View Document Text
F O R M A D V P A R T 2 A
D I S C L O S U R E B R O C H U R E
Pleasantdale Wealth
Management, LLC
Office Address:
7 Stonebriar Lane
Hackettstown, NJ 07840
Mailing Address:
PO Box 513
Hackettstown, NJ 07840
Tel: 908-914-1572
dudes@pdwmanage.com
A P R I L 1 , 2 0 2 6
This brochure provides information about the qualifications and business practices of
Pleasantdale Wealth Management, LLC. Being registered as a registered investment adviser does
not imply a certain level of skill or training. If you have any questions about the contents of this
brochure, please contact us at 908-914-1572. 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 Pleasantdale Wealth Management, LLC (CRD #302034) is available
on the SEC’s website at www.adviserinfo.sec.gov
Item 2: Material Changes
Annual Update
The Material Changes section of this brochure will be updated annually or when material
changes occur since the previous release of the Firm Brochure.
Material Changes since the Last Update
Since the last filing of this brochure on June 26, 2025, the following changes have been
made:
•
Item 4 has been updated to reflect when we became SEC registered.
•
Item 5 has been updated to disclose fees related to mutual funds.
•
Item 8 has been updated to disclose tactical asset allocation may also be used as a an
investment strategy.
•
Item 15 is updated to reflect we do not have custody of client assets.
Full Brochure Available
This Firm Brochure being delivered is the complete brochure for the Firm.
Item 3: Table of Contents
Form ADV – Part 2A – Firm Brochure
Item 1: Cover Page
Item 2: Material Changes .................................................................................................................... ii
Annual Update ................................................................................................................................................................... ii
Material Changes since the Last Update.................................................................................................................. ii
Full Brochure Available .................................................................................................................................................. ii
Item 3: Table of Contents ................................................................................................................... iii
Item 4: Advisory Business .................................................................................................................. 1
Firm Description ............................................................................................................................................................... 1
Types of Advisory Services ........................................................................................................................................... 1
Client Tailored Services and Client Imposed Restrictions ............................................................................... 4
Wrap Fee Programs ......................................................................................................................................................... 4
Client Assets Under Management .............................................................................................................................. 4
Item 5: Fees and Compensation ....................................................................................................... 4
Method of Compensation and Fee Schedule .......................................................................................................... 4
Client Payment of Fees ................................................................................................................................................... 6
Additional Client Fees Charged ................................................................................................................................... 6
Prepayment of Client Fees ............................................................................................................................................ 6
External Compensation for the Sale of Securities to Clients ........................................................................... 7
Item 6: Performance-Based Fees and Side-by-Side Management ........................................ 7
Sharing of Capital Gains ................................................................................................................................................. 7
Item 7: Types of Clients ....................................................................................................................... 7
Description .......................................................................................................................................................................... 7
Account Minimums .......................................................................................................................................................... 7
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................ 7
Methods of Analysis ......................................................................................................................................................... 7
Investment Strategy ........................................................................................................................................................ 7
Security Specific Material Risks .................................................................................................................................. 8
Item 9: Disciplinary Information ................................................................................................... 10
Criminal or Civil Actions ............................................................................................................................................. 10
Administrative Enforcement Proceedings .......................................................................................................... 10
Self- Regulatory Organization Enforcement Proceedings ............................................................................ 10
Item 10: Other Financial Industry Activities and Affiliations ............................................. 10
Broker-Dealer or Representative Registration ................................................................................................. 10
Futures or Commodity Registration ...................................................................................................................... 10
Material Relationships Maintained by this Advisory Business and Conflicts of Interest ................ 10
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ............. 10
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading ................................................................................................................................................... 10
Code of Ethics Description ......................................................................................................................................... 10
Investment Recommendations Involving a Material Financial Interest and Conflict of Interest. 11
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest 11
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities
Transactions and Conflicts of Interest .................................................................................................................. 11
Item 12: Brokerage Practices ......................................................................................................... 12
Factors Used to Select Broker-Dealers for Client Transactions ................................................................. 12
Aggregating Securities Transactions for Client Accounts ............................................................................. 12
Item 13: Review of Accounts ........................................................................................................... 12
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons
Involved ............................................................................................................................................................................. 12
Review of Client Accounts on Non-Periodic Basis ........................................................................................... 13
Content of Client Provided Reports and Frequency ........................................................................................ 13
Item 14: Client Referrals and Other Compensation ................................................................ 13
Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of
Interest ............................................................................................................................................................................... 13
Advisory Firm Payments for Client Referrals .................................................................................................... 13
Item 15: Custody .................................................................................................................................. 13
Account Statements ...................................................................................................................................................... 13
Item 16: Investment Discretion ..................................................................................................... 13
Discretionary Authority for Trading...................................................................................................................... 13
Item 17: Voting Client Securities ................................................................................................... 14
Proxy Votes ...................................................................................................................................................................... 14
Item 18: Financial Information ...................................................................................................... 14
Balance Sheet .................................................................................................................................................................. 14
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments
to Clients ............................................................................................................................................................................ 14
Bankruptcy Petitions during the Past Ten Years .............................................................................................. 14
Brochure Supplement (Part 2B of Form ADV) .......................................................................... 16
Principal Executive Officer – Bill Dudes, ChFC® ................................................................................................ 16
Item 2 - Educational Background and Business Experience ....................................................................... 16
Professional Certifications ......................................................................................................................................... 16
Item 3 - Disciplinary Information ........................................................................................................................... 16
Item 4 - Other Business Activities Engaged In ................................................................................................... 16
Item 5 - Additional Compensation .......................................................................................................................... 17
Item 6 - Supervision ..................................................................................................................................................... 17
Brochure Supplement (Part 2B of Form ADV) .......................................................................... 19
Supervised Person – Brian Dudes ........................................................................................................................... 19
Item 2 - Educational Background and Business Experience ....................................................................... 19
Item 3 - Disciplinary Information ........................................................................................................................... 19
Item 4 - Other Business Activities ........................................................................................................................... 20
Item 5 - Additional Compensation .......................................................................................................................... 20
Item 6 - Supervision ..................................................................................................................................................... 20
Brochure Supplement (Part 2B of Form ADV) .......................................................................... 22
Supervised Person – Michael Dudes ...................................................................................................................... 22
Item 2 - Educational Background and Business Experience ....................................................................... 22
Item 3 - Disciplinary Information ........................................................................................................................... 22
Item 4 - Other Business Activities ........................................................................................................................... 23
Item 5 - Additional Compensation .......................................................................................................................... 23
Item 6 - Supervision ..................................................................................................................................................... 23
Item 4: Advisory Business
Firm Description
Pleasantdale Wealth Management, LLC (“PDW”) was founded in 2018 and became
registered with the state to offer investment advisory services in 2019 and with the
Securities and Exchange Commission on August 7, 2025. William “Bill” Dudes is 80%
owner. Michael Dudes and Brian Dudes are each 10% owners.
