Overview
Assets Under Management: $207 million
Headquarters: PROVIDENCE, RI
High-Net-Worth Clients: 69
Average Client Assets: $2 million
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Fee Structure
Primary Fee Schedule (FORM ADV PART 2A)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $500,000 | 1.50% |
| $500,001 | $1,000,000 | 1.25% |
| $1,000,001 | $2,000,000 | 1.00% |
| $2,000,001 | $5,000,000 | 0.85% |
| $5,000,001 | $10,000,000 | 0.50% |
| $10,000,001 | and above | 0.35% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $13,750 | 1.38% |
| $5 million | $49,250 | 0.98% |
| $10 million | $74,250 | 0.74% |
| $50 million | $214,250 | 0.43% |
| $100 million | $389,250 | 0.39% |
Clients
Number of High-Net-Worth Clients: 69
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 52.27
Average High-Net-Worth Client Assets: $2 million
Total Client Accounts: 935
Discretionary Accounts: 935
Regulatory Filings
CRD Number: 332618
Last Filing Date: 2025-02-14 00:00:00
Website: https://plumpointewealth.com
Form ADV Documents
Primary Brochure: FORM ADV PART 2A (2025-10-24)
View Document Text
Item 1: Cover Page
Form ADV Part 2A – Firm Brochure
225 Dyer Street. 3rd Floor
Providence, RI 02903
401-228-8258
Dated October 3, 2025
This Brochure provides information about the qualifications and business practices of Plum Pointe Wealth
Management, LLC, “Plum Pointe”. If you have any questions about the contents of this Brochure, please contact
us at 401-228-8258. 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.
Plum Pointe Wealth Management, LLC is registered as an investment adviser with the U.S. Securities and
Exchange Commission. Registration of an investment adviser does not imply any level of skill or training.
Additional information about Plum Pointe is available on the SEC’s website at www.adviserinfo.sec.gov which
can be found using the firm’s identification number 332618.
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Since the first filing of the Form ADV Part 2A for Plum Pointe, dated February 14, 2025, the following
material changes have occurred:
Item 2: Material Changes
Item 10 –John Williams is Managing Member and CCO of Clarity Retirement & Wealth, LLC. Please
note, this item only discusses changes we consider material and not all changes made.
Item 3: Table of Contents
Contents
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 ................................................................................................................. 6
Item 6: Performance-Based Fees and Side-By-Side Management ............................................................. 8
Item 7: Types of Clients ............................................................................................................................... 8
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ....................................................... 8
Item 9: Disciplinary Information ............................................................................................................... 11
Item 10: Other Financial Industry Activities and Affiliations .................................................................... 12
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............. 12
Item 12: Brokerage Practices .................................................................................................................... 14
Item 13: Review of Accounts .................................................................................................................... 15
Item 14: Client Referrals and Other Compensation ................................................................................. 15
Item 15: Custody ....................................................................................................................................... 15
Item 16: Investment Discretion ................................................................................................................ 16
Item 17: Voting Client Securities .............................................................................................................. 16
Item 18: Financial Information ................................................................................................................. 16
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Description of Advisory Firm
Item 4: Advisory Business
Plum Pointe Wealth Management, LLC is registered as an investment adviser with the U.S. Securities and
Exchange Commission. We were founded in August 2024. Plum Point Wealth Management, Ltd. and
John Williams III, are the principal owners of Plum Pointe. As of February 12, 2025, Plum Pointe Manages
$206,679,179 on a discretionary basis.
Types of Advisory Services
Investment Management Services
We are in the business of managing individually tailored investment portfolios. Our firm provides
continuous advice to a client regarding the investment of client funds based on the individual needs of
the client. Through personal discussions in which goals and objectives based on a client's particular
circumstances are established, we develop a client's personal investment policy or an investment plan
with an asset allocation target and create and manage a portfolio based on that policy and allocation
target. During our data-gathering process, we determine the client’s individual objectives, time horizons,
risk tolerance, and liquidity needs. We may also review and discuss a client’s prior investment history,
as well as family composition and background.
Account supervision is guided by the stated objectives of the client (e.g., maximum capital appreciation,
growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable
restrictions on investing in certain securities, types of securities, or industry sectors. Fees pertaining to
this service are outlined in Item 5 of this brochure.
Wealth Management Advisory Service
Our Inclusive Investment Advisory Service combines both our Investment Management Services, as
described above, and financial planning as described below.
Our financial planning is a comprehensive evaluation of a client’s current and future financial state by
using currently known variables to predict future cash flows, asset values and withdrawal plans. The key
defining aspect of financial planning is that through the financial planning process, all questions,
information and analysis will be considered as they impact and are impacted by the entire financial and
life situation of the client. Clients purchasing this service will receive a written or an electronic report,
providing the client with a detailed financial plan designed to achieve his or her stated financial goals
and objectives.
