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Part 2A of Form ADV
Brochure
PO Box 321
Calistoga, CA 94515
415 497-7533
www.sonomawestadvisors.com
Updated: September 1, 2025
This brochure provides information about the qualifications and business practices of Sonoma
West Advisors (“Sonoma West” or “the firm”). If you have any questions about the contents of this
brochure, please contact us 415 497-7533. The information in this brochure has not been
approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any
state securities authority.
Sonoma West Advisors delivers its Form ADV Part II with each new client’s investment advisory
agreement. Following the signature of the investment advisory agreement, the client has 5 days
to unconditionally rescind the contract at no charge. Form ADV Part II is also provided annually
to existing clients if there are material changes or upon request.
Additional information about Sonoma West Advisors is also available on the SEC’s website at:
www.adviserinfo.sec.gov.
Material Changes
Effective September 1, 2025 the firm rebranded from its previous business name DTS Group to
Sonoma West Advisors. The firm’s business activities have not changed materially and there has
been no change in ownership. Ownership that existed prior to the rebranding remains the same
under Sonoma West LLC, a California Limited Liability Company. Sonoma West LLC is registered
as an investment advisor with the Securities and Exchange Commission. All required legal and
compliance matters have been addressed to make this change effective. This includes
notification to clients, counterparties, and regulators.
Table of Contents
Material Changes ................................................................................................................................................................... 2
Table of Contents ................................................................................................................................................................... 2
Advisory Business .................................................................................................................................................................. 2
Fees and Compensation ................................................................................................................................................... 3
Performance-Based Fees …………………………………………………………………………………………………………………………… 4
Types of Clients ...................................................................................................................................................................... 4
Methods of Analysis, Investment Strategies and Risk of Loss .............................................................. 4
Disciplinary Information ................................................................................................................................................... 5
Other Financial Industry Activities and Affiliations ..................................................................................... 5
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ....... 6
Brokerage Practices ............................................................................................................................................................. 7
Review of Accounts ..................................................................................................................................................... 10
Client Referrals and Other Compensation...................................................................................................... 10
Custody ........................................................................................................................................................................................ 10
Investment Discretion................................................................................................................................................ 10
Voting Client Securities ............................................................................................................................................. 11
Financial Information .................................................................................................................................................. .11
Advisory Business
Sonoma West provides investment management and financial advisory services to its clients,
consisting of high net worth individuals, families, associated trusts, corporate clients, charitable
organizations and other legal entities. Clients generally work with the firm under one or more
of the following arrangements:
• Under a discretionary arrangement – in which the client grants the firm the
discretion and authority to supervise, invest and trade assets placed under its
management consistent with established client objectives and guidelines
• Under a non-discretionary arrangement – in which the firm provides varying services
based upon mutual agreement
• Under a consulting arrangement – for varying consulting services based upon
mutual agreement
The firm may also provide some material elements of financial planning as needed to its clients.
Financial planning may include financial statement preparation and analysis, income tax
planning, education planning, risk management, retirement planning and estate planning. The
firm may or may not charge additional fees for financial planning.
In providing its services, the standard of care imposed upon the firm shall be to act with the
care, skill, prudence and diligence under the circumstances then prevailing that a prudent
person acting in a like capacity and familiar with such matters would use in the conduct of an
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enterprise of a like character and with like aims. Furthermore, whether the firm may acquire, or
not acquire, securities or property for itself or for any other client will not be considered in
determining the advisability of acquiring or not acquiring similar securities or property for the
portfolio account of any client.
Sonoma West, in consultation with each client, structures a portfolio to meet the investment
goals, risk tolerance and other guidelines as specified by the client. Client assets are generally
invested in open end, no-load mutual funds, exchange-traded funds or other pooled investment
vehicles. Under some circumstances, investments are made in individual equities or fixed
income securities and closed end mutual funds. Some client assets may be invested in certain
private investment funds or other separate account vehicles managed by other advisors.
Clients can place reasonable restrictions on the firm’s investment discretion. For example, some
clients have asked not to sell certain securities where the client has a particularly low tax basis.
Sonoma West was originally started as DTS Group LLC and was founded in 2005 by Noel Murphy
as its sole managing member. As of December 2021, the California Limited Liability Company
name was changed to Sonoma West, LLC.
As of September 1, 2025, the firm manages $220,000,000 on a discretionary basis and $45,000,000
on a non-discretionary basis on behalf of approximately 60 clients.
