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Item 1: Cover Page
Part 2A of Form ADV: Firm Brochure
October 2025
6154 Innovation Way
Carlsbad, CA 92009
www.SeasideWealth.com
Firm Contact:
Jess Beltran
Chief Compliance Officer
This brochure provides information about the qualifications and business practices of Seaside Wealth
Management, Inc. If clients have any questions about the contents of this brochure, please contact us at
(760) 730-8120 or jess@seasidewealth.com. The information in this brochure has not been approved
or verified by the United States Securities and Exchange Commission or by any State Securities
Authority. Additional information about our firm is also available on the SEC’s website at
www.adviserinfo.sec.gov.
Our firm is a registered investment adviser. Please note that the use of the term “registered investment
adviser” and description of our firm and/or our associates as “registered” does not imply a certain level
of skill or training. Clients are encouraged to review this Brochure and Brochure Supplements for our
firm’s associates who advise clients for more information on the qualifications of our firm and our
employees.
Item 2: Material Changes
Seaside Wealth Management, Inc. is required to make clients aware of information that has changed
since the last annual update to the Firm Brochure (“Brochure”) and that may be important to them.
Clients can then determine whether to review the brochure in its entirety or to contact us with questions
about the changes.
Since our annual amendment last filed on February 12th, 2025, our firm has the following material
changes to disclose:
Our firm has appointed Jess Beltran as Chief Compliance Officer of Seaside Wealth Management, Inc.
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Item 3: Table of Contents
Item 1: Cover Page................................................................................................................................................................... 1
Item 2: Material Changes ...................................................................................................................................................... 2
Item 3: Table of Contents ..................................................................................................................................................... 3
Item 4: Advisory Business .................................................................................................................................................... 4
Item 5: Fees & Compensation ............................................................................................................................................. 6
Item 6: Performance-Based Fees & Side-By-Side Management ........................................................................... 7
Item 7: Types of Clients & Account Requirements .................................................................................................... 7
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ................................................................... 8
Item 9: Disciplinary Information ....................................................................................................................................... 9
Item 10: Other Financial Industry Activities & Affiliations .................................................................................... 9
Item 11: Code of Ethics, Participation or Interest in ................................................................................................. 9
Item 12: Brokerage Practices ........................................................................................................................................... 10
Item 13: Review of Accounts or Financial Plans ....................................................................................................... 14
Item 14: Client Referrals & Other Compensation ..................................................................................................... 14
Item 15: Custody .................................................................................................................................................................... 15
Item 16: Investment Discretion ....................................................................................................................................... 16
Item 17: Voting Client Securities ..................................................................................................................................... 16
Item 18: Financial Information ........................................................................................................................................ 16
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Seaside Wealth Management, Inc.
Item 4: Advisory Business
Our firm provides individuals and other types of clients with asset management and financial planning
and consulting services. Our firm is a corporation formed in the State of California. Our firm has been in
business since 2011 and as a registered investment adviser since 2015 and is wholly owned by Bradley
Lineberger.
Types of Advisory Services Offered
Asset Management:
As part of our Asset Management service clients will be provided asset management and financial
planning or consulting services. This service is designed to assist clients in meeting their financial goals
through the use of a financial plan or consultation. Our firm conducts client meetings to understand their
current financial situation, existing resources, financial goals, and tolerance for risk. Based on what is
learned, an investment approach is presented to the client, consisting of individual stocks, bonds, ETFs,
mutual funds and other public and private securities or investments. Once the appropriate portfolio has
been determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced
based upon the client’s individual needs, stated goals and objectives. Upon client request, our firm
provides a summary of observations and recommendations for the planning or consulting aspects of
this service.
Financial Planning & Consulting:
We provide a variety of standalone financial planning and consulting services to clients for the
management of financial resources based upon an analysis of current situation, goals, and objectives.
Financial planning and consulting services will typically involve preparing a financial plan or rendering
a financial consultation for clients based on the client’s financial goals and objectives. This planning or
consulting may encompass Investment Planning, Retirement Planning, Estate Planning, Charitable
Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study, Corporate
Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation,
or Business and Personal Financial Planning.
Written financial plans or financial consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the clients. Implementation
of the recommendations will be at the discretion of the client. Our firm provides clients with a summary
of their financial situation, and observations for financial planning engagements. Financial consultations
are not typically accompanied by a written summary of observations and recommendations, as the
process is less formal than our planning service. Assuming that all the information and documents
requested from the client are provided promptly, plans or consultations are typically completed within
six (6) months of the client signing a contract with our firm.
