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Item 1: Cover Page
Stolz & Associates, PS
Form ADV Part 2A
Investment Adviser Brochure
3102 Ruston Way, Suite A
Tacoma, WA 98402
Phone: (253) 272-3441
www.stolzassoc.com
February 2026
This Brochure provides information about the qualifications and business practices of Stolz &
Associates, PS (“we,” “us,” “our”). If you have any questions about the contents of this
Brochure, please contact Michelle T. Robinson, Vice President and Chief Compliance Officer at
(253) 272-3441 or michelle@stolzassoc.com.
Additional information about our Firm is also available on the SEC’s website at
www.adviserinfo.sec.gov. 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.
We are a registered investment adviser. Please note that use of the term “registered
investment advisor” and a description of the Firm and/or our employees as “registered” does
not imply a certain level of skill or training. For more information on the qualifications of the
Firm and our employees who advise you, we encourage you to review this Brochure and the
Brochure Supplement(s).
Item 2: Summary of Material Changes
In this Item of Stolz & Associates, PS’s (the Firm, we, us, our, etc.) Form ADV 2, we are required to
discuss any material changes that have been made since our last Annual Amendment.
Material Changes since the Last Update
Since our Annual Amendment filing on March 13, 2025, we have the following material change
to report:
• This Form was amended to reflect the addition of a promoter relationship. Please see
Item 14: Client Referrals and Other Compensation.
Annual Update
You will receive a summary of any material changes to our Form ADV brochure within 120 days
of our fiscal year end. We may also provide updated disclosure information about material
changes on a more frequent basis. Any summaries of changes will include the date of the last
annual update of the ADV.
The Supplement to our Form ADV Brochure (Form ADV Part 2B) provides you with information
regarding our employees that provide investment advice.
Full Brochure Available
Our Form ADV may be requested at any time, without charge by contacting Michelle T.
Robinson, Vice President and Chief Compliance Officer at (253) 272-3441 or
michelle@stolzassoc.com. Additional information about the Firm is also available via the SEC’s
website at www.adviserinfo.sec.gov. The SEC’s website also provides information about any
employees affiliated with the Firm who are registered as investment adviser representatives.
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Item 3: Table of Contents
Item 1: Cover Page .......................................................................................................................... 1
Item 2: Summary of Material Changes ........................................................................................... 2
Item 4: Advisory Business ............................................................................................................... 4
Item 5: Fees and Compensation ..................................................................................................... 7
Item 6: Performance-Based Fees and Side-by-Side Management ............................................... 11
Item 7: Types of Clients ................................................................................................................. 12
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ......................................... 13
Item 9: Disciplinary Information ................................................................................................... 16
Item 10: Other Financial Industry Activities and Affiliations ........................................................ 17
Item 11: Code of Ethics, Participation or Interest in Client Transactions, Personal Trading........ 18
Item 12: Brokerage Practices ........................................................................................................ 18
Item 13: Review of Accounts ........................................................................................................ 21
Item 14: Client Referrals and Other Compensation ..................................................................... 22
Item 15: Custody ........................................................................................................................... 23
Item 16: Investment Discretion .................................................................................................... 25
Item 17: Voting Client Securities .................................................................................................. 26
Item 18: Financial Information ..................................................................................................... 27
Form ADV Part 2B – Investment Advisor Brochure Supplement ................................................. 28
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Item 4: Advisory Business
Firm Description and Types of Advisory Services
Stolz & Associates, PS (the “Firm,” “we,” “us,” or “our,”) is an investment adviser registered
with the Securities and Exchange Commission under the Investment Advisers Act of 1940, as
amended.
The Firm is a corporation formed in the State of Washington. We have been providing
investment advisory services to our clients since 2001. Our Firm is owned by Andrew C. Stolz
and Michelle T. Robinson.
As explained more fully in this Brochure, we provide asset management, financial planning and
consulting, and retirement plan consulting. We are dedicated to providing individuals, including
high net worth individuals, families, and retirement plans with a wide array of investment
advisory services.
Types of Advisory Services
We provide wealth management services, and retirement plan consulting. Our services may be
provided on a discretionary basis, meaning that we possess the discretion to buy and sell
individual stocks, bonds, and other investments. Each of our asset management services is
briefly described below.
Wealth Management
As part of our wealth management services, we provide a variety of financial planning to
individuals, families and other clients based upon an analysis of the client’s current situation,
goals, and objectives. Our plan may encompass one or more of the following: investment
planning; retirement planning; estate planning; divorce consulting; charitable planning;
education planning; corporate and personal tax planning; corporate structure; real estate
analysis; mortgage/debt analysis; insurance analysis; lines of credit evaluation; and business
and personal financial planning. Our financial plans usually include general recommendations
for a course of activity and may include specific actions to be taken by the clients. For example,
we may advise clients to begin or revise investment programs, create or revise wills or trusts,
obtain or revise insurance coverage, commence or alter retirement savings rates, or establish
education or charitable giving programs.