Types of Advisory Services
ASSET MANAGEMENT
PDW offers discretionary asset management services to advisory Clients. PDW will offer
Clients ongoing asset management services through determining individual investment
goals, time horizons, objectives, and risk tolerance. Investment strategies, investment
selection, asset allocation, portfolio monitoring and the overall investment program will be
based on the above factors. The Client will authorize PDW discretionary authority to
execute selected investment program transactions as stated within the Investment
Advisory Agreement.
FINANCIAL PLANNING AND CONSULTING
If financial planning services are applicable, a thorough review of all applicable topics
including but not limited to, Wills, Estate Plans and Trusts, Investments, Taxes, Qualified
Plans, Insurance, Retirement Income, Social Security, College Planning, and Divorce
Planning will be reviewed. If a conflict of interest exists between the interests of PDW and
the interests of the Client, the Client is under no obligation to act upon PDW’s
recommendation. If the Client elects to act on any of the recommendations, the Client is
under no obligation to effect the transaction through PDW. Financial plans will be
completed and delivered inside of thirty (30) days contingent upon timely delivery of all
required documentation.
ERISA PLAN SERVICES
PDW provides service to qualified retirement plans including 401(k) plans, 403(b) plans,
pension and profit-sharing plans, cash balance plans, and deferred compensation plans.
PDW may act as either a 3(21) or 3(38) advisor:
Limited Scope ERISA 3(21) Fiduciary. PDW may serve as a limited scope ERISA 3(21)
fiduciary that can advise, help and assist plan sponsors with their investment decisions on
a non-discretionary basis. As an investment advisor PDW has a fiduciary duty to act in the
best interest of the Client. The plan sponsor is still ultimately responsible for the decisions
made in their plan, though using PDW can help the plan sponsor delegate liability by
following a diligent process.
1. Fiduciary Services are:
• Provide non-discretionary investment advice to the Client about asset classes and
investment alternatives available for the Plan in accordance with the Plan’s investment
policies and objectives. Client will make the final decision regarding the initial selection,
retention, removal and addition of investment options. PDW acknowledges that it is a
fiduciary as defined in ERISA section 3 (21) (A) (ii).
- 1 -
• Assist the Client in the development of an investment policy statement (“IPS”). The IPS
establishes the investment policies and objectives for the Plan. Client shall have the
ultimate responsibility and authority to establish such policies and objectives and to
adopt and amend the IPS.
• Provide non-discretionary investment advice to the Plan Sponsor with respect to the
selection of a qualified default investment alternative for participants who are
automatically enrolled in the Plan or who have otherwise failed to make investment
elections. The Client retains the sole responsibility to provide all notices to the Plan
participants required under ERISA Section 404(c) (5) and 404(a)-5.
• Assist in monitoring investment options by preparing periodic investment reports that
document investment performance, consistency of fund management and conformance
to the guidelines set forth in the IPS and make recommendations to maintain, remove
or replace investment options.
• Meet with Client on a periodic basis to discuss the reports and the investment
recommendations.
2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and
the investment alternatives available to them under the Plan. Client understands PDW’s
assistance in education of the Plan participants shall be consistent with and within the
scope of the Department of Labor’s definition of investment education (Department of
Labor Interpretive Bulletin 96-1). As such, PDW is not providing fiduciary advice as
defined by ERISA 3(21)(A)(ii) to the Plan participants. Advisor will not provide
investment advice concerning the prudence of any investment option or combination of
investment options for a particular participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan
participation among the employees and investment and financial understanding by the
employees.
PDW may provide these services or, alternatively, may arrange for the Plan’s other
providers to offer these services, as agreed upon between Advisor and Client.
3. PDW has no responsibility to provide services related to the following types of assets
(“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and
similar vehicles); or
• Other hard-to-value or illiquid securities or property.
- 2 -
Excluded Assets will not be included in calculation of Fees paid to PDW on the ERISA
Agreement. Specific services will be outlined in detail to each plan in the 408(b)2
disclosure.
ERISA 3(38) Investment Manager. PDW can also act as an ERISA 3(38) Investment
Manager in which it has discretionary management and control of a given retirement plan’s
assets. PDW would then become solely responsible and liable for the selection, monitoring
and replacement of the plan’s investment options.
1. Fiduciary Services are:
• PDW has discretionary authority and will make the final decision regarding the initial
selection, retention, removal and addition of investment options in accordance with the
Plan’s investment policies and objectives.
• Assist the Client with the selection of a broad range of investment options consistent
with ERISA Section 404(c) and the regulations thereunder.