Fees and Compensation
Sonoma West charges most clients an annual investment management fee based on the
following schedule:
Assets under management
Annual Fee
On the first $2 million
Amounts in excess of $2 million & up to $5 million
Amounts in excess of $5 million & up to $10 million
Amounts in excess of $10 million
1.00%
0.85%
0.75%
0.50%
The firm is also following the practice of charging clients with assets in excess of $20m a fee of
0.25% (25 basis points) per annum excluding cash equivalent balances.
The basic hourly fee for non-discretionary accounts (primarily for individuals) is $400 per hour.
The total fees for such services will vary depending on the nature and complexity of each client’s
financial circumstances and the services authorized and performed.
Clients may direct the firm to maintain “unsupervised assets” within the portfolio for the
convenience of the client. The firm generally does not charge a management fee on
unsupervised assets and is not responsible for the supervision or suitability of such assets.
However, the firm may charge a fee on certain unsupervised assets such as the case when it is
asked to provide ongoing reporting or research of unsupervised private investments. To date, the
firm has not charged such fees to any clients. If it were, the firm would communicate this intention
in advance to the client and follow the provisions for fees specified in its standard advisory
agreement.
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The firm may negotiate a different investment advisory fee arrangement with the client,
including a flat fee arrangement based on the nature of the client’s account.
The firm has negotiated lower fees for certain clients, such as charitable organizations or family
members and friends.
The firm charges fees quarterly in advance based on the total market value of the account value
at the end of the prior quarter. The initial quarterly fee for a new client is pro-rated based upon the
date the client assets are transferred to the firm’s management or as negotiated between the firm
and the client.
Most clients authorize the firm to deduct fees automatically from their brokerage accounts,
but clients may request that the firm send quarterly invoices to be paid by check.
If a client terminates the investment management agreement with the firm in the middle of a
billing period, the firm will refund any unearned investment management fee to the client on a
pro-rata basis based upon the time remaining in the quarter.
In addition to investment management fees, clients bear trading costs and for certain
investments (i.e., private placements) the custodian may charge the client a nominal fee to
custody such investments.
To the extent that clients’ accounts are invested in mutual and exchange traded funds, these
funds pay a separate layer of management, trading, and administrative expenses.
Sonoma West believes its fees are competitive with those fees charged by other investment
advisors for comparable services. However, comparable services may be available from other
sources for lower fees than those charged by the firm.
Performance-Based Fees
Sonoma West does not charge any performance fees. It is the opinion of the firm that fees based
on performance can encourage a level of risk-taking that is not aligned with the interests of the
client. Some investment advisers experience conflicts of interest in connection with the side-by-
side management of accounts with different fee structures. However, these conflicts of interest
are not applicable to the firm.
Types of Clients
Sonoma West primarily provides customized investment management services to high-net-
worth individuals & associated trusts, estates, charitable organizations and other legal entities.
The firm’s minimum client size for new clients is generally $10,000,000 but this amount is
negotiable.
Methods of Analysis, Investment Strategies and Risk of Loss
The firm uses a variety of methods to evaluate the overall financial markets, asset classes and
various types of securities. The firm p er f orms i ts own internal research and analysis as well as
receives research and analysis from third parties. Additionally, the firm reviews statements and
reports provided by other investment advisors that provide investment management services to
firm clients. This analysis varies depending on the security in question.
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After developing an investment policy for each client, the firm creates an investment strategy.
This strategy integrates the client’s needs and goals with current developments in the economic
and financial markets.
The firm primarily invests for long time horizons. The firm’s investment philosophy is founded on
the premise that investors can build a strong, secure future by following a long-term investment
program, and by diversifying their investments across multiple asset classes and money
managers. However, market developments could cause the firm to sell securities more quickly.
Depending on a client’s investment objectives, the firm may engage in option writing. The use
of option writing poses additional risks that are discussed in detail with any clients who are
considering the use of these investment vehicles.
Mutual funds are an investment vehicle and the investment strategies, objectives and types of
securities utilized by mutual funds vary widely.
All mutual funds incur operating expenses in connection with the management of the
fund. Mutual funds pass some or all of these expenses through to their shareholders (the
individual investors in the funds) in the form of management fees. The management fees
charged vary from mutual fund to mutual fund. In addition, mutual funds charge shareholders
(individual investors in the funds) other types of fees such as a sales load or a transaction fee.