Once a financial plan is developed, we create individual investment portfolios, which may
consist of individual stocks or bonds, exchange traded funds (“ETFs”), mutual funds, non-
commission annuities and other public and private securities or investments. Each client’s
portfolio is tailored to an individual investment strategy and to specific goals and objectives and
may include some or all of the previously mentioned securities. Once the appropriate portfolio
has been determined, we review the portfolio at least annually and, as necessary, we rebalance
the portfolio based upon the client’s needs and stated goals and objectives. We may exercise
discretion over the investment of the portfolio, or a portfolio may be maintained on a
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nondiscretionary basis. When granted discretionary authority, we will direct the investment
and reinvestment of the assets in the client account(s) in securities and/or cash or cash
equivalents. Alternatively, we may be granted non-discretionary authority, obtaining client
consent prior to placing investment transactions on behalf of the client.
Retirement Plan Consulting
We offer various levels of advisory and consulting services to employee benefit plans and to the
participants of such plans (“Participants”). These services are designed to assist plan sponsors
(“Plan Sponsors”) in meeting their management and fiduciary obligations to the Participants
under the Employee Retirement Income Securities Act (“ERISA”) and the Pension Protection Act
of 2006 (“PPA”). We will provide services to Plan Sponsors and their Participants as described
below. Generally, investment advice provided to Plan Sponsors and Participants is regulated
under ERISA and the PPA. Plan Sponsors must make the ultimate decision to retain us for
retirement plan consulting and other advisory services including, but not limited to, services at
the participant level. The Plan Sponsor is free to seek independent advice about the
appropriateness of any recommended services for the plan.
In this role, we may review some or all of the following areas: overview, investor circumstances,
tax policy, reviews, diversification and investment constraints, selection/retention criteria for
investments, investment monitoring and control procedures, and duties and responsibilities.
Services include: Management of vendor relationships; Request for Proposals (“RFPs”);
Assistance on plan design strategies; Fiduciary consulting and oversight; Investment
Management; and Employee Education and Communication Services.
Advisory services provided to retirement plans may be solely provided by IARs, or in
combination with third parties and their retirement plan services.
Tailored Relationships
All of our advice is based on an assessment of each client’s individual needs, which we identify
at the onset of each relationship using, as appropriate, client questionnaires and profiles, a
review of existing investments and financial status, and other means. We review each client’s
individual investments and investment profile at least annually. When a client’s investment
profile needs a change, we receive notice or additional information and then modify our advice,
as appropriate.
If we manage a client’s portfolio, we permit a client to impose restrictions on the types of
investments that are acquired or held. These restrictions must be reasonable and practicable
and permit us to manage the account without undue difficulty. If we do not directly manage a
client’s portfolio, such as when a third-party manager is designated, individually imposed
restrictions on investments are generally not permitted.
Fiduciary Statement
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment
advice to you regarding your retirement plan account or individual retirement account, we are
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also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act,
(“ERISA”) and/or the Internal Revenue Code, (“IRC”), as applicable, which are laws governing
retirement accounts.
We have to act in your best interest and not put our interest ahead of yours. At the same time,
the way we make money creates some conflicts with your interests. We must take into
consideration each client’s objectives and act in the best interests of the client. We are
prohibited from engaging in any activity that is in conflict with the interests of the client. We
have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial
circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented
in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to
provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably.
Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material
fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as
fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client.
We will act with competence, dignity, integrity, and in an ethical manner, when working with
clients. We will use reasonable care and exercise independent professional judgement when
conducting investment analysis, making investment recommendations, trading, promoting our
services, and engaging in other professional activities.
Assets Under Management
As of December 31, 2025, we managed $282,195,649 in client assets, $253,170,912 managed
on a discretionary basis, and $29,024,737 on a non-discretionary basis.
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Item 5: Fees and Compensation
This item describes the fees we charge for our advisory services and how our fees are
calculated and paid.
Investment Advisory Services
Wealth Management Fees
For wealth management services, clients pay fees based on a percentage of their assets under
management, by household. As disclosed in the client’s engagement letter, the maximum fee
schedule is below.