The client always has the right to decide whether or not to act upon our recommendations. If the client
elects to act on any of the recommendations, the client always has the right to affect the transactions
through anyone of their choosing.
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In general, the financial plan will address any or all of the following areas of concern. The client and
advisor will work together to select the specific areas to cover. These areas may include, but are not
limited to, the following:
• Business Planning: We provide consulting services for clients who currently operate their own
business, are considering starting a business, or are planning for an exit from their current
business. Under this type of engagement, we work with you to assess your current situation,
identify your objectives, and develop a plan aimed at achieving your goals.
• Cash Flow and Debt Management: We will conduct a review of your income and expenses to
determine your current surplus or deficit along with advice on prioritizing how any surplus should
be used or how to reduce expenses if they exceed your income. Advice may also be provided on
which debts to pay off first based on factors such as the interest rate of the debt and any income
tax ramifications. We may also recommend what we believe to be an appropriate cash reserve
that should be considered for emergencies and other financial goals, along with a review of
accounts (such as money market funds) for such reserves, plus strategies to save desired
amounts.
• College Savings: Includes projecting the amount that will be needed to achieve college or other
post-secondary education funding goals, along with advice on ways for you to save the desired
amount. Recommendations as to savings strategies are included, and, if needed, we will review
your financial picture as it relates to eligibility for financial aid or the best way to contribute to
grandchildren (if appropriate).
• Employee Benefits Optimization: We will provide review and analysis as to whether you, as an
employee, are taking the maximum advantage possible of your employee benefits. If you are a
business owner, we will consider and/or recommend the various benefit programs that can be
structured to meet both business and personal retirement goals.
• Estate Planning: This usually includes an analysis of your exposure to estate taxes and your
current estate plan, which may include whether you have a will, powers of attorney, trusts and
other related documents. Our advice also typically includes ways for you to minimize or avoid
future estate taxes by implementing appropriate estate planning strategies such as the use of
applicable trusts.
We always recommend that you consult with a qualified attorney when you initiate, update, or
complete estate planning activities. We may provide you with contact information for attorneys
who specialize in estate planning when you wish to hire an attorney for such purposes. From
time-to-time, we will participate in meetings or phone calls between you and your attorney with
your approval or request.
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• Financial Goals: We will help clients identify financial goals and develop a plan to reach them.
We will identify what you plan to accomplish, what resources you will need to make it happen,
how much time you will need to reach the goal, and how much you should budget for your goal.
•
Insurance: Review of existing policies to ensure proper coverage for life, health, disability, long-
term care, liability, home and automobile.
•
Investment Analysis: This may involve developing an asset allocation strategy to meet clients’
financial goals and risk tolerance, providing information on investment vehicles and strategies,
reviewing employee stock options, as well as assisting you in establishing your own investment
account at a selected broker/dealer or custodian. The strategies and types of investments we
may recommend are further discussed in Item 8 of this brochure.
• Retirement Planning: Our retirement planning services typically include projections of your
likelihood of achieving your financial goals, typically focusing on financial independence as the
primary objective. For situations where projections show less than the desired results, we may
make recommendations, including those that may impact the original projections by adjusting
certain variables (e.g., working longer, saving more, spending less, taking more risk with
investments).
If you are near retirement or already retired, advice may be given on appropriate distribution
strategies to minimize the likelihood of running out of money or having to adversely alter
spending during your retirement years.
• Risk Management: A risk management review includes an analysis of your exposure to major
risks that could have a significantly adverse effect on your financial picture, such as premature
death, disability, property and casualty losses, or the need for long-term care planning. Advice
may be provided on ways to minimize such risks and about weighing the costs of purchasing
insurance versus the benefits of doing so and, likewise, the potential cost of not purchasing
insurance (“self-insuring”).
• Tax Planning Strategies: Advice may include ways to minimize current and future income taxes
as a part of your overall financial planning picture. For example, we may make recommendations
on which type of account(s) or specific investments should be owned based in part on their “tax
efficiency,” with consideration that there is always a possibility of future changes to federal, state
or local tax laws and rates that may affect your situation.
We recommend that you consult with a qualified tax professional before initiating any tax
planning strategy, and we may provide you with contact information for accountants or attorneys
who specialize in this area if you wish to hire someone for such purposes. We will participate in
meetings or phone calls between you and your tax professional with your approval.
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Client Tailored Services and Client Imposed Restrictions
We offer the same suite of services to all of our clients. However, specific client financial plans and their
implementation are dependent upon a client Investment Policy Statement, which outlines each client’s
current situation (income, tax levels, and risk tolerance levels) and is used to construct a client specific
plan to aid in the selection of a portfolio that matches restrictions, needs, and targets.