Retirement Plan Consulting:
Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing basis.
Generally, such consulting services consist of assisting employer plan sponsors in establishing,
monitoring and reviewing their company's participant-directed retirement plan. As the needs of the
plan sponsor dictate, areas of advising may include:
• Establishing an Investment Policy Statement – Our firm will assist in the development of a
statement that summarizes the investment goals and objectives along with the broad strategies
to be employed to meet the objectives.
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Seaside Wealth Management, Inc.
•
Investment Options – Our firm will work with the Plan Sponsor to evaluate existing investment
options and make recommendations for appropriate changes.
• Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation
models to aid Participants in developing strategies to meet their investment objectives, time
horizon, financial situation and tolerance for risk.
•
Investment Monitoring – Our firm will monitor the performance of the investments and notify
the client in the event of over/underperformance and in times of market volatility.
• Participant Education – Our firm will provide opportunities to educate plan participants about
their retirement plan offerings, different investment options, and general guidance on allocation
strategies.
In providing services for retirement plan consulting, our firm does not provide any advisory services with
respect to the following types of assets: employer securities, real estate (excluding real estate funds and
publicly traded REITS), participant loans, non-publicly traded securities or assets, other illiquid
investments, or brokerage window programs
(collectively, “Excluded Assets”). All retirement plan
consulting services shall comply with the applicable state laws regulating retirement consulting
services. This applies to client accounts that are retirement or other employee benefit plans (“Plan”)
governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the client
accounts are part of a Plan, and our firm accepts appointment to provide services to such accounts, our
firm acknowledges its fiduciary standard within the meaning of Section 3(21) or 3(38) of ERISA as
designated by the Retirement Plan Consulting Agreement with respect to the provision of services
described therein.
*Use of Pontera to manage assets “held away”: We provide an additional service for accounts not
directly held in our custody, but where we do have discretion, and may leverage an Order Management
System to implement tax-efficient asset location and opportunistic rebalancing strategies on behalf of
the client. These are primarily 401(k) accounts, HSA’s, and other assets we do not custody. We
regularly review the available investment options in these accounts, monitor them, and rebalance and
implement our strategies in the same way we do other accounts, though using different tools as
necessary.
Tailoring of Advisory Services
Our firm offers individualized investment advice to our Asset Management clients. General investment
advice will be offered to our Financial Planning & Consulting and Retirement Plan Consulting clients.
Each Asset Management client may place reasonable restrictions on the types of investments to be held in
the portfolio. Restrictions on investments in certain securities or types of securities may not be possible
due to the level of difficulty this would entail in managing the account.
Participation in Wrap Fee Programs
Our firm does not offer a wrap fee program.
Regulatory Assets Under Management
As of December 31, 2024, our firm manages $362,311,582. Of these assets, $356,851,776 is managed on
a discretionary basis while $5,459,806 is managed on a non-discretionary basis.
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Seaside Wealth Management, Inc.
Item 5: Fees & Compensation
Compensation for Our Advisory Services
Asset Management:
The maximum annual fee charged for this service will not exceed 1.25%. Total fees to be assessed will
be outlined in the advisory agreement to be signed by the client. Annualized fees are billed on a pro-rata
basis quarterly in advance based on the total value of the assets in the Client’s portfolio(s) on the last
day of the previous quarter. Adjustments will be made for deposits and withdrawals greater than or
equal to $100,000 during the quarter. Fees are generally not negotiable and will be deducted from client
account(s). In rare cases, our firm will agree to directly bill clients. Unless otherwise stated in writing,
our firm bills on cash. As part of this process, clients understand the following:
a) The client’s independent custodian sends statements at least quarterly showing the market
values for each security included in the Assets and all account disbursements, including the
amount of the advisory fees paid to our firm;
b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our
firm will send an invoice directly to the custodian; and
c) If our firm sends a copy of our invoice to the client, a legend urging the comparison of
information provided in our statement with those from the qualified custodian will be included.
Financial Planning & Consulting:
Our firm charges on an hourly or flat fee basis for financial planning and consulting services. The total
estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of our
engagement with the client. The maximum hourly fee to be charged will not exceed $500. Flat fees will
not exceed $10,000. Our firm requires a retainer of 50% of the ultimate financial planning or consulting
fee at the time of signing. The remainder of the fee will be directly billed to the client and due within 30
days of a financial plan being delivered or consultation rendered. Our firm will not require a retainer
exceeding $1,200 when services cannot be rendered within 6 months.