PERCENTAGE OF ASSETS UNDER MANAGEMENT*
Household Assets Under Management Maximum Annual Fee
$0 to $1,000,000
$1,000,001 to $2,500,000
$2,500,001 to $5,000,000
$5,000,001 and above
1.25%
1.00%
0.40%
0.20%
Our maximum fees (above) are negotiable under appropriate circumstances and as a result, not
all clients pay the same fee. When we negotiate fees, we may consider factors such as the fees
that our client has paid to a competitor for similar services, the totality of our relationship with
the client, the potential for future business and the complexity of the client’s investment
strategy.
Retirement Plan Consulting
For retirement plan consulting, we charge an annual fee of 0.75% to 1.00% of the total plan assets.
Fees are paid quarterly in advance or arrears and paid by either the Plan Sponsor or Plan
Participants. The type and amount of the fees charged are negotiable and are generally based on
the size and complexity of the plan, the number of Plan Participants, the location of the
Participants, the estimated number of meetings required, and other factors that may be deemed
relevant by us when negotiating with the client.
Calculation and Payment
Fees for Our Advisory Services
Fees that are billed quarterly in advance are based on the value of each client’s household assets
on the last trading day of the previous quarter. Fees billed in arrears are based on the average
daily balance of the accounts.
Each client provides us with the authorization for the direct debit of our fee and other applicable
fees and charges (primarily transaction charges) from their account when an account is first
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established. Statements are provided at least quarterly by each account’s custodian that
indicate all disbursements, including advisory fees paid to us.
Fees for accounts that are maintained for less than a full billing period will be prorated. Fees that
are collected in advance will be prorated and returned, without interest, if an account is
terminated before the billing period ends.
Cash Balances
Some of your assets may be held as cash and remain uninvested. Holding a portion of your
assets in cash and cash alternatives, i.e., money market fund shares, may be based on your
desire to have an allocation to cash as an asset class, to support a phased market entrance
strategy, to facilitate transaction execution, to have available funds for withdrawal needs or to
pay fees or to provide for asset protection during periods of volatile market conditions. Your
cash and cash equivalents will be subject to our investment advisory fees unless otherwise
agreed upon. You may experience negative performance on the cash portion of your portfolio if
the investment advisory fees charged are higher than the returns you receive from your cash.
Retirement Plan Rollover Recommendations
As part of our investment advisory services to our clients, we may recommend that clients roll
assets from their employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account
(collectively, a “Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP
IRA, Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will advise on the
client’s behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from
Plan Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts.
If the client elects to roll the assets to an IRA that is subject to our advisement, we will charge
the client an asset-based fee as set forth in the advisory agreement the client executed with our
firm. This creates a conflict of interest because it creates a financial incentive for our firm to
recommend the rollover to the client (i.e., receipt of additional fee-based compensation).
Clients are under no obligation, contractually or otherwise, to complete the rollover. Moreover,
if clients do complete the rollover, clients are under no obligation to have the assets in an IRA
advised on by our firm. Due to the foregoing conflict of interest, when we make rollover
recommendations, we operate under a special rule that requires us to act in our clients’ best
interests and not put our interests ahead of our clients’.
Under this special rule’s provisions, we must:
• meet a professional standard of care when making investment recommendations (give
prudent advice);
• never put our financial interests ahead of our clients’ when making recommendations
(give loyal advice);
• avoid misleading statements about conflicts of interest, fees, and investments;
•
follow policies and procedures designed to ensure that we give advice that is in our
clients’ best interests;
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• charge no more than a reasonable fee for our services; and
• give clients basic information about conflicts of interest.
Many employers permit former employees to keep their retirement assets in their company
plan. Also, current employees can sometimes move assets out of their company plan before
they retire or change jobs. In determining whether to complete the rollover to an IRA, and to
the extent the following options are available, clients should consider the costs and benefits of
a rollover. Note that an employee will typically have four options in this situation:
1. leaving the funds in the employer’s (former employer’s) plan;
2. moving the funds to a new employer’s retirement plan;
3. cashing out and taking a taxable distribution from the plan; or
4. rolling the funds into an IRA rollover account.
Each of these options has positives and negatives. Because of that, along with the importance
of understanding the differences between these types of accounts, we will provide clients with
an explanation of the advantages and disadvantages of both account types and document the
basis for our belief that the rollover transaction we recommend is in your best interests.
General Information on Compensation and Other Fees
In certain circumstances, fees, account minimums, and payment terms are negotiable
depending on client’s unique situation – such as the size of the aggregate related party
portfolio size, family holdings, low-cost basis securities, or certain passively advised investments
and pre-existing relationships with clients. Certain clients may pay more or less than others
depending on the amount of assets, type of portfolio, or the time involved, the degree of
responsibility assumed, complexity of the engagement, special skills needed to solve problems,
the application of experience and knowledge of the client’s situation.