Wrap Fee Programs
We do not participate in wrap fee programs.
Item 5: Fees and Compensation
Please note, unless a client has received the firm’s disclosure brochure at least 48 hours prior to signing
the investment advisory contract, the investment advisory contract may be terminated by the client
within five (5) business days of signing the contract without incurring any advisory fees and without
penalty. How we are paid depends on the type of advisory service we are performing. Please review the
fee and compensation information below.
Wealth Management Advisory Services
Our standard advisory fee is based on the market value of the assets under management and is
calculated as follows:
Account Value
Annual Advisory Fee*
1.50%
First $500,000
1.25
Next $500,000
1.00%
Next $1,000,000
0.85%
Next $3,000,000
0.50%
Next $5,000,000
0.35%
$10,000,001 and Above
*The annual advisory fee includes financial planning.
The annual fees are negotiable and are pro-rated and paid in arrears monthly. The advisory fee is a tiered
fee and is calculated by assessing the percentage rates using the predefined levels of assets as shown in
the above chart, resulting in a combined weighted fee. For example, an account valued at $2,500,000
would pay an effective fee of 1.01% with the annual fee of $25,250.00. The monthly fee is determined
by the following calculation: ($1,000,000 x 1.25%) + ($1,000,000 x 1.00%) + ($500,000 x 0.85)) ÷ 12 =
$2,104.17. No increase in the annual fee shall be effective without agreement from the client by signing
a new agreement or amendment to their current advisory agreement.
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Advisory fees are directly debited from client accounts. Accounts initiated or terminated during a
calendar quarter will be charged a pro-rated fee based on the amount of time remaining in the billing
period. An account may be terminated with written notice at least 15 calendar days in advance. Since
fees are paid in arrears, no rebate will be needed upon termination of the account.
Investment Management Services
Our standard advisory fee is based on the market value of the assets under management and is
calculated as follows:
Account Value
Annual Advisory Fee
0.50%
First $3,000,000
0.25%
Next $2,000,000
0.20%
Next $10,000,000
0.15%
$15,000,001 and Above
The annual fees are negotiable and are pro-rated and paid in arrears on a monthly basis. The advisory
fee is a tiered fee and is calculated by assessing the percentage rates using the predefined levels of assets
as shown in the above chart, resulting in a combined weighted fee. For example, an account valued at
$5,000,000 would pay an effective fee of 0.37% with the annual fee of $18,500.00. The monthly fee is
determined by the following calculation: (($3,000,000 x 0.50%) + ($2,000,000 x 0.25%) + ÷ 12 =
$1,541.67. No increase in the annual fee shall be effective without agreement from the client by signing
a new agreement or amendment to their current advisory agreement.
Advisory fees are directly debited from client accounts. Accounts initiated or terminated during a
calendar quarter will be charged a pro-rated fee based on the amount of time remaining in the billing
period. An account may be terminated with written notice at least 15 calendar days in advance. Since
fees are paid in arrears, no rebate will be needed upon termination of the account.
Financial Planning Service
Our financial planning services are included in our Wealth Management Advisory Service. Clients
desiring financial planning services are welcome to shift to Wealth Management Advisory Service.
Other Types of Fees and Expenses
Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses
that may be incurred by the client. Clients may incur certain charges imposed by custodians, brokers,
and other third parties such as custodial fees, deferred sales charges, odd-lot differentials, transfer taxes,
wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities
transactions. Mutual fund and exchange traded funds also charge internal management fees, which are
disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to
our fee, and we shall not receive any portion of these commissions, fees, and costs.
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Item 12 further describes the factors that we consider in selecting or recommending broker-dealers for
client’s transactions and determining the reasonableness of their compensation (e.g., commissions).
We do not accept compensation for the sale of securities or other investment products including asset-
based sales charges or service fees from the sale of mutual funds.
We do not offer performance-based fees.
Item 6: Performance-Based Fees and Side-
By-Side Management
We provide financial planning and portfolio management services to individuals, high net-worth
individuals, pension and profiting sharing plans and charitable organizations.
Item 7: Types of Clients
Our minimum account size requirement is $50,000.00 for clients requesting Investment Advisory only.
Our minimum account size requirement for our Wealth Management Advisory service is $500,000.00.
Our minimum account requirements can be waived at the sole discretion of Plum Pointe.
Our primary methods of investment analysis are fundamental, technical and cyclical analysis.
Item 8: Methods of Analysis, Investment
Strategies and Risk of Loss
Fundamental analysis involves analyzing individual companies and their industry groups, such as a
company’s financial statements, details regarding the company’s product line, the experience, and
expertise of the company’s management, and the outlook for the company’s industry. The resulting data
is used to measure the true value of the company’s stock compared to the current market value. The
risk of fundamental analysis is that information obtained may be incorrect and the analysis may not
provide an accurate estimate of earnings, which may be the basis for a stock’s value. If securities prices
adjust rapidly to new information, utilizing fundamental analysis may not result in favorable
performance.