• Assist the Client in the development of an investment policy statement (“IPS”). The IPS
establishes the investment policies and objectives for the Plan.
• Provide discretionary investment advice to the Plan Sponsor with respect to the
selection of a qualified default investment alternative for participants who are
automatically enrolled in the Plan or who have otherwise failed to make investment
elections. The Client retains the sole responsibility to provide all notices to the Plan
participants required under ERISA Section 404(c) (5).
2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and
the investment alternatives available to them under the Plan. Client understands the
PDW’s assistance in education of the Plan participants shall be consistent with and
within the scope of the Department of Labor’s definition of investment education
(Department of Labor Interpretive Bulletin 96-1). As such, the PDW is not providing
fiduciary advice as defined by ERISA to the Plan participants. PDW will not provide
investment advice concerning the prudence of any investment option or combination of
investment options for a particular participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan
participation among the employees and investment and financial understanding by the
employees.
PDW may provide these services or, alternatively, may arrange for the Plan’s other
providers to offer these services, as agreed upon between PDW and Client.
3. PDW has no responsibility to provide services related to the following types of assets
(“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
- 3 -
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and
similar vehicles); or
• Other hard-to-value or illiquid securities or property.
Excluded Assets will not be included in calculation of Fees paid to the Adviser on the ERISA
Agreement. Specific services will be outlined in detail to each plan in the 408(b)2
disclosure.
Client Tailored Services and Client Imposed Restrictions
The goals and objectives for each Client are documented in our Client files. Investment
strategies are created that reflect the stated goals and objectives. Clients may impose
restrictions on investing in certain securities or types of securities.
Agreements may not be assigned without written Client consent.
Wrap Fee Programs
PDW does not sponsor any wrap fee programs.
Client Assets Under Management
PDW has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts:
$111,900,000
$1,800,000
Date Calculated:
December 31, 2025
Item 5: Fees and Compensation
Method of Compensation and Fee Schedule
ASSET MANAGEMENT
PDW offers discretionary direct asset management services to advisory Clients. PDW
charges an annual investment advisory fee based on the total assets under management as
follows:
Assets Under Management
Up to $1,000,000
Over $1,000,000
Annual Fee
1.45%
1.10%
Monthly Fee
.1208%
.0916%
This is a flat rate/breakpoint fee schedule, the entire portfolio is charged the same
asset management fee. For example, a Client with $750,000 under management
would pay $10,875 on an annual basis. $750,000 x 1.45% = $10,875.
The annual fee may be negotiable based upon certain criteria (e.g., historical relationship,
type of assets, anticipated future earning capacity, anticipated future additional assets,
dollar amounts of assets to be managed, related accounts, account composition,
negotiations with Clients, etc.). Fees are billed monthly in advance based on the amount of
assets managed as of the close of business on the last business day of the previous month.
Lower fees for comparable services may be available from other sources. Clients may
terminate their account within five (5) business days of signing the Investment Advisory
Agreement with no obligation and without penalty. Clients may terminate advisory
services with thirty (30) days written notice. For accounts opened or closed mid-billing
- 4 -
period, fees will be prorated based on the days services are provided during the given
period. All unpaid earned fees will be due to PDW. Additionally, all unearned fees will be
refunded to the Client. Client shall be given thirty (30) days prior written notice of any
increase in fees. Any increase in fees will be acknowledged in writing by both parties before
any increase in said fees occurs.
Layering of Fees (Mutual Fund Investments)
Clients should be aware that investments in mutual funds involve certain fees and expenses
that are separate from, and in addition to, the advisory fees charged by our firm. Mutual
funds typically assess internal expenses, including management fees, distribution (12b-1)
fees, and other operational costs. These expenses are reflected in the fund’s expense ratio
and are deducted from the fund’s assets on an ongoing basis.
Accordingly, clients invested in mutual funds will incur a layering of fees—both the
advisory fee paid to our firm and the internal expenses of the mutual funds themselves.
These combined costs can have a direct impact on overall investment returns, as higher
total expenses reduce the net performance experienced by the investor over time.
For clients invested solely in mutual funds, this layering effect may be more pronounced
because all invested assets are subject to both advisory fees and fund-level expenses. Over
extended periods, even relatively small differences in fees can compound and result in
materially lower returns.
We seek to mitigate the impact of these layered costs by evaluating available share classes
and selecting investments that we believe are appropriate for the client’s objectives,
including, where applicable, institutional or lower-cost share classes. However, clients
should carefully review all applicable fees and consider their cumulative effect on
investment performance.
FINANCIAL PLANNING AND CONSULTING
PDW charges an hourly fee for financial planning. Prior to the planning process the Client
will be provided an estimated plan fee. Services are completed and delivered inside of
thirty (30) days contingent upon timely delivery of all required documentation. Client may
cancel within five (5) business days of signing Agreement with no obligation and without
penalty. If the Client cancels after five (5) business days, any unearned fees will be
refunded to the Client, or any unpaid earned fees will be due to PDW a pro rata basis based
on number of hours spent by PDW. PDW reserves the right to waive the fee should the
Client implement the plan through PDW.
HOURLY FEES
Financial Planning Services are offered based on an hourly fee of $200 per hour.
Fees for financial plans are:
Billed 50% in advance with the balance due upon plan delivery.
ERISA PLAN SERVICES
The annual fees are based on the market value of the Included Assets and will not exceed
1.25%. The annual fee is negotiable and will be charged as a percentage of the Included
Assets. Fees may be charged quarterly or monthly in arrears or in advance based on the
- 5 -
assets as calculated by the custodian or record keeper of the Included Assets (without
adjustments for anticipated withdrawals by Plan participants or other anticipated or
scheduled transfers or distribution of assets). If the services to be provided start any time
other than the first day of a quarter or month, the fee will be prorated based on the number
of days remaining in the quarter or month. If this Agreement is terminated prior to the end
of the billing cycle, PDW shall be entitled to a prorated fee based on the number of days
during the fee period services were provided or Client will be due a prorated refund of fees
for days services were not provided in the billing cycle.