• Custodial and similar fees and costs are customarily associated with the maintenance of
•
a custody or brokerage account.
Internal expenses associated with products such as mutual funds and ETFs, including
investment management and 12b-1 fees. These internal expenses are typically
calculated as a percentage of the fund’s assets under management. Some of these fees
are retained by the product issuers, and some are paid to third parties, such as a
custodian, for services including the maintenance of shareholder accounts and the
distribution of prospectuses and similar items. More information about specific
expenses charged by a fund or ETF may be found in the applicable prospectus. Because
these expenses are directly deducted from a fund’s assets, they have the effect of
reducing the performance of the investment.
• Products, primarily mutual funds, may have multiple share classes, each class with
different fee and compensation structures, which may include deferred sales charges.
Charges for internal expenses may also differ among share classes, including investment
management fees and 12b-1 fees. Mutual fund shares may be subject to these fees and
expenses, and we may acquire shares other than those designated specifically for
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advisory or institutional accounts. Lower cost share classes for the same mutual fund
may be available through another arrangement.
• Other types of charges and expenses may be incurred, including mark-ups and mark-
downs, odd-lot differentials, spreads paid to market makers from whom securities were
obtained, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes
on brokerage and securities transactions.
Fees and Expenses (Mutual Funds Share Class)
Funds generally offer multiple share classes available for investment based upon certain
eligibility and/or purchase requirements. For instance, in addition to retail share classes
(typically referred to as class A, class B and class C shares), funds may also offer institutional
share classes or other share classes that are specifically designed for purchase by investors who
meet certain specified eligibility criteria, including, for example, whether an account meets
certain minimum dollar amount thresholds or is enrolled in an eligible fee-based investment
advisory program. Institutional share classes usually have a lower expense ratio than other
share classes.
The appropriateness of a particular fund share class selection is dependent upon a range of
different considerations, including but not limited to: the asset-based advisory fee that is
charged, whether transaction charges are applied to the purchase or sale of funds, operational
considerations associated with accessing or offering particular share classes (including the
presence of selling agreements with the fund sponsors and the Firm’s ability to access
particular share classes through the custodian), share class eligibility requirements; and the
availability of revenue sharing, distribution fees, shareholder servicing fees or other
compensation associated with offering a particular class of shares.
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Item 6: Performance-Based Fees and Side-by-Side Management
“Performance-based fees” are fees based on the capital gains or capital appreciation in an
account. We do not charge performance-based fees.
“Side-by-side management” refers to the practice of managing both accounts that are charged
a performance-based fee and accounts that are charged other types of fees, such as asset-
based fees and hourly fees. Because we do not charge performance-based fees, we do not
engage in side-by-side management.
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Item 7: Types of Clients
Types of Clients
• We provide services to: Individuals, including high net worth individuals;
• Pension and profit-sharing plans; and
• Trusts, Estates or Charitable organizations.
Account Minimums
We do not have minimum requirements for opening and maintaining accounts or otherwise
engaging us, unless otherwise specified by the account custodian.
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Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Before selecting an adviser, each client should obtain specific information about the investment
analysis and strategies used by a particular adviser and consider the risk of loss associated with
the adviser’s strategies. Below is general information about the analysis and strategies that may
be used by our advisers and the risk of loss associated with various types of investments.
Fundamental Analysis: Fundamental analysis is used to measure the intrinsic value of a security
by looking at economic and financial factors (including the overall economy, industry
conditions, and the financial condition and management of the company itself) to determine if
the security is underpriced (indicating it may be a good time to buy) or overpriced (indicating it
may be time to sell). Fundamental analysis does not attempt to anticipate market movements,
which may present a potential risk since the price of a security may move up or down with the
overall market regardless of the economic and financial factors considered in evaluating the
stock.
Technical Analysis: Using technical analysis, we analyze past market movements and use the
analysis to recognize recurring patterns of investor behavior and to predict future price
movement. Technical analysis does not consider the intrinsic value of a security, which may
present a risk since a poorly managed or financially unsound company may underperform
regardless of market movement.
Efficient Market Hypothesis: Using Efficient Market Hypothesis, we assert that financial
markets are “informationally efficient” or in other words, one cannot achieve returns in excess
of average market returns on a risk-adjusted basis, given the information publicly available at
the time the investment is made. There are three major versions of this hypothesis:
Weak Efficient Market Hypothesis: Proposes that prices on traded assets (e.g., stocks, bonds,
or property) already reflect all past publicly available information.
Semi-Strong Efficient Market Hypothesis: Proposes both that prices reflect all publicly available
information and that prices instantly change to reflect new public information.