Technical analysis involves using chart patterns, momentum, volume, and relative strength in an effort
to pick sectors that may outperform market indices. However, there is no assurance of accurate
forecasts or that trends will develop in the markets we follow. In the past, there have been periods
without discernible trends and similar periods will presumably occur in the future. Even where major
trends develop, outside factors like government intervention could potentially shorten them.
Furthermore, one limitation of technical analysis is that it requires price movement data, which can
translate into price trends sufficient to dictate a market entry or exit decision. In a trendless or erratic
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market, a technical method may fail to identify trends requiring action. In addition, technical methods
may overreact to minor price movements, establishing positions contrary to overall price trends, which
may result in losses. Finally, a technical trading method may under perform other trading methods when
fundamental factors dominate price moves within a given market.
Cyclical analysis is a type of technical analysis that involves evaluating recurring price patterns and
trends based upon business cycles. Economic/business cycles may not be predictable and may have
many fluctuations between long term expansions and contractions. The lengths of economic cycles may
be difficult to predict with accuracy and therefore the risk of cyclical analysis is the difficulty in predicting
economic trends and consequently the changing value of securities that would be affected by these
changing trends.
Investment Management Strategies
We recognize that each client’s needs and goals are different; subsequently portfolio strategies and
underlying investment vehicles may vary. Generally, our investment advice is based on Modern Portfolio
Theory and the belief that proper diversification and risk management will provide an investor client
with a stable and consistent return over time. The practice of Modern Portfolio Theory does not employ
market timing or stock selection methods of investing but rather a long term buy-and-hold strategy with
periodic rebalancing of the account to maintain desired risk levels. For other investors, we may choose
to employ a Core + Satellite Strategy: blending passive (or index) and active investing, where passive
investments are used as the basis or “core” of a portfolio and actively- managed investments are added
as “satellite” positions. For example, the core of a portfolio may be built with low-cost index funds or
ETFs, and satellite holdings would include active holdings believed capable of adding value beyond a
stated benchmark over a full market cycle. The core represents the majority of the portfolio and the
remainder of the portfolio employs holdings that take a shorter duration to assist in the over-or-under
allocation to specific sectors, regions, assets classes, etc.
Material Risks Involved
All investing strategies we offer involve risk and may result in a loss of your original investment which
you should be prepared to bear. Many of these risks apply equally to stocks, bonds, commodities and
any other investment or security. Material risks associated with our investment strategies are listed
below.
Market Risk: Market risk involves the possibility that an investment’s current market value will fall
because of a general market decline, reducing the value of the investment regardless of the operational
success of the issuer’s operations or its financial condition.
Strategy Risk: The Adviser’s investment strategies and/or investment techniques may not work as
intended.
Small and Medium Cap Company Risk: Securities of companies with small and medium market
capitalizations are often more volatile and less liquid than investments in larger companies. Small and
medium cap companies may face a greater risk of business failure, which could increase the volatility of
the client’s portfolio.
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Turnover Risk: At times, the strategy may have a portfolio turnover rate that is higher than other
strategies. A high portfolio turnover would result in correspondingly greater brokerage commission
expenses and may result in the distribution of additional capital gains for tax purposes. These factors
may negatively affect the account’s performance.
Limited markets: Certain securities may be less liquid (harder to sell or buy) and their prices may at times
be more volatile than at other times. Under certain market conditions we may be unable to sell or
liquidate investments at prices we consider reasonable or favorable or find buyers at any price.
Concentration Risk: Certain investment strategies focus on particular asset-classes, industries, sectors
or types of investment. From time to time these strategies may be subject to greater risks of adverse
developments in such areas of focus than a strategy that is more broadly diversified across a wider
variety of investments.
Interest Rate Risk: Bond (fixed income) prices generally fall when interest rates rise, and the value may
fall below par value or the principal investment. The opposite is also generally true: bond prices generally
rise when interest rates fall. In general, fixed income securities with longer maturities are more sensitive
to these price changes. Most other investments are also sensitive to the level and direction of interest
rates.
Legal or Legislative Risk: Legislative changes or Court rulings may impact the value of investments, or
the securities’ claim on the issuer’s assets and finances.
Inflation: Inflation may erode the buying-power of your investment portfolio, even if the dollar value of
your investments remains the same.
Risks Associated with Securities
Apart from the general risks outlined above which apply to all types of investments, specific securities
may have other risks.
Commercial Paper is, in most cases, an unsecured promissory note that is issued with a maturity of 270
days or less. Being unsecured the risk to the investor is that the issuer may default.
