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Form ADV Part 2A
April 23, 2026
Pflueger Wealth, LLC
107 Harriet Road
Churchville, PA 18966
215-499-6850
pfluegerwealth.com
Item 1 – Cover Page
This Form ADV Part 2A (“Brochure”) is a very important document between clients and Pflueger Wealth,
LLC. (“Pflueger”, “us”, “we”, “our”). The oral and written communications provided to clients and
prospects, including this Brochure, is information that can be used to evaluate and hire us (and other
advisors).
This Brochure provides information about our qualifications and business practices. If clients
have any questions about the contents of this Brochure, please contact us at 215-499-6850. The
information in this Brochure has not been approved or verified by the United States Securities
and Exchange Commission or by any State Securities Regulatory Authority. We are an
Investment Adviser registered with the Securities and Exchange Commission. Our registration
as an Investment Adviser does not imply any level of skill or training.
Additional information about our firm (and our employees) is available to clients for free, by visiting
www.adviserinfo.sec.gov and our CRD number is 339188.
Item 2 – Material Changes
This follows our last brochure dated April 6, 2026, and removes standing letters of authorization in Item
15.
In the future, this Brochure will be amended anytime there is a material change and this section will
include a summary of those changes. Following the SEC and state rules, we will ensure that clients
receive a summary of any material changes to this and subsequent Brochures within 120 days of the
close of our fiscal year. We may provide other ongoing disclosure information about material changes
as necessary.
If clients or prospective clients want to learn more about Pflueger Wealth, LLC please call 215-499-
6850 or visit the SEC’s website at www.adviserinfo.sec.gov.
Item 3 – Table of Contents
Form ADV Part 2A ............................................................................................................................ 1
Item 1 – Cover Page ..................................................................................................................... 1
Item 2 – Material Changes ............................................................................................................ 2
Item 3 – Table of Contents ............................................................................................................ 2
Item 4 – Advisory Business ........................................................................................................... 3
Item 5 – Fees and Compensation .................................................................................................. 3
Item 6 – Performance-Based Fees and Side-By-Side Management ............................................... 4
Item 7 – Types of Clients ............................................................................................................... 4
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................... 4
Item 9 – Disciplinary Information ................................................................................................... 5
Item 10 – Other Financial Industry Activities and Affiliations ........................................................... 5
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...... 6
Item 12 – Brokerage Practices ...................................................................................................... 6
Item 13 – Review of Accounts ....................................................................................................... 7
Item 14 – Client Referrals and Other Compensation ...................................................................... 7
Item 15 – Custody ......................................................................................................................... 8
Item 16 – Investment Discretion .................................................................................................... 8
Item 17 – Voting Client Securities .................................................................................................. 8
Item 18 – Financial Information ..................................................................................................... 8
Item 19—Requirements for State Registered Advisors ................................................................... 8
Form ADV Part 2B ............................................................................................................................ 9
Item 2 – Educational Background and Business Experience ........................................................ 10
Item 3 – Disciplinary Information ................................................................................................. 10
Item 4 – Other Business Activities ............................................................................................... 10
Item 5 – Additional Compensation ............................................................................................... 10
Item 6 – Supervision ................................................................................................................... 10
Item 7 – Requirements for State-Registered Advisors .................................................................. 10
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Item 4 – Advisory Business
Plueger Wealth, LLC (“Pflueger”) was established to provide thoughtful, precise and accurate fiduciary-
based investment management (“Investment Management:) and financial consulting (“Financial
Consulting”) for individuals, families and business owners. Pflueger is owned by Barry Pflueger and
was created in 2025 as an independent registered investment advisor.
Investment Management: Our services are designed to assist clients in meeting their unique financial
goals through the use of financial investments. Pflueger utilizes various securities, including but not
limited to; stocks, bonds, mutual funds, exchange traded funds (ETF), certificates of deposit, real estate
investment trusts (REIT), preferred stock, U.S Treasury bonds and other investment programs available
through the custodian selected by the client. Please refer to Item 8 for information on risks associated
with investments selected by Pflueger.
Clients may impose restrictions on purchasing various investments and we will tailor investment
management based upon the individual needs of the client. Pflueger will consider information provided
by the client in determining the appropriate suitability. Clients receive ongoing portfolio construction,
investment selection, monitoring, rebalancing, reporting and execution of trades on a discretionary
basis, which means we will not obtain client’s consent before making trades. Incidental financial
consulting is provided as needed in conjunction with Investment Management and includes assisting
clients with investment advice, financial goals and objectives analysis, as well as financial and
retirement planning. However, not all Investment Management clients will require or receive incidental
financial consulting.