Strong Efficient Market Hypothesis: Proposes both that prices reflect all publicly available
information and that prices instantly change to reflect new public information. Additionally,
price prices instantly change to reflect even hidden or “insider” information.
Investment Strategies
Our investment strategies and advice may vary depending upon each client's specific financial
situation. As such, we determine investments and allocations based upon your predefined
objectives, risk tolerance, time horizon, financial information, liquidity needs, and other various
suitability factors. Your restrictions and guidelines may affect the composition of your portfolio.
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It is important that you notify us immediately with respect to any material changes to your
financial circumstances, including for example, a change in your current or expected income
level, tax circumstances, or employment status.
The Firm’s philosophy centers on long-term investing (typically for more than one year) and the
use of the analysis of past performance of various assets classes to build diversified, low-cost,
passive portfolios as its goal. Risks associated with a long-term purchase strategy include that
we may not take advantage of short-term gains that could be profitable to a client or that a
security may decline sharply in value before we make the decision to sell.
Generally, we recommend investing in various mutual funds. A mutual fund is a managed type
of collective investment that pools money from many investors to buy securities (stocks, bonds,
short-term money market instruments, and/or other securities). A mutual fund has a fund
manager that trades (buys and sells) the fund's investments in accordance with the fund's
investment objective. It should be known that investing in any type of security may involve risk
of loss of principal.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear.
All investments involve the risk of loss, including (among other things) loss of principal, a
reduction in earnings (including interest, dividends and other distributions), and the loss of
future earnings. Although we manage the assets in a manner consistent with risk tolerances,
there can be no guarantee that our efforts will be successful. The investor should be prepared
to bear the following investment risks of loss:
•
Interest-rate Risk: Fluctuations in interest rates may cause investment prices to
fluctuate. For example, when interest rates rise, yields on existing bonds become
less attractive, causing their market values to decline.
• Market Risk: The price of a security, bond, or mutual fund may drop in reaction to
•
tangible and intangible events and conditions. This type of risk is caused by external
factors independent of a security’s particular underlying circumstances. For
example, political, economic and social conditions may trigger market events.
Inflation Risk: When any type of inflation is present, a dollar next year will not buy
as much as a dollar today, because purchasing power is eroding at the rate of
inflation.
• Currency Risk: Overseas investments are subject to fluctuations in the value of the
dollar against the currency of the investment’s originating country. This is also
referred to as exchange rate risk.
• Reinvestment Risk: This is the risk that future proceeds from investments may have
to be reinvested at a potentially lower rate of return (i.e., interest rate). This
primarily relates to fixed income securities.
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• Business Risk: These risks are associated with a particular industry or a particular
company within an industry. For example, oil-drilling companies depend on finding
oil and then refining it, a lengthy process, before they can generate a profit. They
carry a higher risk of profitability than an electric company, which generates its
income from a steady stream of customers who buy electricity no matter what the
economic environment is like.
• Liquidity Risk: Liquidity is the ability to readily convert an investment into cash.
Generally, assets are more liquid if many traders are interested in a standardized
product. For example, Treasury Bills are highly liquid, while real estate properties
(i.e., non-traded REITs and other alternative investments) are not.
• Financial Risk: Excessive borrowing to finance a business’ operations increases the
risk of profitability, because the company must meet the terms of its obligations in
good times and bad. During periods of financial stress, the inability to meet loan
obligations may result in bankruptcy and/or a declining market value.
• Cybersecurity Risk: A breach in cyber security refers to both intentional and
unintentional events that may cause an account to lose proprietary information,
suffer data corruption, or lose operational capacity. This in turn could cause an
account to incur regulatory penalties, reputational damage, and additional
compliance costs associated with corrective measures, and/or financial loss.
• Pandemic Risk: Large-scale outbreaks of infectious disease can greatly increase
morbidity and mortality over a wide geographic area, crossing international
boundaries, and causing significant economic, social, and political disruption.
• Custodial Risk: This risk is the probability that a party to a transaction will be unable
or unwilling to fulfill its contractual obligations either due to technological errors,
control failures, malfeasance, or potential regulatory liabilities.
It is not possible to list all risks associated with each class of securities or assets or each market
sector. Clients should consult their IAR for more information about specific risks that may be
associated with the adviser’s investment strategy.
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Item 9: Disciplinary Information
We are required to disclose all pertinent facts regarding any legal, regulatory, or disciplinary events
that would be material to your evaluation of the Firm or the integrity of our management.
There have never been any legal, regulatory, or disciplinary actions against the Firm or our
management persons.