Common stocks may go up and down in price quite dramatically, and in the event of an issuer’s
bankruptcy or restructuring could lose all value. A slower-growth or recessionary economic environment
could have an adverse effect on the price of all stocks.
Corporate Bonds are debt securities to borrow money. Generally, issuers pay investors periodic interest
and repay the amount borrowed either periodically during the life of the security and/or at maturity.
Alternatively, investors can purchase other debt securities, such as zero coupon bonds, which do not pay
current interest, but rather are priced at a discount from their face values and their values accrete over
time to face value at maturity. The market prices of debt securities fluctuate depending on such factors
as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when
interest rates rise and increase when interest rates fall. The longer the time to a bond’s maturity, the
greater its interest rate risk.
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Bank Obligations including bonds and certificates of deposit may be vulnerable to setbacks or panics in
the banking industry. Banks and other financial institutions are greatly affected by interest rates and may
be adversely affected by downturns in the U.S. and foreign economies or changes in banking regulations.
Municipal Bonds are debt obligations generally issued to obtain funds for various public purposes,
including the construction of public facilities. Municipal bonds pay a lower rate of return than most other
types of bonds. However, because of a municipal bond’s tax-favored status, investors should compare
the relative after-tax return to the after-tax return of other bonds, depending on the investor’s tax
bracket. Investing in municipal bonds carries the same general risks as investing in bonds in general.
Those risks include interest rate risk, reinvestment risk, inflation risk, market risk, call or redemption risk,
credit risk, and liquidity and valuation risk.
Options and other derivatives carry many unique risks, including time-sensitivity, and can result in the
complete loss of principal. While covered call writing does provide a partial hedge to the stock against
which the call is written, the hedge is limited to the amount of cash flow received when writing the
option. When selling covered calls, there is a risk the underlying position may be called away at a price
lower than the current market price.
Exchange Traded Funds prices may vary significantly from the Net Asset Value due to market conditions.
Certain Exchange Traded Funds may not track underlying benchmarks as expected.
Investment Companies Risk. When a client invests in open end mutual funds or ETFs, the client indirectly
bears its proportionate share of any fees and expenses payable directly by those funds. Therefore, the
client will incur higher expenses, many of which may be duplicative. In addition, the client’s overall
portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment
practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following
risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value; (ii) the
ETF may employ an investment strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares
may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed
from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases
in stock prices) halts stock trading generally. The Adviser has no control over the risks taken by the
underlying funds in which clients invest.
Criminal or Civil Actions
Item 9: Disciplinary Information
Plum Pointe and its management have not been involved in any criminal or civil action.
Administrative Enforcement Proceedings
Plum Pointe and its management have not been involved in administrative enforcement proceedings.
Self-Regulatory Organization Enforcement Proceedings
Plum Pointe 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 Plum Pointe or the integrity of its management.
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Item 10: Other Financial Industry Activities
and Affiliations
John Williams is a Registered Representatives of Purshe Kaplan Sterling Investments (PKS). In his capacity
as a Registered Representative of PKS, he receives commissions or other compensation for transactions.
A conflict of interest may exist when, as a PKS Registered Representative, Mr. Williams receives
commissions or additional compensation when they recommend transactions to clients and these
commissions do not offset any advisory fees paid to Plum Pointe.
John Williams is licensed as an investment adviser representative of Clarity Retirement & Wealth, LLC
(CRD #337718), a registered investment adviser. As such, John Williams, in his separate capacity as an
investment adviser representative, can provide advisory services apart from Plum Pointe, for which he
will receive separate and customary compensation.
No Plum Pointe employee is registered, or have an application pending to register, as a futures
commission merchant, commodity pool operator or a commodity trading advisor.
Brian Dunckley is President and Managing Member of Plum Pointe Advisors, LLC, an insurance agency.
Associated persons of Plum Pointe are licensed to sell life and health insurance and may engage in
product sales with our clients, for which they will receive additional compensation. Any commissions
received through life or health insurance sales do not offset advisory fees the client may pay for advisory
services under Plum Pointe. Clients are free to use any party of their choosing for their insurance needs,
and are not required to use Plum Pointe Advisors, LLC.
Plum Pointe only receives compensation directly from clients. We do not receive compensation from
any outside source. We do not have any conflicts of interest with any outside party.
Brian Dunckley is the managing member of Saunderstown Partners, LLC, an exempt reporting adviser.
Item 11: Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading
As a fiduciary, our firm and its associates have a duty of utmost good faith to act solely in the best
interests of each client. Our clients entrust us with their funds and personal information, which in turn
places a high standard on our conduct and integrity. Our fiduciary duty is a core aspect of our Code of
Ethics and represents the expected basis of all of our dealings. The firm also adheres to the Code of Ethics
and Professional Responsibility adopted by the CFP® Board of Standards Inc. and accepts the obligation
not only to comply with the mandates and requirements of all applicable laws and regulations but also
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to take responsibility to act in an ethical and professionally responsible manner in all professional
services and activities.