These charges also vary widely among funds.
The firm generally invests assets in no-load mutual funds. A “true” no-load mutual fund
assesses no Rule 12b-1 fee. Even though the firm invests in no-load funds, clients will still pay
management fees and expenses as charged by each mutual fund in which they are invested
in addition to those fees charged by the firm.
Closed end funds and other pooled investments vehicles have different expense structures.
Client is advised to consult with the firm regarding the various fee structures.
All investing involves a risk of loss and the investment strategy offered by t h e f i r m could lose
money over short or even long periods. Performance could be negatively impacted by a
number of different investment risks including but not limited to market risk, which is the chance
that overall markets will decline. Markets tend to move in cycles, with periods of rising prices and
periods of falling prices.
Disciplinary Information
The firm and its owner have never been involved in any legal or disciplinary events and have
never been the subject of a client complaint.
Other Financial Industry Activities and Affiliations
Sonoma West functions as an advisor and a fiduciary. As such, the firm does not have any
affiliations with banks, investment companies, brokerage firms, or private funds. In addition, the
firm does not receive any referral fees nor does it pay any referral fees for sources of outside
business.
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Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
The firm has adopted a written code of ethics that defines its standards. Among other
things, the code requires firm to act in clients’ best interests, abide by all applicable regulations,
avoid the appearance of insider trading, and avoid any conflicts of interests that would influence
its fiduciary responsibilities.
Sonoma West requirements:
Act with integrity, competence, diligence, respect, and in an ethical manner with
in the
the public, clients, prospective clients, employers, employees, colleagues
investment profession, and other participants in the global capital markets;
Place the integrity of the investment profession, the interests of clients, and above
personal interests;
Act with integrity, competence, diligence, respect, and in an ethical manner with the
public, clients, prospective clients, employers, employees, colleagues in the investment
profession, and other participants in the global capital markets;
Adhere to the fundamental standard that you should not take inappropriate advantage
of your position;
Avoid any actual or potential conflict of interest;
Conduct all personal securities transactions in a manner consistent with this policy;
Use
reasonable care and exercise
independent professional
investment analysis, making
investment
recommendations,
judgment when
taking
conducting
investment actions, and engaging in other professional activities;
Practice and encourage others to practice in a professional and ethical manner that
will reflect credit on yourself and the profession;
Promote the integrity of, and uphold the rules governing, capital markets;
Maintain and improve your professional competence and strive to maintain and
improve the competence of other investment professionals;
Comply with applicable provisions of the federal securities laws.
The firm’s restrictions on trading and standards apply to its principal and to family members
living in the same household.
The firm is permitted to buy and sell securities for personal investments and to invest in mutual
and exchange traded funds held by client accounts. In some cases, the firm may buy or sell funds
or securities that are also recommended to clients. To govern such transactions, the firm has
adopted a personal securities policy and procedure that outlines the timing and conditions under
which employees may buy or sell funds or securities when such funds or securities are also held
or traded by clients. The firm trading policy and procedure is designed to ensure that clients are
not disadvantaged in any way by the personal securities transactions of the firm.
Sonoma West may not provide gifts or entertainment to a client in excess of $100. The firm will
not accept any gifts or entertainment from a client.
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The firm holds client information in the strictest confidence and is mindful of the trust placed in
it by clients. It is the firm’s policy that no client information obtained by the firm is sold or made
available to third parties for any reason except that:
Third parties may be used assist in the management or maintenance of client accounts (such
as a custodian); and
Information may be released in accordance with applicable laws and regulations.
A copy of the firm code of ethics is available upon request.
Brokerage Practices
Brokers, dealers, and custodians are selected based upon a number of factors, including:
providing services of direct benefit to clients such as acting as custodian for the account,
providing services that facilitate trading, performance evaluation and other information on
securities, their inventory of securities and proven ability to execute, clear and settle transactions,
their ability to commit capital, ability to report promptly and accurately, provide prompt and
efficient delivery of securities, supply information on securities, including, but not limited to,
written and oral research reports, economic and financial data and financial publications.
The firm uses the Schwab Institutional division of Charles Schwab & Co., Inc. (“Schwab”), a FINRA-
registered broker-dealer, member SIPC, to maintain custody of clients’ assets and to effect
trades for their accounts. The firm generally recommends that clients establish brokerage
accounts with Schwab. The firm does not share in commissions generated by client trades
executed at Schwab. The firm has managed client assets held at Schwab for many years and
has found Schwab to offer good services at competitive prices. Although the firm may
recommend that clients establish accounts at Schwab, it is the client’s decision to custody assets
with Schwab or another custodian of the client’s choice. Sonoma West is independently owned
and operated and not affiliated with Schwab.