Retirement Plan Consulting:
Our firm charges a fee based on a percentage of Plan assets under management for our Retirement Plan
Consulting services. The maximum annual fee charged for this service will not exceed 1.00%. The fee-
paying arrangements will be determined on a case-by-case basis and will be detailed in the signed
consulting agreement.
Other Types of Fees & Expenses
Clients may incur transaction fees for trades executed by their chosen custodian via individual
transaction charges. These transaction fees are separate from our firm’s advisory fees and will be
disclosed by the chosen custodian. Charles Schwab & Co., Inc. (“Schwab”) does not charge transaction
fees for U.S. listed equities and exchange traded funds.
Clients may also pay holdings charges imposed by the chosen custodian for certain investments, charges
imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be disclosed in the
fund’s prospectus (i.e., fund management fees, initial or deferred sales charges, mutual fund sales loads,
12b-1 fees, surrender charges, variable annuity fees, IRA and qualified retirement plan fees, and other
fund expenses), mark-ups and mark-downs, spreads paid to market makers, fees for trades executed
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Seaside Wealth Management, Inc.
away from custodian, wire transfer fees and other fees and taxes on brokerage accounts and securities
transactions. Our firm does not receive a portion of these fees.
Our firm does not charge an additional fee for managing held-away assets for clients that engage us
under our Comprehensive Portfolio Management agreement, however, Pontera charges a 0.25% fee
for those assets. Our firm will not charge clients the 0.25% Pontera fee and will cover the additional
cost of this service.
Termination & Refunds
Either party may terminate the advisory agreement signed with our firm for Asset Management services
in writing at any time. Upon notice of termination our firm will process a pro-rata refund of the unearned
portion of the advisory fees charged in advance.
Clients may terminate their Financial Planning and Consulting agreement at any time before the delivery
of a financial plan by providing written notice. For purposes of calculating refunds, all work performed
by us up to the point of termination shall be calculated at the hourly fee currently in effect. Clients will
receive a pro-rata refund of unearned fees based on the time and effort expended by our firm.
Either party to a Retirement Plan Consulting Agreement may terminate at any time by providing written
notice to the other party. Full refunds will only be made in cases where cancellation occurs within 5
business days of signing an agreement. After 5 business days from initial signing, either party must
provide the other party 30 days written notice to terminate billing. Billing will terminate 30 days after
receipt of termination notice. Clients will be charged on a pro-rata basis, which takes into account work
completed by our firm on behalf of the client. Clients will incur charges for bona fide advisory services
rendered up to the point of termination (determined as 30 days from receipt of said written notice) and
such fees will be due and payable.
Commissionable Securities Sales
Representatives of our firm are registered representatives of Purshe Kaplan Sterling Investments, Inc.
(“PKS”), member FINRA/SIPC. As such they are able to accept compensation for the sale of securities or
other investment products, including distribution or service (“trail”) fees from the sale of mutual funds.
Clients should be aware that the practice of accepting commissions for the sale of securities presents a
conflict of interest and gives our firm and/or our representatives an incentive to recommend investment
products based on the compensation received. Our firm generally addresses commissionable sales
conflicts that arise when explaining to clients these sales create an incentive to recommend based on
the compensation to be earned and/or when recommending commissionable mutual funds, explaining
that “no-load” funds are also available. Our firm does not prohibit clients from purchasing recommended
investment products through other unaffiliated brokers or agents.
Item 6: Performance-Based Fees & Side-By-Side Management
Our firm does not charge performance-based fees.
Item 7: Types of Clients & Account Requirements
Our firm has the following types of clients:
•
Individuals and High Net Worth Individuals;
• Trusts, Estates or Charitable Organizations;
• Pension and Profit-sharing Plans; &
• Corporations, Limited Liability Companies and/or Other Business Types.
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Seaside Wealth Management, Inc.
Typically, our firm requires a minimum account balance of $750,000 for clients to engage us for our
Asset Management service. However, our firm, in its sole discretion, may reduce or waive this
requirement on a case-by-case basis.
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
Methods of Analysis
Seaside builds portfolios grounded in economic theory and backed by decades of empirical research.
Research is received from Dimensional Funds Advisors (DFA), Vanguard, Blackrock, State Street, and
other firms. DFA provides historical market analysis, risk/return analysis, and continuing education
services. Software programs from DFA and other firms are used to model historical and expected
returns of individual asset classes and portfolios.