Code of Ethics Description
This code does not attempt to identify all possible conflicts of interest, and literal compliance with each
of its specific provisions will not shield associated persons from liability for personal trading or other
conduct that violates a fiduciary duty to advisory clients. A summary of the Code of Ethics' Principles is
outlined below.
•
Integrity - Associated persons shall offer and provide professional services with integrity.
•
Objectivity - Associated persons shall be objective in providing professional services to clients.
•
Competence - Associated persons shall provide services to clients competently and maintain the
necessary knowledge and skill to continue to do so in those areas in which they are engaged.
•
Fairness - Associated persons shall perform professional services in a manner that is fair and
reasonable to clients, principals, partners, and employers, and shall disclose conflict(s) of interest
in providing such services.
•
Confidentiality - Associated persons shall not disclose confidential client information without the
specific consent of the client unless in response to proper legal process, or as required by law.
•
Professionalism - Associated persons’ conduct in all matter shall reflect credit of the profession.
•
Diligence - Associated persons shall act diligently in providing professional services.
We periodically review and amend our Code of Ethics to ensure that it remains current, and we require
all firm access persons to attest to their understanding of and adherence to the Code of Ethics at least
annually. Our firm will provide of copy of its Code of Ethics to any client or prospective client upon
request.
Investment Recommendations Involving a Material Financial Interest and
Conflicts of Interest
Neither our firm, its associates or any related person is authorized to recommend to a client, or effect a
transaction for a client, involving any security in which our firm or a related person has a material
financial interest, such as in the capacity as an underwriter, adviser to the issuer, etc.
Advisory Firm Purchase of Same Securities Recommended to Clients and
Conflicts of Interest
Our firm and its “related persons” may buy or sell securities similar to, or different from, those we
recommend to clients for their accounts. 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. Any exceptions or trading pre-clearance must
be approved by the firm principal in advance of the transaction in an account, and we maintain the
required personal securities transaction records per regulation.
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Trading Securities at/Around the Same Time as Client’s Securities
From time to time, our firm or its “related persons” may buy or sell securities for themselves at or around
the same time as clients. We will not trade non-mutual fund securities 5 days prior to the same security
for clients.
Factors Used to Select Custodians and/or Broker-Dealers
Item 12: Brokerage Practices
Plum Pointe Wealth Management, LLC does not have any affiliation with Broker-Dealers. Specific
custodian recommendations are made to client based on their need for such services. We recommend
custodians based on the reputation and services provided by the firm.
1. Research and Other Soft-Dollar Benefits
We currently do not receive soft dollar benefits.
2. Brokerage for Client Referrals
We receive no referrals from a broker-dealer or third party in exchange for using that broker-dealer or
third party.
3. Clients Directing Which Broker/Dealer/Custodian to Use
We do recommend a specific custodian for clients to use, however, clients may custody their assets at a
custodian of their choice. Clients may also direct us to use a specific broker-dealer to execute
transactions. By allowing clients to choose a specific custodian, we may be unable to achieve most
favorable execution of client transaction and this may cost clients’ money over using a lower-cost
custodian.
Aggregating (Block) Trading for Multiple Client Accounts
Investment advisers may elect to purchase or sell the same securities for several clients at approximately
the same time when they believe such action may prove advantageous to clients. This process is referred
to as aggregating orders, batch trading or block trading. We do not engage in block trading. It should be
noted that implementing trades on a block or aggregate basis may be less expensive for client accounts;
however, it is our trading policy is to implement all client orders on an individual basis. Therefore, we do
not aggregate or “block” client transactions. Considering the types of investments, we hold in advisory
client accounts, we do not believe clients are hindered in any way because we trade accounts
individually. This is because we develop individualized investment strategies for clients and holdings will
vary. Our strategies are primarily developed for the long-term and minor differences in price execution
are not material to our overall investment strategy.
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Item 13: Review of Accounts
Client accounts with the Investment Management Service will be reviewed regularly on an at least a
quarterly basis by Brian S. Dunckley, President and CCO. The account is reviewed with regards to the
client’s investment policies and risk tolerance levels. Events that may trigger a special review would be
unusual performance, addition or deletions of client imposed restrictions, excessive draw-down,
volatility in performance, or buy and sell decisions from the firm or per client's needs.
Clients will receive trade confirmations from the broker(s) for each transaction in their accounts as well
as monthly or quarterly statements and annual tax reporting statements from their custodian showing
all activity in the accounts, such as receipt of dividends and interest.