The fee schedule, which includes compensation of PDW for the services is described in
detail in Schedule A of the ERISA Plan Agreement. The Plan is obligated to pay the fees,
however the Plan Sponsor may elect to pay the fees. Client may elect to be billed directly or
have fees deducted from Plan Assets. PDW does not reasonably expect to receive any
additional compensation, directly or indirectly, for its services under this Agreement. If
additional compensation is received, PDW will disclose this compensation, the services
rendered, and the payer of compensation. PDW will offset the compensation against the
fees agreed upon under the Agreement.
Client Payment of Fees
Investment management fees are billed monthly in advance. Fees are usually deducted
from a designated Client account to facilitate billing. The Client must consent in advance to
direct debiting of their investment account.
Fees for financial plans are:
Billed 50% in advance with the balance due upon plan delivery.
PDW, in its sole discretion, may charge a lesser investment advisory fee based upon certain
criteria (e.g., historical relationship, type of assets, anticipated future earning capacity,
anticipated future additional assets, dollar amounts of assets to be managed, related
accounts, account composition, negotiations with Clients, etc.).
Additional Client Fees Charged
Custodians may charge transaction fees on purchases or sales of certain mutual funds,
equities, options and exchange-traded funds. These charges may include mutual fund
transaction fees, postage and handling and miscellaneous fees.
For more details on the brokerage practices, see Item 12 of this brochure.
Prepayment of Client Fees
PDW does not require any prepayment of fees of more than $1,200 per Client and six
months or more in advance.
Fees for financial plans are billed 50% in advance with the balance due upon plan delivery.
Investment management fees are billed monthly in advance.
If the Client cancels after five (5) business days, any unearned fees will be refunded to the
Client, or any unpaid earned fees will be due to PDW.
Fees for ERISA 3(21) and 3(38) services may be billed in advance.
- 6 -
External Compensation for the Sale of Securities to Clients
PDW does not receive any external compensation for the sale of securities to Clients, nor do
any of the investment advisor representatives of PDW.
Item 6: Performance-Based Fees and Side-by-Side Management
Sharing of Capital Gains
Fees are not based on a share of the capital gains or capital appreciation of managed
securities.
PDW does not use a performance-based fee structure because of the conflict of interest.
Performance based compensation may create an incentive for PDW to recommend an
investment that may carry a higher degree of risk to the Client.
Item 7: Types of Clients
Description
PDW generally provides investment advice to individuals, high net worth individuals,
trusts, estates, or charitable organizations, corporations or business entities.
Client relationships vary in scope and length of service.
Account Minimums
PDW does not require a minimum to open an account.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Security analysis methods include fundamental analysis and tactical asset allocation.
Investing in securities involves risk of loss that Clients should be prepared to bear. Past
performance is not a guarantee of future returns.
Fundamental analysis concentrates on factors that determine a company’s value and
expected future earnings. This strategy would normally encourage equity purchases in
stocks that are undervalued or priced below their perceived value. The risk assumed is that
the market will fail to reach expectations of perceived value.
Tactical asset allocation is an active investment strategy that adjusts a portfolio's asset
class weightings according to short term forecasts of expected returns. The strategy is often
considered a moderate active strategy, since managers usually return to the portfolio's
original strategic asset mix when desired short-term profits are achieved. Fundamental-
valuation signals: Metrics include dividend yield, book/market ratio, and P/E ratio, to
determine relative valuation. Another approach is to use the dividend discount model to
determine the required rate of return from market prices and projected dividend growth
rates.
Investment Strategy
The investment strategy for a specific Client is based upon the objectives stated by the
Client during consultations. The Client may change these objectives at any time by
providing written notice to PDW. Each Client executes a Client profile form or similar form
that documents their objectives and their desired investment strategy.
- 7 -
Other strategies may include long-term purchases, short-term purchases and option
writing and option buying (put options) (including covered options, uncovered options or
spreading strategies).
Security Specific Material Risks
All investment programs have certain risks that are borne by the investor. Our investment
approach constantly keeps the risk of loss in mind. Investors face the following investment
risks and should discuss these risks with PDW:
• Market Risk: The prices of securities held by mutual funds in which Clients invest
may decline in response to certain events taking place around the world, including
those directly involving the companies whose securities are owned by a fund;
conditions affecting the general economy; overall market changes; local, regional or
global political, social or economic instability; and currency, interest rate and
commodity price fluctuations. Investors should have a long-term perspective and be
able to tolerate potentially sharp declines in market value.
•
Interest-rate Risk: Fluctuations in interest rates may cause investment prices to
fluctuate. For example, when interest rates rise, yields on existing bonds become
less attractive, causing their market values to decline.
•
Inflation Risk: When any type of inflation is present, a dollar today will buy more
than a dollar next year, because purchasing power is eroding at the rate of inflation.
• Currency Risk: Overseas investments are subject to fluctuations in the value of the
dollar against the currency of the investment’s originating country. This is also
referred to as exchange rate risk.
• Reinvestment Risk: This is the risk that future proceeds from investments may have
to be reinvested at a potentially lower rate of return (i.e. interest rate). This
primarily relates to fixed income securities.
• Liquidity Risk: Liquidity is the ability to readily convert an investment into cash.
Generally, assets are more liquid if many traders are interested in a standardized
product. For example, Treasury Bills are highly liquid, while real estate properties
are not.