Investment Strategies We Use
Seaside’s investment philosophy incorporates many of the principles of Modern Portfolio Theory. This
theory has been thoroughly researched and supported for decades by leading financial academics,
including several Nobel Prize winners. The fundamentals of Seaside’s philosophy include:
• Embrace Market Pricing - The market is an effective information-processing machine. Each day,
the world equity markets process billions of dollars in trades between buyers and sellers—and
the real-time information they bring helps set prices.
• Don’t Try to Outguess the Market - The market’s pricing power works against investors –
including mutual fund managers – who try to outperform through stock picking or market
timing.
• Resist Chasing Past Performance - Some investors select mutual funds based on their past
returns. Yet, past performance offers little insight into a fund’s future returns.
• Let Markets Work for You - The financial markets have rewarded long-term investors. Investors
expect a positive return on the capital they supply, and historically, the equity and bond markets
have provided growth of wealth that has more than offset inflation.
• Asset Allocation - The primary consideration when building a client’s portfolio is asset
allocation—the way in which assets will be divided between different investments (stocks,
bonds, real estate, and cash). Academic studies have shown asset allocation to be the most
important determinant of investment return and risk.
• Practice Smart Diversification - Holding securities across many market segments, sectors,
industries, and geographies can help manage overall risk.
• Avoid Market Timing - We never know which market segments will outperform from year to
year. By holding a globally diversified portfolio, investors are well-positioned to seek returns
wherever they occur.
• Consider the Drivers of Returns - Academic research has identified specific equity and fixed
income dimensions, which point to differences in expected returns. Investors can pursue higher
expected returns by structuring their portfolio around these dimensions, also referred to as
“premiums.”
• Disciplined Rebalancing - Differences in the performance of asset classes will cause them to
deviate from their allocation targets. A disciplined rebalancing strategy restores the portfolio’s
target allocation once a minimum or maximum threshold has been exceeded. This disciplined
process serves to keep risk at the appropriate level while minimizing trading costs and taxable
gains.
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Seaside Wealth Management, Inc.
Preferred Securities
Seaside invests client assets in the following security types, provided that such securities are
appropriate to the needs of the client and consistent with the client's investment objectives, risk
tolerance, and time horizons, among other considerations.
Individual Securities
• ETF’s
• Mutual Funds
•
• Municipal Bonds
• Corporate Bonds
Seaside invests primarily in passively managed investment vehicles, similar to index funds. An index
fund is a basket of stocks which owns most of the securities in a market or specific asset class. In the
management of an index fund, no attempt is made to pick “attractive” over “unattractive” securities or
to time the market. Rather, by owning all the securities in a market, the fund mimics the market’s
performance. Index funds enjoy lower investment costs (management fees, transaction costs, and tax
costs) as compared to “actively managed” funds. Consequently, index funds deliver superior long‐term
performance compared to most actively managed funds.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear. While the stock
market may increase and the account(s) could enjoy a gain, it is also possible that the stock market may
decrease, and the account(s) could suffer a loss. It is important that clients understand the risks
associated with investing in the stock market, and that their assets are appropriately diversified in
investments. Clients are encouraged to ask our firm any questions regarding their risk tolerance.
Description of Material, Significant or Unusual Risks
Our firm generally invests client cash balances in money market funds, FDIC Insured Certificates of
Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, our
firm tries to achieve the highest return on client cash balances through relatively low-risk conservative
investments. In most cases, at least a partial cash balance will be maintained in a money market account
so that our firm may debit advisory fees for our services related to our Asset Management service, as
applicable.
Item 9: Disciplinary Information
There are no legal or disciplinary events that are material to the evaluation of our advisory business or
the integrity of our management.
Item 10: Other Financial Industry Activities & Affiliations
Representatives of our firm are registered representatives of PKS, member FINRA/SIPC, and licensed
insurance agents. As a result of these transactions, they receive normal and customary commissions. A
conflict of interest exists as these commissionable securities sales create an incentive to recommend
products based on the compensation earned. To mitigate this potential conflict, our firm will act in the
client’s best interest.
Item 11: Code of Ethics, Participation or Interest in
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Seaside Wealth Management, Inc.