Plum Pointe will provide written reports to Investment Management clients on at least a quarterly basis,
or monthly basis. We urge clients to compare these reports against the account statements they receive
from their custodian.
Item 14: Client Referrals and Other
Compensation
We do not receive any economic benefit, directly or indirectly from any third party for advice rendered
to our clients. Nor do we directly or indirectly compensate any person who is not advisory personnel for
client referrals.
Pursuant to SEC Regulation Section 275.206.4-1, and applicable state laws, we have entered into a
“promotion arrangements” with other registered investment advisers. At the time of referral, the
prospective client is given full disclosure of the promotion arrangement and the nature of the
relationship between us and the other investment adviser.
Item 15: Custody
Plum Pointe does not accept custody of client funds. Clients should receive at least quarterly statements
from the broker dealer, bank or other qualified custodian that holds and maintains client's investment
assets. We urge you to carefully review such statements and compare such official custodial records to
the account statements or reports that we may provide to you. Our statements or reports may vary from
custodial statements based on accounting procedures, reporting dates, or valuation methodologies of
certain securities.
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Item 16: Investment Discretion
For those client accounts where we provide investment management services, we maintain discretion
over client accounts with respect to securities to be bought and sold and the amount of securities to be
bought and sold. Investment discretion is explained to clients in detail when an advisory relationship has
commenced. At the start of the advisory relationship, the client will execute a Limited Power of Attorney,
which will grant our firm discretion over the account. Additionally, the discretionary relationship will be
outlined in the advisory contract and signed by the client. Clients may impose reasonable restrictions
on investing in certain securities, types of securities, or industry sectors.
Item 17: Voting Client Securities
Plum Pointe Wealth Management, LLC does not vote Client proxies. Therefore, Clients maintain exclusive
responsibility for: (1) voting proxies, and (2) acting on corporate actions pertaining to the Client’s
investment assets. The Client shall instruct the Client’s qualified custodian to forward to the Client copies
of all proxies and shareholder communications relating to the Client’s investment assets. If the client
would like our opinion on a particular proxy vote, they may contact us at the number listed on the cover
of this brochure.
In most cases, you will receive proxy materials directly from the account custodian. However, in the
event we were to receive any written or electronic proxy materials, we would forward them directly to
you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we
would forward you any electronic solicitation to vote proxies.
Item 18: Financial Information
Registered investment advisers are required in this Item to provide you with certain financial information
or disclosures about our financial condition. We have no financial commitment that impairs our ability
to meet contractual and fiduciary commitments to clients, and we have not been the subject of a
bankruptcy proceeding.
We do not have custody of client funds or securities or require or solicit prepayment of more than $1,200
in fees per client six months in advance.
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WHAT DOES PLUM POINTE WEALTH MANAGEMENT, LLC
DO WITH YOUR PERSONAL INFORMATION?
FACTS
Why?
Registered investment advisers choose how they share your personal information. Federal law
gives clients the right to limit some but not all sharing. Federal law also requires us to tell you
h o w we collect, share, and protect your personal information. Please read this notice carefully
to understand what we do.
What?
The types of personal information we collect, and share depend on the product or service
you have with us. This information can include:
Information you provide in the subscription documents and other forms (including
name, address, social security number, date of birth, income and other financial-
related information); and
Data about your transactions with us (such as the types of investments you have
made and your account status).
How?
All financial companies need to share clients’ personal information to run their everyday business.
In the section below, we list the reasons financial companies can share their clients’ personal
information; the reasons Plum Pointe Wealth Management, LLC chooses to share; and whether
you can limit this sharing.
Reasons we can share your personal information
For our everyday business purposes— to process your transactions, maintain your accounts (for example we may
share with our third-party service providers that perform services on our behalf or on your behalf, such as accountants,
attorneys, consultants, clearing and custodial firms, and technology companies, respond to court orders and legal
investigations, or report to credit bureaus.
For Marketing purposes— to offer our products and services to you
How do we protect your information?
To safeguard your personal information from unauthorized access and use, we maintain physical, procedural and
electronic safeguards. These include computer safeguards such as passwords, secured files and buildings.
Our employees are advised about Plum Pointe Wealth Management, LLC 's need to respect the confidentiality
of each client’s non-public personal information. We train our employees on their responsibilities.
We require third parties that assist in providing our services to you to protect the personal information they receive.
This includes contractual language in our third-party agreements.
Other important information
We will send you our Privacy Notice annually for as long as you maintain an ongoing relationship with us. Periodically
we may revise our Privacy Notice and will provide you with a revised policy if the changes materially alter the previous
Privacy Notice. We will not, however, revise our Privacy Notice to permit the sharing of non-public personal information
other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the
information sharing.