The firm primarily recommends that its clients invest in mutual & exchange traded funds and
separate account managers. As such, the firm does not face the same issues relating to best
execution that an adviser that regularly invests directly in equities and fixed income securities.
While not facing the same issues as an advisor that invests directly in equities, the firm will
periodically evaluate its primary broker-dealer / custodian to ensure that the overall relationship
is satisfying certain key criteria, including:
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Reasonableness of transaction fees and charges
Ability to maintain the confidentiality of trading intentions
Timeliness of execution and settlement
Timeliness and accuracy of trade confirmations
Client reporting capability
Custody services provided
Financial condition
Business reputation
The firm may continue to hold a security in one client account while selling it for another client
account. This occurs when client guidelines, risk tolerances, or tax considerations mandate a
sale for a particular client. In some cases, consistent with client objectives and risk, the firm may
purchase a security for one client while selling it for another.
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Client trades may be executed at different times at different prices due to the timing of
recommendations, certain security liquidity constraints, and specific client objectives, risk
tolerances, or tax considerations.
While executing transactions for equities and closed end funds, the firm generally uses market
orders. For fixed income transactions, firm generally obtains multiple bids or offers or may
transfer the fixed income security to a separate account manager to execute the trades since the
separate account manager has greater access to fixed income dealers. The separate account
manager is not affiliated with the firm.
Mutual funds recommended to clients may impose a redemption charge or similar fee, and the
overall cost structure of each fund is evaluated through the firm research process and prior to
recommending it as an investment option for clients
The firm receives certain products and services from Schwab free of charge or at discounted
rates.
• Schwab provides access to its institutional trading and custody services, which are
typically not available to Schwab retail investors. These services generally are available
to independent investment advisors on an unsolicited basis, at no charge to them
so long as a total of at least $10 million of the advisor’s clients’ assets are maintained
in accounts at Schwab Institutional. These services are not contingent upon the firm
committing to Schwab any specific amount of business (assets in custody or trading
commissions). Schwab’s brokerage services include the execution of securities
transactions, custody, research, and access to mutual funds and other investments
that are otherwise generally available only to institutional investors or would require
a significantly higher minimum initial investment. For client accounts maintained
in its custody, Schwab generally does not charge separately for custody services but is
compensated by account holders through commissions and other transaction-related
or asset based fees for securities trades that are executed through Schwab or that
settle into Schwab accounts.
• Schwab Institutional also makes available to the firm other products and services that
benefit the firm but may not benefit its clients’ accounts. Many of these products and
services may be used to service all or some substantial number of the firm’s
accounts, including accounts not maintained at Schwab. Schwab’s products and
services that assist the firm in managing and administering clients’ accounts include
software and other technology that (i) provide access to client account data (such as
trade confirmations and account statements); (ii) facilitate trade execution and
allocate aggregated trade orders for multiple client accounts; (iii) provide research,
pricing and other market data; (iv) facilitate payment of the firm’s fees from its clients’
accounts; and (v) assist with back-office functions, recordkeeping and client reporting.
• Schwab Institutional also offers other services intended to help the firm manage and
further develop its business enterprise. These services may include: (i) compliance,
legal and business consulting; (ii) publications and conferences on practice
management and business succession; and (iii) access to employee benefits providers,
human capital consultants and insurance providers.
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• Schwab may make available, arrange and/or pay third-party vendors for the types
of services rendered to the firm. Schwab Institutional may discount or waive fees it
would otherwise charge for some of these services or pay all or a part of the fees of a
third-party providing these services to the firm.
• Schwab Institutional may also provide other benefits such as educational events
or occasional business entertainment of firm personnel.
The firm does not believe that clients whose accounts are held by Schwab bear any additional
costs in connection with products and services. However, the firm would not receive these
products and services if client accounts were not held in custody and traded by Schwab. In
evaluating whether to recommend that clients custody their assets at Schwab, the firm may
take into account the availability of some of the foregoing products and services and other
arrangements as part of the total mix of factors it considers and not solely the nature, cost or
quality of custody and brokerage services provided by Schwab, which may create a potential
conflict of interest.