Client Transactions & Personal Trading
As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material
facts and to act solely in the best interest of each of our clients at all times. Our fiduciary duty is the
underlying principle for our firm’s Code of Ethics, which includes procedures for personal securities
transaction and insider trading. Our firm requires all representatives to conduct business with the highest
level of ethical standards and to comply with all federal and state securities laws at all times. Upon
employment with our firm, and at least annually thereafter, all representatives of our firm will acknowledge
receipt, understanding and compliance with our firm’s Code of Ethics. Our firm and representatives must
conduct business in an honest, ethical, and fair manner and avoid all circumstances that might negatively
affect or appear to affect our duty of complete loyalty to all clients. This disclosure is provided to give all
clients a summary of our Code of Ethics. If a client or a potential client wishes to review our Code of Ethics
in its entirety, a copy will be provided promptly upon request.
Our firm recognizes that the personal investment transactions of our representatives demands the
application of a Code of Ethics with high standards and requires that all such transactions be carried out in
a way that does not endanger the interest of any client. At the same time, our firm also believes that if
investment goals are similar for clients and for our representatives, it is logical, and even desirable, that
there be common ownership of some securities. In order to prevent conflicts of interest, our firm has
established procedures for transactions effected by our representatives for their personal accounts1. In
order to monitor compliance with our personal trading policy, our firm has pre-clearance requirements and
a quarterly securities transaction reporting system for all of our representatives.
Neither our firm nor a related person recommends, buys or sells for client accounts, securities in which
our firm or a related person has a material financial interest without prior disclosure to the client.
Related persons of our firm may buy or sell securities and other investments that are also recommended
to clients. In order to minimize this conflict of interest, our related persons will place client interests
ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon
request.
Likewise, related persons of our firm buy or sell securities for themselves at or about the same time they
buy or sell the same securities for client accounts. In order to minimize this conflict of interest, our related
persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a
copy of which is available upon request. Further, our related persons will refrain from buying or selling the
same securities that will be bought or sold in client accounts unless done so after the client execution or
concurrently as a part of a block trade.
Item 12: Brokerage Practices
Custodian & Brokers Used
Our firm does not maintain custody of client assets (although our firm may be deemed to have custody
of client assets if given the authority to withdraw assets from client accounts. See Item 15 Custody,
below). Client assets must be maintained in an account at a “qualified custodian,” generally a broker-
dealer or bank. Our firm recommends that clients use the Schwab Advisor Services division of Charles
Schwab & Co. Inc. (“Schwab”), a FINRA-registered broker-dealer, member SIPC, as the qualified
custodian. Our firm is independently owned and operated, and not affiliated with Schwab. Schwab will
1 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse, his/her
minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our associate
controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect beneficial interest
in.
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hold client assets in a brokerage account and buy and sell securities when instructed. While our firm
recommends that clients use Schwab as custodian/broker, clients will decide whether to do so and open
an account with Schwab by entering into an account agreement directly with them. Our firm does not
open the account. Even though the account is maintained at Schwab, our firm can still use other brokers
to execute trades, as described in the next paragraph.
How Brokers/Custodians Are Selected
Our firm seeks to recommend a custodian/broker who will hold client assets and execute transactions
on terms that are overall most advantageous when compared to other available providers and their
services. A wide range of factors are considered, including, but not limited to:
•
•
•
combination of transaction execution services along with asset custody services (generally
without a separate fee for custody)
capability to execute, clear and settle trades (buy and sell securities for client accounts)
capabilities to facilitate transfers and payments to and from accounts (wire transfers, check
requests, bill payment, etc.)
• breadth of investment products made available (stocks, bonds, mutual funds, exchange traded
funds (ETFs), etc.)
• availability of investment research and tools that assist in making investment decisions and
•
quality of services
competitiveness of the price of those services (commission rates, margin interest rates, other
fees, etc.) and willingness to negotiate them
reputation, financial strength and stability of the provider
•
• prior service to our firm and our other clients
• availability of other products and services that benefit our firm, as discussed below (see
“Products & Services Available from Schwab”)
Custody & Brokerage Costs
Schwab generally does not charge a separate for custody services but is compensated by charging
commissions or other fees to clients on trades that are executed or that settle into the Schwab account.
In addition to commissions, Schwab charges a flat dollar amount as a “prime broker” or “trade away” fee
for each trade that our firm has executed by a different broker-dealer but where the securities bought
or the funds from the securities sold are deposited (settled) into a Schwab account. These fees are in
addition to the commissions or other compensation paid to the executing broker-dealer. Because of this,
in order to minimize client trading costs, our firm has Schwab execute most trades for the accounts.