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Item 10: Other Financial Industry Activities and Affiliations
We are required to disclose to our clients any relationship or arrangement with certain related
persons that is material to our advisory business.
Financial Industry Activities
We are not registered as a broker-dealer, and none of our management persons are registered
representatives of a broker-dealer.
Neither we, nor any of our management persons, is registered as (or associated with) a futures
commissions merchant, commodity pool operator, or a commodity trading advisor.
Neither we nor any of our management persons, have a material relationship or arrangement
with any related person or financial industry entities.
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Item 11: Code of Ethics, Participation or Interest in Client
Transactions, Personal Trading
Code of Ethics
We have a duty to exercise our authority and responsibility for the benefit of our clients, to
place the interests of our clients first, and to refrain from having outside interests that conflict
with the interests of our clients. We and our employees avoid any circumstances that might
adversely affect, or appear to affect, our duty of loyalty. We have adopted a Code of Ethics (the
Code); the Code’s key provisions include:
• Statement of general principles;
• Policy on and reporting of personal securities transactions;
• A prohibition on insider trading;
• Restrictions on the acceptance of significant gifts;
• Procedures to detect and deter misconduct and violations; and
• Requirement to maintain confidentiality of client information.
Our employees must acknowledge the terms of the Code at least annually, and any employee
not in compliance with the Code may be subject to termination. We will provide a copy of our
Code upon request.
Personal Trading Practices
Both the Firm and our employees may buy or sell securities identical to those recommended to
clients for their personal accounts. The Code, described above, is designed to assure that the
personal securities transactions, activities, and interests of the employees of the Firm will not
interfere with (i) making decisions in the best interest of clients and (ii) implementing such
decisions while, at the same time, allowing employees to invest for their own accounts. Under
the Code certain classes of securities, primarily mutual funds, have been designated as exempt
transactions, based upon a determination that these would materially not interfere with the
best interest of our clients. In addition, the Code requires pre-clearance of many transactions.
Nonetheless, because the Code in some circumstances would permit employees to invest in the
same securities as clients, there is a possibility that employees might benefit from market
activity by a client in a security held by an employee. The Firm may maintain a list of restricted
securities that employees may not purchase or sell based upon having (or possibly having)
access to inside information. Employee trading is continually monitored under the Code and
designed to reasonably prevent conflicts of interest between the Firm and our clients.
Participation or Interest in Client Transactions and Principal/Agency Cross Trades
We do not recommend any securities to our clients in which we have a material financial
interest. We do not affect any principal or agency cross securities transactions for client
accounts. We also do not cross trades between client accounts.
Item 12: Brokerage Practices
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Research and Other Soft Dollar Benefits
We do not receive soft dollars, products or services acquired with client brokerage
commissions.
We may receive from custodians, without cost or at a discount, non-soft-dollar support services
or products which are used to assist us to better monitor and service the client accounts we
maintain at such institutions. The support services we may receive include, but are not limited
to, investment-related research, pricing information and market data, software and other
technology, data, compliance or practice management related publications, consulting services,
attendance at conferences, meetings, and other educational or social events, marketing
support, computer hardware and software, and other products to assist us in our investment
advisory business operations. Our clients do not pay more for investment transactions effected
by or assets maintained at these custodians as a result of these arrangements. There is no
commitment made by us or any other custodian as a result of these arrangements.
Brokerage for Client Referrals
We do not receive client referrals from broker/dealers.
Directed Brokerage
While not routine, the client may direct us to use a particular broker dealer to execute some or
all transactions for the client. This brokerage direction must be requested by the client in
writing. In that case, the client will negotiate terms and arrangements for the account with that
broker-dealer, and we will not seek better execution services or prices from other broker-
dealers or be able to “batch” client transactions for execution through other broker-dealers
with orders for other accounts managed by us. By directing brokerage, the client may pay
higher commissions or other transaction costs or greater spreads, or receive less favorable net
prices, on transactions for the account than would otherwise be the case. Not all advisers
require or allow their clients to direct brokerage. Subject to its duty of best execution, we may
decline a client’s request to direct brokerage if, in our sole discretion, such directed brokerage
arrangements would result in additional operational difficulties.
If the client requests us to arrange for the execution of securities brokerage transactions for the
client’s account, we shall direct such transactions through broker-dealers that we reasonably
believe will provide best execution. The Firm generally suggests that clients use Schwab as their
custodian. This determination is factors in reasonableness of commissions, and other costs of
trading, ability to facilitate trades, access to client records, computer trading support, and other
operational considerations. We periodically and systematically review its policies and
procedures regarding recommending broker-dealers to our clients in light of its duty to seek
best execution.
