
Mr. Hetzel dually registered with sK Advisory Network, LLC, (“sKan”) and Pomona Wealth
Management, LLC other SEC registered investment advisor to offer asset management services and
financial planning services. Asset management services are offered for a fee based on the assets under
management. NFWM and sKan are affiliated separate legal entities under common control and
management of Mr. Hetzel. Prior to receiving investment advice through sKan, clients are required to
enter a separate agreement and must be provided with the appropriate disclosure brochures.
Item 5 - Additional Compensation
This section includes details regarding if someone who is not a client provides an economic benefit to the
supervised person for providing advisory services. For purposes of this Item, economic benefits include sales
awards and other prizes, but not the supervised person’s regular salary, if any.
Mr. Hetzel can receive economic benefits based on production such as awards, incentive travel
expenses, attendance at conferences, dinners or other entertainment events as well as promotional gifts
Item 6 – Supervision
This section explains how Hetzel Wealth Management, Inc. supervises the supervised person, including how the
advice the supervised person provided to clients is monitored.
NFWM maintains a supervisory structure and system reasonably designed to prevent violations of
applicable state rules and regulations. Mr. Hetzel serves as the Chief Compliance Officer and is
responsible for administering the policies and procedures and a system of technology-based controls to
monitor account activity for irregularities or patterns that require review and potential action that may
lead to disciplinary action or reimbursements. Mr. Hetzel does not have a supervisor.
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Disclosure Brochure
Privacy Policy
Our Commitment to You
NoFate BWWM, LLC (“NFWM”) is committed to safeguarding the use of personal information of our
Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described
herein our Privacy Policy ("Policy"). Our relationship with you is our most important asset. We understand
that you have entrusted us with your private information, and we do everything that we can to maintain
that trust. The firm (also referred to as "we", "our" and "us") protects the security and confidentiality of
personal information. Additionally, the firm has implemented controls to ensure that such information is
used for proper business purposes in connection with the management or servicing of our relationship with
you. NFWM does not sell your non-public personal information to anyone. Nor do we provide such
information to others except for discrete and reasonable business purposes in connection with the servicing
and management of our relationship with you, as discussed below. Details of our approach to privacy and
how your personal non-public information is collected and used is outlined in this Policy.
What you need to know?
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of
servicing your account. Federal and State laws give you the right to limit some of this sharing and require
RIAs to disclose how we collect, share, and protect your personal information.
What information do we collect from you?
Driver’s license number
Date of birth
Social security or taxpayer-identification number
Assets and liabilities
Name, address and phone number(s)
Income and expenses
E-mail address(es)
Investment activity
Account information (including other institutions)
Investment experience and goals
What Information do we collect from other sources?
Custody, brokerage and advisory agreements
Account applications and forms
Other advisory agreements and legal documents
Investment suitability questionnaires
Transactional information with us or others
Additional information needed to
service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use, we maintain physical,
procedural and electronic security measures. These include such safeguards as secure passwords,
encrypted file storage and a secure office environment. Our technology vendors provide security and access
control over personal information and have policies over the transmission of data. Our associates are
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trained on their responsibilities to protect the Client's personal information. We require third parties that
assist in providing our services to you to protect the personal information they receive from us.
How do we share your information?
An Registered Investment Advisor shares Client personal information to implement its services effectively.
In the section below, we list some reasons we may share your personal information.
Basis For Sharing
Do we
share?
Can you
limit?
Yes
No
Servicing our Clients
We share information with technology vendors and third-party
service providers to manage and support operations and regulatory
compliance
(such as administrators, brokers, custodians,
regulators, credit agencies, consultants and other financial
institutions) as necessary to provide agreed-upon services,
consistent with applicable law, including but not limited to:
processing transactions; general account maintenance; responding
to regulators or legal investigations; and credit reporting.
No
Not
Shared
Marketing Purposes
NFWM does not disclose and does not intend to disclose, personal
information with non-affiliated third parties to offer you services.
Specific laws may give us the right to share your personal
information with financial institutions where you are a customer
and where NFWM or the client has a formal agreement with the
financial institution. We will only share information for purposes
of servicing your accounts, not for marketing purposes.
Yes
Yes
Authorized Users
Your non-public personal information may be disclosed to you
and persons that we believe to be your authorized agent(s) or
representative(s).
No
Not
Shared
Information About Former Clients
NFWM does not disclose and does not intend to disclose, non-
public personal information to non-affiliated third parties
concerning persons who are no longer our Clients.
Changes to our Privacy Policy
We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with
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us. Periodically we may revise this Policy and will provide you with a revised policy if the changes
materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the
sharing of non-public personal information other than as described in this notice unless we first notify you
and provide you with an opportunity to prevent the information sharing.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by
contacting us at (214) 379-3333 or by email at johnh@nofatebwwm.com.
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