• Management Risk: The advisor’s investment approach may fail to produce the
intended results. If the advisor’s assumptions regarding the performance of a
specific asset class or fund are not realized in the expected time frame, the overall
performance of the Client’s portfolio may suffer.
• Equity Risk: Equity securities tend to be more volatile than other investment choices.
The value of an individual stock, mutual fund or ETF can be more volatile than the
market as a whole. This volatility affects the value of the Client’s overall portfolio.
Small- and mid-cap companies are subject to additional risks. Smaller companies
may experience greater volatility, higher failure rates, more limited markets,
product lines, financial resources, and less management experience than larger
companies. Smaller companies may also have a lower trading volume, which may
- 8 -
disproportionately affect their market price, tending to make them fall more in
response to selling pressure than is the case with larger companies.
• Fixed Income Risk: The issuer of a fixed income security may not be able to make
interest and principal payments when due. Generally, the lower the credit rating of a
security, the greater the risk that the issuer will default on its obligation. If a rating
agency gives a debt security a lower rating, the value of the debt security will
decline because investors will demand a higher rate of return. As nominal interest
rates rise, the value of fixed income securities held by a fund is likely to decrease. A
nominal interest rate is the sum of a real interest rate and an expected inflation rate.
• Foreign Securities Risk: Funds in which Clients invest may 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 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.
• Long-term purchases: Long-term investments are those vehicles purchased with the
intension of being held for more than one year. Typically the expectation of the
investment is to increase in value so that it can eventually be sold for a profit. In
addition, there may be an expectation for the investment to provide income. One of
the biggest risks associated with long-term investments is volatility, the fluctuations
in the financial markets that can cause investments to lose value.
• Short-term purchases: Short-term investments are typically held for one year or less.
Generally, there is not a high expectation for a return or an increase in value.
Typically, short-term investments are purchased for the relatively greater degree of
principal protection they are designed to provide. Short-term investment vehicles
may be subject to purchasing power risk — the risk that your investment’s return
will not keep up with inflation.
• Trading risk: Investing involves risk, including possible loss of principal. There is no
assurance that the investment objective of any fund or investment will be achieved.
• Options Trading: The risks involved with trading options are that they are very time
sensitive investments. An options contract is generally a few months. The buyer of
an option could lose his or her entire investment even with a correct prediction
about the direction and magnitude of a particular price change if the price change
does not occur in the relevant time period (i.e., before the option expires).
Additionally, options are less tangible than some other investments. An option is a
“book-entry” only investment without a paper certificate of ownership.
- 9 -
Item 9: Disciplinary Information
Criminal or Civil Actions
PDW and its management have not been involved in any criminal or civil action.
Administrative Enforcement Proceedings
PDW and its management have not been involved in administrative enforcement
proceedings.
Self- Regulatory Organization Enforcement Proceedings
PDW and its management have not been involved in legal or disciplinary events that are
material to a Client’s or prospective Client’s evaluation of PDW or the integrity of its
management.
Item 10: Other Financial Industry Activities and Affiliations
Broker-Dealer or Representative Registration
PDW is not registered as a broker-dealer and no affiliated representatives of PDW are
registered representatives of a broker-dealer.
Futures or Commodity Registration
Neither PDW nor its affiliated representatives are registered or have an application
pending to register as a futures commission merchant, commodity pool operator, or a
commodity trading advisor.
Material Relationships Maintained by this Advisory Business and Conflicts of Interest
PDW does not have any material relationships or other business activities.
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest
PDW does not select or recommend other investment advisors.
Item 11: Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
Code of Ethics Description
include employees and/or
The affiliated persons (affiliated persons
independent
contractors) of PDW have committed to a Code of Ethics (“Code”). The purpose of our Code
is to set forth standards of conduct expected of PDW affiliated persons and addresses
conflicts that may arise. The Code defines acceptable behavior for affiliated persons of
PDW. The Code reflects PDW and its supervised persons’ responsibility to act in the best
interest of their Client.
One area which the Code addresses is when affiliated persons buy or sell securities for
their personal accounts and how to mitigate any conflict of interest with our Clients. We do
not allow any affiliated persons to use non-public material information for their personal
profit or to use internal research for their personal benefit in conflict with the benefit to
our Clients.
PDW’s policy prohibits any person from acting upon or otherwise misusing non-public or
inside information. No advisory representative or other affiliated person, officer or director
of PDW may recommend any transaction in a security or its derivative to advisory Clients
- 10 -
or engage in personal securities transactions for a security or its derivatives if the advisory
representative possesses material, non-public information regarding the security.
PDW’s Code is based on the guiding principle that the interests of the Client are our top
priority. PDW’s officers, directors, advisors, and other affiliated persons have a fiduciary
duty to our Clients and must diligently perform that duty to maintain the complete trust
and confidence of our Clients. When a conflict arises, it is our obligation to put the Client’s
interests over the interests of either affiliated persons or the company.
The Code applies to “access” persons. “Access” persons are affiliated persons who have
access to non-public information regarding any Clients' purchase or sale of securities, or
non-public information regarding the portfolio holdings of any reportable fund, who are
involved in making securities recommendations to Clients, or who have access to such
recommendations that are non-public.
PDW will provide a copy of the Code of Ethics to any Client or prospective Client upon
request.
Investment Recommendations Involving a Material Financial Interest and Conflict of
Interest
PDW and its affiliated persons do not recommend to Clients securities in which we have a
material financial interest.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
Interest
PDW and its affiliated persons may buy or sell securities that are also held by Clients. In
order to mitigate conflicts of interest such as trading ahead of Client transactions, affiliated
persons are required to disclose all reportable securities transactions as well as provide
PDW with copies of their brokerage statements.