19
Trade Aggregation
We and our employees may trade in the same securities with client accounts on an aggregated
basis when consistent with our obligation of best execution. In such circumstances, the
affiliated and client accounts will share commission costs equally and receive securities at a
total average price. We will retain records of the trade order (specifying each participating
account) and its allocation, which will be completed prior to the entry of the aggregated order.
Completed orders will be allocated as specified in the initial trade order. Partially filled orders
will be allocated on a pro rata basis. Any exceptions will be explained on the order.
20
Item 13: Review of Accounts
Reviews
We monitor client portfolios as part of an ongoing process, and regular account reviews are
generally conducted on a quarterly basis. Reviews could also occur at the time of new deposits,
material changes in the client’s financial information, changes in economic cycles, at our
discretion or as often as the client directs. Reviews entail analyzing securities, sensitivity to overall
markets, economic changes, investment results, asset allocation, etc., to ensure the investment
strategy and expectations are structured to continue to meet the client’s objectives. These
reviews are conducted by one of our Investment Advisor Representatives.
Clients are encouraged to discuss their needs, goals, and objectives with us and to inform us of
any changes.
Reporting
At least quarterly, the custodian provides clients with an account statement for each client
account, which may include individual holdings, cost basis information, deposits and withdrawals,
accrued income, dividends, and performance. We may also provide clients with periodic reports
regarding their holdings, allocations, and performance.
21
Item 14: Client Referrals and Other Compensation
Other Compensation for Advisory Services
We do not receive any formal economic benefits (other than normal compensation) from any
firm or individual for providing investment advice.
See disclosure in Item 12 regarding compensation, including economic benefits received in
connection with giving advice to clients.
Compensation – Client Referrals
Affiliated and Unaffiliated persons or entities, (“Promoters”) may, from time to time refer,
solicit, or introduce clients to our Firm. We may compensate certain Promoters consistent with
the requirements of the Investment Advisers Act of 1940 as well as applicable state/local laws
and regulations.
22
Item 15: Custody
Custody – Fee Debiting
The client agreement authorizes us to deduct advisory fees directly from the client’s account at
the custodian. We send the amount of the quarterly fee to the custodian. With the exception of
the ability to debit client accounts for advisory fees, we do not and will not have custody of
clients’ funds or securities. Client assets shall be held in the custody of a bank, trust company or
brokerage firm agreed upon by the client and us.
The custodian is advised in writing of the limitation of our access to the account. The custodian
sends a statement to the client, at least quarterly, indicating all amounts disbursed from the
account including the amount of advisory fees paid directly to us.
Custody – First Party Money Transfers
Clients may provide us with written ongoing authorization to ACH money between the client’s
accounts held with the qualified custodian directly to an outside financial institution (i.e., a
client’s bank account). A copy of this authorization is provided to the qualified custodian. The
authorization includes the client’s account number(s) at the outside financial institution(s) as
required.
Custody – Third Party Money Transfers
Clients may provide us with a standing letter of authorization (or similar asset transfer
authorization) which allows us to disburse funds on behalf of clients to third parties. We ensure
the following conditions are in place when deemed to have custody via third party money
movement:
• The client provides a Written Authorization to the custodian that includes all
appropriate information as to how the transfer should be directed;
• The Written Authorization includes instruction to direct transfers to the third party
either on a specified schedule or from time to time;
• Appropriate verification is performed by the custodian, along with a transfer of funds
notice to the client promptly after each transfer;
• The client may terminate or change the instruction to the custodian;
• We have no authority or ability to designate or change any information about the third
party contained in the instruction;
• We maintain records showing that the third party is not a related party of the Firm or
located at the same address as the Firm; and
• The custodian sends the client a written initial notice confirming the instruction and an
annual written confirmation thereafter.
Custody – Account Statements
Clients receive at least quarterly statements from the custodian that holds and maintains
client’s investment assets. Clients are urged to carefully review such statements and compare
23
such official custodial records to the reports that we provide. Our reports may vary from
custodial statements based on accounting procedures, reporting dates, or valuation
methodologies of certain securities.
24
Item 16: Investment Discretion
For advisory accounts and certain retirement plan consulting engagements, we are granted a
limited power of attorney in favor of the Firm, permitting us to exercise full discretion as to the
nature, type and amount of securities to be purchased without preapproval by the client. Our
exercise of discretion may be limited by any investment guidelines and objectives that are
furnished by a client or that we develop with the client and by any restrictions on investment
that we have accepted and agreed to administer.
If we have not been given discretionary authority, we will consult with the client prior to each
trade.