Products & Services Available from Schwab
Schwab Advisor Services is Schwab’s business serving independent investment advisory firms like our
firm. They provide our firm and clients with access to its institutional brokerage – trading, custody,
reporting and related services – many of which are not typically available to Schwab retail customers.
Schwab also makes available various support services. Some of those services help manage or
administer our client accounts while others help manage and grow our business. Schwab’s support
services are generally available on an unsolicited basis (our firm does not have to request them) and at
no charge to our firm. The availability of Schwab’s products and services is not based on the provision
of particular investment advice, such as purchasing particular securities for clients. Here is a more
detailed description of Schwab’s support services:
Services that Benefit Clients
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Seaside Wealth Management, Inc.
Schwab’s institutional brokerage services include access to a broad range of investment products,
execution of securities transactions, and custody of client assets. The investment products available
through Schwab include some to which our firm might not otherwise have access or that would require
a significantly higher minimum initial investment by firm clients. Schwab’s services described in this
paragraph generally benefit clients and their accounts.
Services that May Not Directly Benefit Clients
Schwab also makes available other products and services that benefit our firm but may not directly
benefit clients or their accounts. These products and services assist in managing and administering our
client accounts. They include investment research, both Schwab’s and that of third parties. This research
may be used to service all or some substantial number of client accounts, including accounts not
maintained at Schwab. In addition to investment research, Schwab also makes available software and
other technology that:
• provides access to client account data (such as duplicate trade confirmations and account
statements);
facilitates trade execution and allocate aggregated trade orders for multiple client accounts;
facilitates payment of our fees from our clients’ accounts; and
•
• provides pricing and other market data;
•
• assists with back-office functions, recordkeeping and client reporting.
Services that Generally Benefit Only Our Firm
Schwab also offers other services intended to help manage and further develop our business enterprise.
These services include:
technology, compliance, legal, and business consulting;
• educational conferences and events
•
• publications and conferences on practice management and business succession; and
• access to employee benefits providers, human capital consultants and insurance providers.
Schwab may provide some of these services itself. In other cases, Schwab will arrange for third-party
vendors to provide the services to our firm. Schwab may also discount or waive fees for some of these
services or pay all or a part of a third party’s fees. Schwab may also provide our firm with other benefits,
such as occasional business entertainment for our personnel.
Irrespective of direct or indirect benefits to our client through Schwab, our firm strives to enhance the
client experience, help clients reach their goals and put client interests before that of our firm or
associated persons.
Our Interest in Schwab’s Services.
The availability of these services from Schwab benefits our firm because our firm does not have to
produce or purchase them. Our firm does not have to pay for these services, and they are not contingent
upon committing any specific amount of business to Schwab in trading commissions or assets in custody.
In light of our arrangements with Schwab, a conflict of interest exists as our firm may have incentive to
require that clients maintain their accounts with Schwab based on our interest in receiving Schwab’s
services that benefit our firm rather than based on client interest in receiving the best value in custody
services and the most favorable execution of transactions. As part of our fiduciary duty to our clients,
our firm will endeavor at all times to put the interests of our clients first. Clients should be aware,
however, that the receipt of economic benefits by our firm or our related persons creates a potential
conflict of interest and may indirectly influence our firm’s choice of Schwab as a custodial
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recommendation. Our firm examined this potential conflict of interest when our firm chose to
recommend Schwab and have determined that the recommendation is in the best interest of our firm’s
clients and satisfies our fiduciary obligations, including our duty to seek best execution.
In seeking best execution, the determinative factor is not the lowest possible cost, but whether the
transaction represents the best qualitative execution, taking into consideration the full range of a
broker-dealer’s services, including the value of research provided, execution capability, commission
rates, and responsiveness. Although our firm will seek competitive rates, to the benefit of all clients, our
firm may not necessarily obtain the lowest possible commission rates for specific client account
transactions. Our firm believes that the selection of Schwab as a custodian and broker is the best interest
of our clients. It is primarily supported by the scope, quality and price of Schwab’s services, and not
Schwab’s services that only benefit our firm.
Soft Dollars
Our firm does not receive soft dollars in excess of what is allowed by Section 28(e) of the Securities
Exchange Act of 1934. The safe harbor research products and services obtained by our firm will
generally be used to service all of our clients but not necessarily all at any one particular time.
Client Brokerage Commissions
The Recommended Custodians do not make client brokerage commissions generated by client
transactions available for our firm’s use.