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Form ADV Part 2B – Brian S. Dunckley, CFP®
225 Dyer Street, 3rd Floor
Providence, RI 02903
401-228-8258
Dated October 3, 2025
This brochure supplement provides information about Brian S. Dunckley, President and CCO, that
supplements the Plum Pointe Wealth Management, LLC (“Plum Pointe”) brochure. A copy of that
brochure precedes this supplement. Please contact Brian S. Dunckley if the Plum Pointe brochure is not
included with this supplement or if you have any questions about the contents of this supplement.
information about Brian S. Dunckley
is available on
the SEC’s website at
Additional
www.adviserinfo.sec.gov which can be found using the identification number 4953453.
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Item 2: Educational Background and
Brian S. Dunckley, CFP®
Business Experience
Born: 1977
Educational Background
• 2001 – Bachelors of Science, Biology, University of Michigan
Business Experience
• 09/2024 – Present, Plum Pointe Wealth Management, LLC, President and CCO
• 07/2016 – Present, Plum Pointe Wealth Management, Ltd., President and CCO
• 03/2021 – Present, Plum Pointe Advisors, LLC, President and Managing Member
• 02/2023 – Present, Saunderstown Partners, LLC, Managing Member
• 11/2009 – 09/2016, BNY/Mellon, Senior Wealth Advisor
• 02/2006 – 11/2009, Morgan Stanley/Smith Barney, Financial Advisor
Professional Designations, Licensing & Exams
CERTIFIED FINANCIAL PLANNER™ professional
I am certified for financial planning services in the United States by Certified Financial Planner Board of
Standards, Inc. (“CFP Board”). Therefore, I may refer to myself as a CERTIFIED FINANCIAL PLANNER™
professional or a CFP® professional, and I may use these and CFP Board’s other certification marks (the
“CFP Board Certification Marks”). The CFP® certification is voluntary. No federal or state law or
regulation requires financial planners to hold the CFP® certification. You may find more information
about the CFP® certification at www.cfp.net.
CFP® professionals have met CFP Board’s high standards for education, examination, experience, and
ethics. To become a CFP® professional, an individual must fulfill the following requirements:
• Education – Earn a bachelor’s degree or higher from an accredited college or university and
complete CFP Board-approved coursework at a college or university through a CFP Board
Registered Program. The coursework covers the financial planning subject areas CFP Board has
determined are necessary for the competent and professional delivery of financial planning
services, as well as a comprehensive financial plan development capstone course. A candidate
may satisfy some of the coursework requirement through other qualifying credentials.
• Examination – Pass the comprehensive CFP® Certification Examination. The examination is
designed to assess an individual’s ability to integrate and apply a broad base of financial
planning knowledge in the context of real-life financial planning situations.
• Experience – Complete 6,000 hours of professional experience related to the personal financial
planning process, or 4,000 hours of apprenticeship experience that meets additional
requirements.
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• Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP®
Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and
Standards of Conduct (“Code and Standards”), which sets forth the ethical and practice
standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics
requirements to remain certified and maintain the right to continue to use the CFP Board Certification
Marks:
• Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a
commitment to CFP Board, as part of the certification, to act as a fiduciary, and therefore, act
in the best interests of the client, at all times when providing financial advice and financial
planning. CFP Board may sanction a CFP® professional who does not abide by this commitment,
but CFP Board does not guarantee a CFP® professional's services. A client who seeks a similar
commitment should obtain a written engagement that includes a fiduciary obligation to the
client.
• Continuing Education – Complete 30 hours of continuing education every two years to maintain
competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with
developments in financial planning. Two of the hours must address the Code and Standards.
Item 3: Disciplinary Information
No management person at Plum Pointe Wealth Management, Ltd. has ever been involved in an
arbitration claim of any kind or been found liable in a civil, self-regulatory organization, or administrative
proceeding.
Item 4: Other Business Activities
Brian Dunckley is President and Managing Member of Plum Pointe Advisors, LLC, an insurance agency.
Associated persons of Plum Pointe are licensed to sell life and health insurance and may engage in
product sales with our clients, for which they will receive additional compensation. Any commissions
received through life or health insurance sales do not offset advisory fees the client may pay for advisory
services under Plum Pointe. Clients are free to use any party of their choosing for their insurance needs,
and are not required to use Plum Pointe Advisors, LLC.
Brian Dunckley is the managing member of Saunderstown Partners, LLC, an exempt reporting adviser.
Brian S. Dunckley does not receive any economic benefit from any person, company, or organization, in
exchange for providing clients advisory services through Plum Pointe.
Item 5: Additional Compensation
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Brian S. Dunckley, as President and Chief Compliance Officer of Plum Pointe, is responsible for
supervision. He may be contacted at the phone number on this brochure supplement.
Item 6: Supervision
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