Financial Consulting: Clients can engage Pflueger solely for Financial Consulting, which can include a
review or consultations for total portfolio and balance sheet guidance; outside managers/service
providers, debt management, cash flow & budgeting, financial and retirement planning, tax planning,
estate planning, charitable giving, risk management or business consulting. It is important to know that
economic and cyclical actions create different situations or demands and client have different
circumstances so not all of the above services will be provided. It is also important to know that no
trading authority is granted to Pflueger through stand-alone Financial Consulting.
Assets Under Management: As of March 18, 2026 we managed $79,097,815 in assets on a
discretionary basis. We do not manage any assets under a sponsored wrap-fee program.
Item 5 – Fees and Compensation
Wealth Management: The fee for Investment Management is based on the amount of assets under
management (“AUM”), as determined by the independent qualified custodian. Clients can engage
Pflueger for Investment Management by signing an advisory agreement (“Agreement”) that outlines our
services, as well as a description of the fees charged (“Advisory Fees”). Advisory Fees will be charged
monthly and in arrears, based on the average daily value of the AUM at the end of the month. Accounts
opened under the Agreement will be aggregated together for determining AUM during the billing
process, which may provide the client a lower Advisory Fee rate. Our standard Advisory Fee schedule
for Individual Accounts is as:
First $1,000,000
Next $2,000,000
Over $3,000,000
0.75%
0.55%
0.35%
Our Advisory Fee is charged on a tiered basis, meaning that clients will pay each level of fee based on
their AUM. For example, a client with $5 million would annually pay 0.75% on the first $1 million, 0.55%
on the next $2 million and 0.35% on the remaining $2 million. Advisory Fees we charge are separate
and distinct from the fees and expenses charged by investments like mutual funds and exchange traded
funds (ETFs). In these cases, the fees and expenses are described in each fund's prospectus or
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available through common financial websites. These fees will generally include a management fee,
other fund expenses, and a possible distribution fee. In no case will the fees exceed the industry
standard of 3%.
Fees for Financial Consulting are based on the arrangement and can be hourly or fixed as detailed in
the Financial Consulting Agreement (“Consulting Agreement”). The fees for Financial Consulting will
not exceed $500 per hour or $25,000 per engagement. Financial Consulting fees are payable in
arrears. Financial Consulting fees can be paid by check, third-party payment programs, ACH or through
any taxable account opened through Investment Management (if authorized by the client). Clients will
be provided an invoice for Financial Consulting fees upon completion of services, or at minimum on a
quarterly basis.
In addition to our Advisor Fee, clients are also responsible for the transaction charges, fees and other
expenses charged and imposed by the firm (“Custodian”) who holds the client assets. Advisory Fees
may be negotiated, lowered or waived for family, friends or based upon the complexity level of the client
situation. We do have a minimum household fee for Investment Management of $7,500, but can waive
that for family, children or other situations. Clients provide us authorization to electronically debit our
fees in the Agreement and custodial paperwork. Clients can cancel the Agreement for Investment
Management or Financial Consulting without any charges and penalties within 5 business days after
contract execution by contacting us by phone or email.
In the event a client terminates our services Advisory Fees will be charged until the notice of termination
is provided by the client. Clients can terminate our Investment Management or Financial Consulting
services by phone, writing or email. Advisory Fees are electronically debited from client accounts. The
value used to calculate the Advisory Fee will include all positions in the account, cash, dividends,
accrued interest and interest payments unless specifically excluded in the Special Instructions section
of the Agreement.
Item 6 – Performance-Based Fees and Side-By-Side Management
We do not receive any performance based fees, nor do we offer side-by-side management of assets.
Item 7 – Types of Clients
We provide services to individuals, trusts, estates, charitable organizations (non-profits), corporations,
associations and other business entities (such as limited liability companies, networks or limited
partnerships). We do not have a minimum account size but we do require a minimum annual Advisory
Fee of $7,500 per household.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis: While the methods of analysis are constantly evolving, many decisions and
recommendations are made using the methods noted below. It is important to know that all methods
of analysis are subject to being inaccurate in their projection, deduction, or direction, which could result
in the Risk of Loss as discussed later in this section.
Quantitative Analysis: An analysis technique that seeks to understand behavior by using complex
mathematical and statistical modeling, measurement, and research. By assigning a numerical value
to variables, quantitative analysts try to replicate reality mathematically. Some believe that it can also
be used to predict real-world events, such as changes in the share price.