The Chief Compliance Officer of PDW is Bill Dudes. He reviews all trades of the affiliated
persons each quarter. The personal trading reviews ensure that the personal trading of
affiliated persons does not affect the markets and that Clients of the firm receive
preferential treatment over associated persons’ transactions.
Client Securities Recommendations or Trades and Concurrent Advisory Firm
Securities Transactions and Conflicts of Interest
PDW does not maintain a firm proprietary trading account and does not have a material
financial interest in any securities being recommended and therefore no conflicts of
interest exist. However, affiliated persons may buy or sell securities at the same time they
buy or sell securities for Clients. In order to mitigate conflicts of interest such as front
running, affiliated persons are required to disclose all reportable securities transactions as
well as provide PDW with copies of their brokerage statements.
The Chief Compliance Officer of PDW is Bill Dudes. He reviews all employee trades each
quarter. The personal trading reviews ensure that the personal trading of affiliated persons
does not affect the markets and that Clients of the firm receive preferential treatment over
associated persons’ transactions.
- 11 -
Item 12: Brokerage Practices
Factors Used to Select Broker-Dealers for Client Transactions
PDW may recommend the use of a particular broker-dealer such as Charles Schwab & Co.,
Inc. or may utilize a broker-dealer of the Client's choosing. PDW will select appropriate
brokers based on a number of factors including but not limited to their relatively low
transaction fees and reporting ability. PDW relies on its broker to provide its execution
services at the best prices available. Lower fees for comparable services may be available
from other sources. Clients pay for any and all custodial fees in addition to the advisory fee
charged by PDW.
• Directed Brokerage
In circumstances where a Client directs PDW to use a certain broker-dealer, PDW
still has a fiduciary duty to its Clients. The following may apply with Directed
Brokerage: PDW's inability to negotiate commissions, to obtain volume discounts,
there may be a disparity in commission charges among Clients and conflicts of
interest arising from brokerage firm referrals. The firm may be unable to achieve
most favorable execution of client transactions, and this practice may cost clients
more money.
• Best Execution
Investment advisors who manage or supervise Client portfolios have a fiduciary
obligation of best execution. The determination of what may constitute best
execution and price in the execution of a securities transaction by a broker involves
a number of considerations and is subjective. Factors affecting brokerage selection
include the overall direct net economic result to the portfolios, the efficiency with
which the transaction is effected, the ability to affect the transaction where a large
block is involved, the operational facilities of the broker-dealer, the value of an
ongoing relationship with such broker and the financial strength and stability of the
broker. The firm does not receive any portion of the trading fees.
• Soft Dollar Arrangements
PDW does not receive soft dollar benefits.
Aggregating Securities Transactions for Client Accounts
PDW is authorized in its discretion to aggregate purchases and sales and other transactions
made for the account with purchases and sales and transactions in the same securities for
other Clients of PDW. All Clients participating in the aggregated order shall receive an
average share price with all other transaction costs shared on a pro-rated basis.
Item 13: Review of Accounts
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory
Persons Involved
Account reviews are performed quarterly by the Chief Compliance Officer of PDW. Account
reviews are performed more frequently when market conditions dictate. Reviews of Client
accounts include, but are not limited to, a review of Client documented risk tolerance,
adherence to account objectives, investment time horizon, and suitability criteria,
- 12 -
reviewing target bans of each asset class to identify if there is an opportunity for
rebalancing, and reviewing accounts for tax loss harvesting opportunities.
Financial plans generated are updated as requested by the Client and pursuant to a new or
amended agreement, PDW suggests updating at least annually.
Review of Client Accounts on Non-Periodic Basis
Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws,
new investment information, and changes in a Client's own situation.
Content of Client Provided Reports and Frequency
Clients receive written account statements no less than monthly for managed accounts.
Account statements are issued by PDW’s custodian. Client receives confirmations of each
transaction in account from Custodian and an additional statement during any month in
which a transaction occurs. Performance reports will be provided by PDW at least
annually to Clients with assets under management, exclusive of Assets Held Away.
Item 14: Client Referrals and Other Compensation
Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts
of Interest
PDW does not receive any economic benefits from external sources.
Advisory Firm Payments for Client Referrals
PDW does not compensate for Client referrals.
Item 15: Custody
Account Statements
All assets are held at qualified custodians, which means the custodians provide account
statements directly to Clients at their address of record at least quarterly.
PDW is deemed to have custody solely because advisory fees are directly deducted from
Client’s accounts by the custodian on behalf of PDW.
Item 16: Investment Discretion
Discretionary Authority for Trading
PDW requires discretionary authority to manage securities accounts on behalf of Clients.
PDW has the authority to determine, without obtaining specific Client consent, the
securities to be bought or sold, and the amount of the securities to be bought or sold.
PDW allows Client’s to place certain restrictions, as outlined in the Client’s Investment
Policy Statement or similar document. Such restrictions could include only allowing
purchases of socially conscious investments. These restrictions must be provided to PDW
in writing.
The Client approves the custodian to be used and the commission rates paid to the
custodian. PDW does not receive any portion of the transaction fees or commissions paid
by the Client to the custodian.
- 13 -
Item 17: Voting Client Securities
Proxy Votes
PDW does not vote proxies on securities. Clients are expected to vote their own proxies.
The Client will receive their proxies directly from the custodian of their account or from a
transfer agent.
When assistance on voting proxies is requested, PDW will provide recommendations to the
Client. If a conflict of interest exists, it will be disclosed to the Client.
Item 18: Financial Information
Balance Sheet
A balance sheet is not required to be provided because PDW does not serve as a custodian
for Client funds or securities and PDW does not require prepayment of fees of more than
$1,200 per Client and six months or more in advance.
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet
Commitments to Clients
PDW has no condition that is reasonably likely to impair our ability to meet contractual
commitments to our Clients.