The Selection of Trading Counterparties
The firm can typically trade accounts held at Schwab using other broker/dealers. However,
Schwab charges clients trade-away fees that the firm believes outweigh any benefits from
trading stocks, mutual funds, or ETFs with other brokers. The availability and pricing of bonds
varies more widely, so prior to placing a bond trade the firm solicits bids from several dealers
and then executes the trade with the dealer that offers sufficient liquidity and the most
favorable pricing.
For clients who elect to have their accounts held by firms other than Schwab, the firm’s
approach is generally to trade stocks, mutual funds, and ETFs with the chosen custodian, and
to trade bonds with the dealer that offers sufficient liquidity and the most favorable pricing or
to transfer the bond to a fixed income separate account manager who has access to dealers
that offer sufficient liquidity and favorable pricing.
Best Execution Reviews
On a periodic basis the firm evaluates the pricing and services offered by Schwab and other
trading counterparties with those offered by other reputable firms. The firm as sought to make
a good-faith determination that Schwab and other chosen trading counterparties provide
clients with good services at competitive prices. However, clients should be aware that this
determination could have been influenced by the firm’s receipt of products and services from
Schwab. Historically the firm has concluded that Schwab is as good as, or better than, the other
firms that have been considered. The firm would notify its clients if it were to determine that
another firm offered better pricing and services than Schwab.
Client Referrals
The firm does not compensate Schwab or any other custodian or broker/dealer for referring client
accounts.
Trade Error Policy
The firm requires that its personnel carefully implement investment management decisions.
Nevertheless, if a trade error occurs, it is the firm’s policy that the error be corrected as soon as
possible and in such a manner that the affected client is not disadvantaged and bears no loss.
The firm’s policy prohibits its staff from requesting a broker-dealer to accept financial
responsibility for a trade error caused by personnel in exchange for the promise of future
compensation from commissions.
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Review of Accounts
Accounts under management are monitored on an ongoing basis by the firm Each account is
reviewed in detail on at least a weekly basis, as well as in connection with each client meeting or
more often as market conditions dictate. Sonoma West recommends a quarterly review with the
client, either in person, online or by telephone. Clients may request quarterly or semi-annual
reviews. As a practice, the firm communicates more than quarterly directly with its clients.
levels of
investment analytics. This portal
Clients receive account statements directly from their chosen independent custodian on a
monthly basis. In addition, clients have access to a secure investment portal to review accounts
online and apply varying
is accessed via
www.sonomawestadvisors.com and employs functionality developed by Envestnet, a leading
industry-standard client interface. This level of reporting is provided without cost to all clients
regardless of assets under management. The firm may supplement these custodial statements
with reports provided quarterly, during client meetings or as requested.
Client Referrals and Other Compensation
The firm does not pay any compensation to another investment adviser in connection with that
adviser’s referral of a client to the firm.
Custody
All clients’ accounts are held in custody by unaffiliated broker/dealers or banks, but the firm can
access many clients’ accounts through its ability to debit advisory fees. Apart from fee
arrangements, the firm does not hold custody of client assets.
Account custodians send statements directly to the account owners on at least a quarterly basis.
Clients should carefully review these statements, and should compare these statements to any
account information provided by the firm.
Investment Discretion
Sonoma West has investment discretion over the majority clients’ accounts. Clients grant th e
firm trading discretion through custodial firm limited power of attorney documents aligned with
their signed asset management agreement, which delegate discretionary authority that permits
the firm to choose the:
1. The selection of investments
2. The timing of any buys or sells
3. The broker-dealer to be used in the transaction
4. The commission rate to be paid to the broker-dealer that executes the transaction
Clients can and will place reasonable restrictions on the firm’s investment discretion. For
example, some clients have asked not to sell certain securities where the client has a particularly
low tax basis. In addition, clients have requested that no investments be made with certain
counterparties and in certain companies not aligned with their interests.
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Voting Client Securities
In accordance with its fiduciary duty to clients, the firm has adopted and implemented the policy
to not take responsibility for voting proxies, tender offers, rights offerings and other actions. The
firm instructs such issuer-related communications be sent to the client. In a small number of
circumstances, clients have requested that the firm advise on these communications as a
fiduciary.
Financial Information
The firm does not require or solicit any prepayments of fees three months or more in advance.
Sonoma West and its principal have never filed for bankruptcy. There are no financial conditions
condition that are expected to affect its ability to manage client accounts.
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