Client Transactions in Return for Soft Dollars
Our firm does not direct client transactions to a particular broker-dealer in return for soft dollar
benefits.
Brokerage for Client Referrals
Our firm does not receive brokerage for client referrals.
Directed Brokerage
Neither our firm nor any of our firm’s representatives have discretionary authority in making the
determination of the brokers-dealers and/or custodians with whom orders for the purchase or sale of
securities are placed for execution, and the commission rates at which such securities transactions are
effected. Our firm routinely recommends that clients direct us to execute through a specified broker-
dealer. Our firm recommends the use of Schwab. Each client will be required to establish their account(s)
with either Schwab if not already done. Please note that not all advisers have this requirement.
Special Considerations for ERISA Clients
A retirement or ERISA plan client may direct all or part of portfolio transactions for its account through
a specific broker or dealer in order to obtain goods or services on behalf of the plan. Such direction is
permitted provided that the goods and services provided are reasonable expenses of the plan incurred
in the ordinary course of its business for which it otherwise would be obligated and empowered to pay.
ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the
exclusive benefit of the plan. Consequently, our firm will request that plan sponsors who direct plan
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brokerage provide us with a letter documenting that this arrangement will be for the exclusive benefit
of the plan.
Client-Directed Brokerage
Our firm does not allow client-directed brokerage.
Aggregation of Purchase or Sale
Our firm provides investment management services for various clients. There are occasions on which
portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same
security for numerous accounts served by our firm, which involve accounts with similar investment
objectives. Although such concurrent authorizations potentially could be either advantageous or
disadvantageous to any one or more particular accounts, they are affected only when our firm believes that
to do so will be in the best interest of the effected accounts. When such concurrent authorizations occur, the
objective is to allocate the executions in a manner which is deemed equitable to the accounts involved. In
any given situation, our firm attempts to allocate trade executions in the most equitable manner possible,
taking into consideration client objectives, current asset allocation and availability of funds using price
averaging, proration and consistently non-arbitrary methods of allocation.
Item 13: Review of Accounts or Financial Plans
Mr. Lineberger reviews accounts on at least an annual basis for our Asset Management clients. The
nature of these reviews is to learn whether client accounts are in line with their investment objectives,
appropriately positioned based on market conditions, and investment policies, if applicable. Our firm
provides performance reports to clients on a quarterly basis. Verbal reports to clients take place on at
least an annual basis when our Asset Management clients are contacted. Our firm may review client
accounts more frequently than described above. Among the factors which may trigger an off-cycle
review are major market or economic events, the client’s life events, requests by the client, etc.
Financial Planning and Consulting clients do not receive reviews of their written plans unless they take
action to schedule a financial consultation with us. We do not provide ongoing services to financial
planning clients, but are willing to meet with such clients upon their request to discuss updates to their
plans, changes in their circumstances, etc. If a review is requested, Mr. Lineberger will conduct the
review. Financial Planning and Consulting clients do not receive written or verbal updated reports
regarding their financial plans unless they separately contract with us for a post-financial plan meeting
or update to their initial written financial plan.
Retirement Plan Consulting clients receive reviews of their retirement plans for the duration of the
service. Our firm also provides ongoing services where clients are met with upon their request to discuss
updates to their plans, changes in their circumstances, etc. Retirement Plan Consulting clients do not
receive written or verbal updated reports regarding their plans unless they choose to engage our firm
for ongoing services.
Item 14: Client Referrals & Other Compensation
Schwab
Our firm receives economic benefit from Schwab in the form of the support products and services made
available to our firm and other independent investment advisors that have their clients maintain
accounts at Schwab. These products and services, how they benefit our firm, and the related conflicts of
interest are described above (see Item 12 – Brokerage Practices). The availability of Schwab’s products
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Seaside Wealth Management, Inc.
and services is not based on our firm giving particular investment advice, such as buying particular
securities for our clients.
Product Sponsors
In an effort to keep our clients informed as to the services we offer and the various financial products
we utilize, our firm occasionally sponsors events in conjunction with our product providers. These
events are educational in nature, and are not dependent upon the use of any specific products. While a
conflict of interest may exist given that these events are at least partially funded by product sponsors,
all funds received from the sponsors are used for the education of our clients, and we will always adhere
to our fiduciary duties in selecting appropriate investments for our clients.
Referral Fees
In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm does not provide
cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or
endorsements (which include client referrals).