Qualitative Analysis: Securities analysis that uses subjective judgment based on non-quantifiable
information, such as management expertise, industry cycles, strength of research and development,
and labor relations. This type of analysis technique is different from quantitative analysis, which
focuses on numbers. The two techniques, however, are often used together.
Modern Portfolio Theory: Is the process of maximizing the expected return of the portfolio for a
given amount of portfolio risk.
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Charting (Technical Analysis): Includes the review of charts of market and security activity to identify
when the market is moving up or down and to predict how long the trend may last and when that trend
might reverse.
Investment Strategies: We have the ability to construct client portfolios using a wide variety of
investments, including stocks, bonds, certificates of deposit, exchange traded funds, mutual funds,
closed end funds, unit investment trusts, structured notes, options and other investments available
through the brokerage firm where client assets are held in custody. Additionally, the portion of cash that
is included in the asset allocation is included in the advisory fees. Although any cash held by the client
in the account(s) and designated as unmanaged assets will not be included in the advisory fee.
We also use various investment strategies: Long Term Purchases – investments purchased with the
expectation to hold the position over a long period of time, typically longer than one year. In addition
to the Risk of Loss discussed below, long-term investing has the risk of losing value or returns not being
enough to reach financial goals. Short Term Purchases – investments purchased with the expectation
that they will be quickly sold within a short time period. These investment have the risk of additional
taxation and trade cost impacting performance. Margin Transactions – a transaction where the client
would borrow money to purchase a security and the underlying position is used as collateral on the
loan. Risks of margin could include magnified losses in the event of poor performance. Options – an
investment that that involves buying or selling a right to purchase or sell a security at a specific price
for a specified time. The risk of trading or investing in options include the expiration of the option with
no value, or thinly traded markets which could impact the liquidity of the investment. It should be known
that frequent trading can affect investment performance through increased brokerage and other
transaction costs and taxes
Risk Information: Investing in all types of investments has various risks and all investments have the
risk of losing value that clients should be prepared to bear. Some investments for fixed income have
the risk of defaulting on interest or principal payments. Investors are also faced with the risk that
inflation will outpace the returns of the investment, which lowers the purchasing power of that investor.
Rebalancing a portfolio may cause taxable events, which could raise the client’s taxes. Investing in
options incurs the risk of the option expiring as well as going down in value. Accounts holding a large
cash position risks underperforming other investments that are experiencing higher returns. It is
important clients understand that there are numerous risks associated with their investments. If used,
Investment Managers may under-perform in their selection of the underlying investments which are
subject to the risks noted above. Additional risks include the inaccurate assumptions used in financial
projections that could impair the results of a financial plan. Clients must understand that it is impossible
to completely predict or project variables that go into Financial Consulting, such as investment returns,
inflation, etc. All Financial Consulting bears the risk that the advice provided may be inaccurate. We
recommend that clients discuss any concerns directly with us. Investing in non-traded REITS incurs
the risk of loss, as well as a lack of liquidity.
We also may provide assistance in areas to help clients through complex and emotional issues that
have uncertain and unpredictable outcomes. We strive to provide comprehensive information and
assistance to help clients make wise and thoughtful decisions. However, it is important that all clients
know we cannot foresee all situations and results may differ significantly from our initial and ongoing
analysis. Except where specifically assigned to us, the clients retain the ultimate authority for all
decision-making and outcomes.
Item 9 – Disciplinary Information
Neither Pflueger nor any affiliated persons have any disciplinary history.
Item 10 – Other Financial Industry Activities and Affiliations
Neither Pflueger nor any affiliated persons have any other financial industry activities or affiliations.
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Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
We have implemented policies and procedures to govern our employees and to mitigate the conflicts
of interest we encounter when providing our advisory services to clients. These include:
A Code of Ethics that each employee is required to review and sign an acknowledgement of
receipt and understanding (upon hire, and annually);
Prohibitions on the misuse of material non-public information;
Prohibitions to place their interests in front of clients.
Personal securities trading policies and procedures (governing not only our employee but also
the members of their household and any other securities or brokerage accounts where they have
beneficial ownership of with a spouse, family member or other person). Employees are not
allowed to:
o Trade on inside information
o “Front-run” or trade in anticipation of client transactions.
o Trade or participate in any activity prohibited under the federal securities laws.
We strive to achieve the highest ethical and fiduciary standards (in dealing with clients, the public,
vendors, prospective clients and each other). As a fiduciary, we have an affirmative duty to act with
integrity, competence, and care; this includes disclosing all potential and actual conflicts of interest.