Bankruptcy Petitions during the Past Ten Years
PDW has not had any bankruptcy petitions in the last ten years.
- 14 -
Item 1 Cover Page
S U P E R V I S E D P E R S O N B R O C H U R E
F O R M A D V P A R T 2 B
William “Bill” Dudes, ChFC®
Pleasantdale Wealth
Management, LLC
Office Address:
7 Stonebriar Lane
Hackettstown, NJ 07840
Mailing Address:
PO Box 513
Hackettstown, NJ 07840
Tel: 908-914-1572
dudes@pdwmanage.com
This brochure supplement provides information about Bill Dudes and supplements the
Pleasantdale Wealth Management, LLC brochure. You should have received a copy of that
brochure. Please contact Bill Dudes if you did not receive the brochure or if you have any
questions about the contents of this supplement.
APRIL 1, 2026
Additional information about Bill Dudes (CRD #1300217) is available on the SEC’s website at
www.adviserinfo.sec.gov.
- 15 -
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Principal Executive Officer – Bill Dudes, ChFC®
• Year of birth: 1962
Item 2 - Educational Background and Business Experience
Educational Background:
• Seton Hall University; Bachelor of Science in Accounting; 1984
Business Experience:
• Pleasantdale Wealth Management, LLC; Investment Advisor Representative;
04/2019 – Present
• Pleasantdale Wealth Management, LLC; Managing Member; 01/2018 – Present
• Dudes Boys LLC; Managing Member; 01/2013 – 12/2019
• William Dudes, Sole Proprietor; Insurance Agent; 01/1985 – 05/2021
• American Portfolios Advisors, Inc; Investment Advisor Representative; 08/2008 –
07/2019
• American Portfolios Financial services, Inc; Registered Representative; 07/2008 –
07/2019
Professional Certifications
Employees have earned certifications and credentials that are required to be explained in
further detail.
Chartered Financial Consultant® (ChFC®): Chartered Financial Consultant (ChFC®) is a
designation issued by the American College. ChFC® designation requirements:
• Complete ChFC® coursework within five years from the date of initial enrollment.
• Pass the exams for all required elective courses. A minimum score of 70% must be
achieved to pass.
• Meet the experience requirements: Three years of full-time business experience
within the five years preceding the date of the award. An undergraduate or graduate
degree from an accredited educational institution qualifies as one year of business
experience.
• Take the Professional Ethics Pledge.
• When you achieve your ChFC® designation, you must earn 30 hours of continuing
education credit every two years.
Item 3 - Disciplinary Information
Criminal or Civil Action: None to report.
Administrative Proceeding: None to report.
Self-Regulatory Proceeding: None to report.
Item 4 - Other Business Activities Engaged In
Managing Member Bill Dudes doesn’t have any other business activities.
- 16 -
Item 5 - Additional Compensation
Bill Dudes does not receive any additional compensation for performing advisory services
other than what is disclosed in Item 5 of Part 2A. He does not receive any performance-
based fees.
Item 6 - Supervision
Bill Dudes is the Chief Compliance Officer of PDW. He is responsible for all supervision and
formulation and monitoring of investment advice offered to Clients. He will adhere to the
policies and procedures as described in the firm’s Compliance Manual. He can be reached at
dudes@pdwmanage.com or 908-914-1572.
- 17 -
I T E M 1 C O V E R P A G E
S U P E R V I S E D P E R S O N B R O C H U R E
F O R M A D V P A R T 2 B
Brian Dudes
Pleasantdale Wealth
Management, LLC
Office Address:
7 Stonebriar Lane
Hackettstown, NJ 07840
Mailing Address:
PO Box 513
Hackettstown, NJ 07840
Tel: 908-914-1572
bdudes@pdwmanage.com
This brochure supplement provides information about Brian Dudes and supplements the
Pleasantdale Wealth Management, LLC brochure. You should have received a copy of that
brochure. Please contact Brian Dudes if you did not receive the brochure or if you have any
questions about the contents of this supplement.
APRIL 1, 2026
Additional information about Brian Dudes (CRD #6416487) is available on the SEC’s website at
www.adviserinfo.sec.gov.
- 18 -
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Supervised Person – Brian Dudes
• Year of birth: 1991
Item 2 - Educational Background and Business Experience
Educational Background:
• Bloomsburg University; Bachelor of Science in Business Administration-Finance;
2014
Business Experience:
• Pleasantdale Wealth Management, LLC; Investment Advisor Representative;
10/2021 - Present
• Pleasantdale Wealth Management, LLC; Assistant; 07/2019 - Present
• American Portfolios Financial Services, Inc.; Assistant; 05/2014 – 07/2019
• Student; 08/2010 – 05/2014
Item 3 - Disciplinary Information
A. Brian Dudes has never been involved in a criminal or civil action in a domestic, foreign
or military court of competent jurisdiction for which he:
1. Was convicted of, or pled guilty or nolo contender (“no contest”) to (a) any felony;
(b) misdemeanor that involved investments or an investment-related business,
fraud, false statement or omissions, wrongful taking of property, bribery, perjury,
counterfeiting, or extortion; or (c) a conspiracy to commit any of these offenses;
2. Is the named subject of a pending criminal proceeding that involves an investment-
related business, fraud, false statements or omissions, wrongful taking of property,
bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of
these offenses;
3. Was found to have been involved in a violation of an investment-related statute or
regulation; or
4. Was the subject of any order, judgement or decree permanently or temporarily
enjoining, or otherwise limiting, him from engaging in any investment related
activity, or from violating any investment-related statute, rule, or order.