Item 15: Custody
Deduction of Advisory Fees:
While our firm does not maintain physical custody of client assets (which are maintained by a qualified
custodian, as discussed above), we are deemed to have custody of certain client assets if given the
authority to withdraw assets from client accounts, as further described below under “Third Party Money
Movement.” All our clients receive account statements directly from their qualified custodian(s) at least
quarterly upon opening an account. If our firm decides to also send account statements to clients, such
notice and account statements include a legend that recommends that the client compare the account
statements received from the qualified custodian with those received from our firm. Clients are
encouraged to raise any questions with us about the custody, safety or security of their assets and our
custodial recommendations.
Third Party Money Movement:
The SEC issued a no‐action letter (“Letter”) with respect to the Rule 206(4)‐2 (“Custody Rule”) under
the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody Rule
as well as clarified that an adviser who has the power to disburse client funds to a third party under a
standing letter of instruction (“SLOA”) is deemed to have custody. As such, our firm has adopted the
following safeguards in conjunction with our custodians:
• The client provides an instruction to the qualified custodian, in writing, that includes the client’s
signature, the third party’s name, and either the third party’s address or the third party’s account
number at a custodian to which the transfer should be directed.
• The client authorizes the investment adviser, in writing, either on the qualified custodian’s form
or separately, to direct transfers to the third party either on a specified schedule or from time to
time.
• The client’s qualified custodian performs appropriate verification of the instruction, such as a
signature review or other method to verify the client’s authorization, and provides a transfer of
funds notice to the client promptly after each transfer.
• The client has the ability to terminate or change the instruction to the client’s qualified
custodian.
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• The investment adviser has no authority or ability to designate or change the identity of the third
party, the address, or any other information about the third party contained in the client’s
instruction.
• The investment adviser maintains records showing that the third party is not a related party of
the investment adviser or located at the same address as the investment adviser.
• The client’s qualified custodian sends the client, in writing, an initial notice confirming the
instruction and an annual notice reconfirming the instruction.
Item 16: Investment Discretion
Clients have the option of providing our firm with investment discretion on their behalf, pursuant to an
executed investment advisory client agreement. By granting investment discretion, our firm is
authorized to execute securities transactions, determine which securities are bought and sold, and the
total amount to be bought and sold. Limitations may be imposed by the client in the form of specific
constraints on any of these areas of discretion with our firm’s written acknowledgement.
Item 17: Voting Client Securities
Our firm does not accept the proxy authority to vote client securities. Clients will receive proxies or
other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to
our firm, our firm will forward them to the appropriate client and ask the party who sent them to mail
them directly to the client in the future. Clients may call, write or email us to discuss questions they may
have about particular proxy votes or other solicitations.
Outside asset managers selected or recommended by our firm may vote proxies for clients. Therefore,
except in the event of an outside manager votes proxies, clients maintain exclusive responsibility for:
(1) directing the manner in which proxies solicited by issuers of securities beneficially owned by the
client shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers,
bankruptcy proceedings or other type events pertaining to the client’s investment assets. Therefore
(except for proxies that may be voted by an outside manager), our firm and/or the client shall instruct
the qualified custodian to forward to copies of all proxies and shareholder communications relating to
the client’s investment assets.
Item 18: Financial Information
Our firm is not required to provide financial information in this Brochure because:
• Our firm does not require the prepayment of more than $1,200 in fees when services cannot be
rendered within 6 months.
• Our firm does not take custody of client funds or securities.
• Our firm does not have a financial condition or commitment that impairs our ability to meet
contractual and fiduciary obligations to clients.
• Our firm has never been the subject of a bankruptcy proceeding.
Our firm received financial assistance through the U.S. Small Business Administration’s (“SBA”)
Economic Injury Loan (“EIL”) program. The EIL program is intended to support small businesses in
response to the COVID-19 pandemic by providing low-interest loans and granting a $10,000 grant for
business essential purposes. Although our firm directly received funding from an outside entity, clients
are not obligated to partner with any SBA lenders nor is our firm directly affiliated with the SBA outside
of this unique situation. In addition, the funding is meant to provide relief to our firm’s current
operations and are not intended for soliciting business. Our firm has obtained financial assistance by
participating in the Paycheck Protection Program (“PPP”) established by the SBA. PPP is intended to
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assist us with maintaining our firm’s business in response to the COVID-19 pandemic by providing low-
interest loans for business essentials such as payroll expenses.
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