We perform services for various other clients. We do not have any material financial interest in
recommended securities outside of situations noted in this section. We may give advice or take actions
for our clients that differ from the advice given to other clients. Our firm and its “related persons” may
buy or sell securities similar to, or different from, those we recommend to clients for their accounts. In
an effort 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. We maintain the required personal securities transaction records per regulation.
Principals and supervised persons of our firm may also invest in securities at the same time, before, or
after clients. In an effort 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 securities
transactions. As mentioned above, we maintain the required personal securities transaction records
per regulation. The timing or nature of any action taken for all clients or other sponsors may also vary.
For more information or to request a copy of our Code of Ethics, please contact us at 215-499-6850.
Item 12 – Brokerage Practices
For Investment Management Individual Accounts, we will likely recommend Charles Schwab as the
(“Custodian”) for assets, although the client is ultimately responsible for selecting the Custodian. We
receive certain services and economic benefits from Charles Schwab & Company (“Custodian”) that
are typically not offered to retail investors. These benefits are provided to us for utilizing their custodial
and brokerage services for our clients’ accounts.
The benefits we receive include, but are not limited to, trading costs, electronic access to trading and
client accounts, discounts or payments for software, historical relationship with us, execution
capabilities, reputation, financial strength, products and services, compliance, research and technology
and other operational support that may benefit us, but not the client. Benefits also include covering
specific expenses for compliance or technology based on the assets moved to the Custodian. This
arrangement present a conflict of interest because the economic benefits we receive from Custodian
may influence our recommendation to clients to use their services, rather than a custodian that may
charge less or offer different services. Our decision to recommend the Custodian is based on a range
of factors, including the services, technology, and support it provides, which we believe ultimately
assists us in delivering efficient advisory services to our clients. We address this conflict by disclosing
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the arrangement to you in this brochure. We always uphold our fiduciary duty to seek the best overall
combination of value, service, and price for your account. You are not required to use Charles Schwab
as your custodian; however, if you choose another custodian, we may not be able to provide all of our
services, or the services may be less efficient. In all cases, we must place the interests of the client in
front of our own. If clients select an alternative broker-dealer for their assets, they may pay a higher
commission and prohibit us from blocking transactions. We do not receive client referrals from any
custodian or third parties.
Trading is typically done on a customized basis for clients, where we would not aggregate trades among
different clients. It is possible that rebalancing/trading accounts are done so randomly which could
result in clients holding different positions and receiving higher or lower prices than other accounts with
similar investment objectives. It may be possible for employees to buy or sell securities in their personal
accounts that were also purchased in the client account. Since client accounts are traded individually
it would be rare for us to enter a block trade. By not aggregating or block trading, clients may receive
different execution prices than other clients with similar objectives. However, in the event we enter a
block (aggregated) trade and we received a partial allocation, then all clients would receive a pro-rata
allocation. By not aggregating or block trading, clients may receive different execution prices than other
clients with similar objectives. As noted earlier we have a strict policy against using the trade flow of
clients to economically benefit us or our employees.
Item 13 – Review of Accounts
Client accounts are reviewed on a regular basis, typically on a quarterly basis. However, clients may
request more frequent reviews. There are many factors that might bring about a review of accounts,
including regular review dates, supervision reviews, economic changes, political disruptions or other
market activity. We encourage clients to carefully review the written reports we provide as well as the
statements provided by the Custodian. Clients should rely on the statement for the actual value of the
account. We may also provide clients with reports which may have a different value than statements
provided by the Custodian. This difference could be due to trade date versus settlement date
reconciliations, accrued interest, or the exclusion of a position that is not included in management or
billing. Also, we encourage clients to contact their Custodian immediately if they do not receive their
statement directly from the Custodian. For further information on any billing information contained in
your reports, please refer to Item 5 of this document as well as the Advisory Agreement.
Supervision of the firm is the responsibility of Barry Pflueger, Chief Compliance Officer of the firm. The
review includes the performance of the accounts and positions. It is critical that clients report any
changes in their financial situation so we can ensure they are invested properly. If you have any
questions on the supervision or review of accounts, please call Barry Pflueger at 215-499-6850.
Item 14 – Client Referrals and Other Compensation
As mentioned earlier, we receive certain indirect benefits from the Custodian. We may also receive
additional non-monetary compensation from various vendors, product providers, distributors, and
others. These providers may provide compensation by paying some expenses related to training and
education, including travel expenses, and attaining professional designations. We might receive
payments to subsidize our own training programs. Certain vendors may invite us to participate in
conferences, on-line training or receive publications that may further our skills and knowledge. Some
may occasionally provide us with gifts, meals, and entertainment of reasonable value consistent with
industry rules and regulations. However, we do not receive or pay any compensation, directly or
indirectly, for client referrals.