B. Brian Dudes never had an administrative proceeding before the SEC, any other federal
regulatory agency, any state regulatory agency, or any foreign financial regulatory
authority in which he:
1. Was found to have caused an investment-related business to lose its authorization
to do business; or the subject of an order by the agency or authority;
2. Was found to have been involved in a violation of an investment-related statute or
regulation or was the subject of an order by the agency or authority
(a)denying, suspending or revoking the authorization of the supervised person to
act in an investment-related business; (b) barring or suspending his association
with an investment-related business; (c) otherwise significantly limiting his
- 19 -
investment-related activities; or (d) imposing a civil money penalty of more than
$2,500 on him.
C. Brian Dudes has never been the subject of a self-regulatory organization (SRO)
proceeding in which he:
1. Was found to have caused an investment-related business to lose its authorization
to do business; or
limited
2. Was found to have been involved in a violation of the SRO’s rules and was: (a)
barred or suspended from membership or from association with other members, or
was expelled
from
from membership; (b) otherwise significantly
investment-related activities; or (c) fined more than $2,500.
D. Brian Dudes has not been involved in Any other hearing or formal adjudication in
which a professional attainment, designation, or license of the supervised person was
revoked or suspended because of a violation of rules relating to professional conduct.
Item 4 - Other Business Activities
Brian Dudes does not have any other business activities; therefore this represents no
conflicts of interest.
Item 5 - Additional Compensation
Brian Dudes receives no additional compensation in any capacity, nor does he receive any
performance based fees.
Item 6 - Supervision
face-to-face and phone
William “Bill” Dudes is the Chief Compliance Officer of PDW. Bill Dudes reviews Brian
Dudes’ work through Client account reviews and quarterly personal transaction reports, as
interactions. Bill Dudes can be reached at
well as
dudes@pdwmange.com or 908-914-1572.
- 20 -
I T E M 1 C O V E R P A G E
S U P E R V I S E D P E R S O N B R O C H U R E
F O R M A D V P A R T 2 B
Michael A. Dudes
Pleasantdale Wealth
Management, LLC
Office Address:
7 Stonebriar Lane
Hackettstown, NJ 07840
Mailing Address:
PO Box 513
Hackettstown, NJ 07840
Tel: 908-914-1572
mdudes@pdwmanage.com
This brochure supplement provides information about Michael Dudes and supplements the
Pleasantdale Wealth Management, LLC brochure. You should have received a copy of that brochure.
Please contact Michael Dudes if you did not receive the brochure or if you have any questions about the
contents of this supplement.
APRIL 1, 2026
Additional information about Michael A. Dudes (CRD #6702742) is available on the SEC’s website at
www.adviserinfo.sec.gov.
- 21 -
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Supervised Person – Michael Dudes
• Year of birth: 1994
Item 2 - Educational Background and Business Experience
Educational Background:
• Kutztown University; Bachelor of Science in Business Administration-Finance; 2016
Business Experience:
• Pleasantdale Wealth Management, LLC; Investment Advisor Representative;
05/2024 – Present
• Pleasantdale Wealth Management, LLC; Assistant; 07/2019 - Present
• American Portfolios; Clerical Services; 05/2016 – 07/2019
• Full-Time Student; 08/2012 – 05/2016
Item 3 - Disciplinary Information
E. Michael Dudes has never been involved in a criminal or civil action in a domestic,
foreign or military court of competent jurisdiction for which he:
5. Was convicted of, or pled guilty or nolo contender (“no contest”) to (a) any felony;
(b) misdemeanor that involved investments or an investment-related business,
fraud, false statement or omissions, wrongful taking of property, bribery, perjury,
counterfeiting, or extortion; or (c) a conspiracy to commit any of these offenses;
6. Is the named subject of a pending criminal proceeding that involves an investment-
related business, fraud, false statements or omissions, wrongful taking of property,
bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of
these offenses;
7. Was found to have been involved in a violation of an investment-related statute or
regulation; or
8. Was the subject of any order, judgement or decree permanently or temporarily
enjoining, or otherwise limiting, him from engaging in any investment related
activity, or from violating any investment-related statute, rule, or order.
F. Michael Dudes never had an administrative proceeding before the SEC, any other
federal regulatory agency, any state regulatory agency, or any foreign financial
regulatory authority in which he:
3. Was found to have caused an investment-related business to lose its authorization
to do business; or the subject of an order by the agency or authority;
4. Was found to have been involved in a violation of an investment-related statute or
regulation or was the subject of an order by the agency or authority
(a)denying, suspending or revoking the authorization of the supervised person to
act in an investment-related business; (b) barring or suspending his association
with an investment-related business; (c) otherwise significantly limiting his
investment-related activities; or (d) imposing a civil money penalty of more than
$2,500 on him.
- 22 -
G. Michael Dudes has never been the subject of a self-regulatory organization (SRO)
proceeding in which he:
3. Was found to have caused an investment-related business to lose its authorization
to do business; or
limited
4. Was found to have been involved in a violation of the SRO’s rules and was: (a)
barred or suspended from membership or from association with other members, or
was expelled
from
from membership; (b) otherwise significantly
investment-related activities; or (c) fined more than $2,500.
H. Michael Dudes has not been involved in Any other hearing or formal adjudication in
which a professional attainment, designation, or license of the supervised person was
revoked or suspended because of a violation of rules relating to professional conduct.
Item 4 - Other Business Activities
Michael Dudes does not have any other business activities; therefore this represents no
conflicts of interest.
Item 5 - Additional Compensation
Michael Dudes receives no additional compensation in any capacity, nor does he receive
any performance based fees.
Item 6 - Supervision
face-to-face and phone
William “Bill” Dudes is the Chief Compliance Officer of PDW. Bill Dudes reviews Michael
Dudes’ work through Client account reviews and quarterly personal transaction reports, as
well as
interactions. Bill Dudes can be reached at
dudes@pdwmange.com or 908-914-1572.
- 23 -