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Item 15 – Custody
As noted in the Advisory Agreement signed by the client, we have the ability to deduct our advisory fee
directly from client accounts which is considered custody by the state of Pennsylvania. However, the
custody requirements of Regulation 303.042 shall not be applicable when the following safeguards are
incorporated: 1.Pflueger possesses written authorization from the client to deduct advisory fees from
an account held by a qualified custodian. 2. Pflueger sends the qualified custodian written notice of the
amount of the fee to be deducted from the client’s account. 3. Pflueger sends the client a written invoice
itemizing the fee, including any formulae used to calculate the fee, the period covered, and the amount
of assets under management on which the fee was based.
Item 16 – Investment Discretion
Clients engage us on a discretionary basis by executing the Agreement, granting full authority to buy,
sell, or otherwise effect investment transactions in the accounts. Clients may note investment
restrictions on the special instructions section of the Agreement, by email or in writing.
Item 17 – Voting Client Securities
We do not vote proxies on behalf of clients. Clients will receive all proxy voting materials directly from
the custodian. The client maintains exclusive responsibility for voting all proxies generated from the
securities, although we are available to assist with any questions.
Item 18 – Financial Information
We do not have any financial issue or situation that would impair our ability to deliver services to our
clients. Nor has the firm or any principal shareholders filed bankruptcy. Additionally, we do not require
prepayment of advisory fees more than $1,200 per client, six months or more in advance.
Item 19—Requirements for State Registered Advisors
As mentioned under the Item 4, Advisor is owned and operated by Barry Pflueger. For more
information, please refer to the ADV Part 2B included with this document. We do not provide any
services for performance-based compensation. All fees charged are clearly noted on the Agreement
you sign with us. There are no issues against us, Mr. Pflueger to report, including any arbitration claims
or findings of liability from an investment or an investment-related business or activity; fraud, false
statement(s), or omissions; theft, embezzlement, or other wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; or dishonest, unfair, or unethical practices. Additionally, we have no
relationship or arrangement with any issuer of securities.
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Form ADV Part 2B
April 23, 2026
Barry Pflueger, Investment Advisor Representative
Pflueger Wealth, LLC
107 Harriet Road
Churchville, PA 18966
215-499-6850
pfluegerwealth.com
This brochure supplement provides information about Barry Pflueger that supplements the Pflueger Wealth, LLC
brochure. Clients should have received a copy of that brochure and can contact us if they did not receive it or if
there are any questions about the contents of this Supplement. This Supplement has not been reviewed or
approved by the U.S. Securities & Exchange Commission, any state regulatory agency or self-regulatory
organization.
Additional information about Barry Pflueger (CRD# 8175587) is available on the SEC’s website at
www.adviserinfo.sec.gov.
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Item 2 – Educational Background and Business Experience
Barry Pflueger, born 1965, graduated from Pennsylvania State University in 1988 with a Bachelor of
Science in Finance. From 1982 to 2025 he worked for First National Bank & Trust and was an Executive
Vice President in charge of the Wealth Management Group. In 2025 he started and registered with
Pflueger Wealth, LLC as an Investment Advisor Representative. In 1992 he obtained the Certified
Financial Planner (“CFP®“) designation.
The CFP® designation identifies individuals who have completed the mandatory examination,
education, experience, and ethics requirements mandated by the CFP® Board. Candidates must have
at least three years of qualifying work experience. CFP® candidates must pass an examination that
covers over 100 financial planning topics, which broadly include: investment, financial, retirement,
estate and insurance planning, risk management, employee benefits planning, income tax planning.
The designation has ongoing ethics requirements and oversight by the CFP® Board and 30 hours every
two-years of continuing education.
Item 3 – Disciplinary Information
There are no disciplinary events to report for Mr. Pflueger.
Item 4 – Other Business Activities
There are no other business activities for Mr. Pflueger.
Item 5 – Additional Compensation
There is no other compensation for Mr. Pflueger outside of his employment with Pflueger Wealth, LLC.
Item 6 – Supervision
Barry Pflueger is the Chief Compliance Officer and is responsible for trading, account overview and
supervision for all accounts, including accounts managed by the firm. All advisory accounts opened
are supervised in accordance with the Policies and Procedures established by Pflueger Wealth, LLC.
For any question on the supervision of accounts, clients may reach Mr. Pflueger at 215-499-6850.
Item 7 – Requirements for State-Registered Advisors
All material items have been disclosed and Mr. Pflueger has not been involved in any arbitrations,
bankruptcy petitions, claims, damages or civil, self-regulatory or administrative proceedings.
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