25
Item 17: Voting Client Securities
Proxy Voting
We do not have any authority to and do not vote proxies on behalf of clients, nor do we make
any express or implied recommendation with respect to voting proxies. Clients retain the sole
responsibility for receiving and voting proxies that they receive directly from either their
custodian or transfer agents. Clients may contact us for information about proxy voting.
26
Item 18: Financial Information
We have no financial commitment that impairs our ability to meet contractual and fiduciary
commitments to clients and have not been the subject of a bankruptcy proceeding.
We do not require prepayment of fees of either more than $1,200 per client, and more than six
months in advance; and therefore, is not required to provide a balance sheet to clients.
27
Form ADV Part 2B – Investment Advisor Brochure Supplement
Stolz & Associates, PS
Form ADV Part 2B
Investment Advisor Brochure Supplement
3102 Ruston Way, Suite A
Tacoma, WA 98402
Phone: (253) 272-3441
www.stolzassoc.com
Andrew C. Stolz
February 2026
This Brochure Supplement provides information about the Firm’s (“we,” “us,” “our”) employees
that supplements our Brochure. You should have received a copy that Brochure. Please contact
Michelle T. Robinson, Vice President and Chief Compliance Officer at (253) 272-3441 or
michelle@stolzassoc.com if you did not receive our Brochure or if you have any questions
about the contents of this Supplement.
Additional information about our employee(s) referenced above is also available on the SEC’s
website at www.adviserinfo.sec.gov. You may search this site using a unique identifying
number, known as a CRD number for each employee.
28
Item 2: Educational Background and Business Experience
Born 1986
Andrew C. Stolz
CRD #: 5721796
Business Background:
Stolz & Associates, PS
President and Chief Investment Officer
Vice President and Chief Investment Officer
2021 to Present
2019 to 2021
2018 to 2019
Stolz & Associates, PS
Wealth Planner
2016 to 2018
BNY Mellon Wealth Management
Wealth Manager
2013 to 2016
BNY Mellon Wealth Management
Associate Wealth Manager
2011 to 2013
Stolz & Associates, PS
Financial Analyst
2009 to 2010
Edward Jones
Financial Advisor
Formal Education after High School:
Pacific Lutheran University
Master of Science in Finance
Pacific Lutheran University
Bachelor's in Business Administration
Professional Designations:
Chartered Financial Analyst® (CFA®)
Certified Exit Planning Advisor (CEPA®)
Professional Certifications
Andrew C. Stolz maintains professional designations, which requires the following minimum
requirements:
29
Chartered Financial Analyst® (CFA®)
Issued By
CFA Institute
Candidate must meet one of the following requirements prior to
enrollment:
• Hold a bachelor’s or equivalent degree from a
college/university;
• Be within 11 months of the graduation month for a
bachelor’s degree or equivalent program by the date of
sitting for the Level I exam; or
Prerequisites
• Have a combination of 4,000 hours of work experience
and/or higher education that was acquired over a
minimum of three sequential years by the date of
enrolling for the Level I exam;
• Have 4,000 hours of qualified work experience in the
investment decision-making process (accrued before, during,
or after participation in the CFA Program); and
• Submit two-to-three professional reference letters.
Candidate must complete the following:
• Self-study program (250 hours of study for each of the 3
Education
Requirements
levels)
Three in-person, proctored, closed-book, computer-based exams
None
Exam Type
Continuing Education
Requirements
Certified Exit Planning Advisor (CEPA®)
Issued By
Exit Planning Institute
Candidate must meet all of the following requirements:
• Five years of full-time or equivalent experience working
directly with business owners as a financial advisor, attorney,
CPA, business broker, investment banker, commercial
lender, estate planner, insurance professional, business
consultant or in a related capacity
Prerequisites
• Undergraduate degree from a qualifying institution; if no
qualifying degree must submit additional professional work
experience (two years of relevant professional experience
may be substituted for each year of required undergraduate
studies
• Exit Planning Institute member in good standing
Five-day educational program
Final exam (multiple-choice, proctored, closed book)
40 hours every three years
Education
Requirements
Exam Type
Continuing Education
Requirements
30
Item 3: Disciplinary Information
Andrew C. Stolz has not been involved in any activities resulting in a disciplinary disclosure.
Item 4: Other Business Activities
Andrew C. Stolz does not have any outside business activities.
Item 5: Additional Compensation
Andrew C. Stolz does not receive any economic benefit outside of regular salaries or bonuses.
Item 6: Supervision
Michelle T. Robinson, Vice President and Chief Compliance Officer, supervises the persons
named in this Form ADV Part 2B Investment Advisor Brochure Supplement. Michelle T.
Robinson supervises this person by holding regular staff, investment, and other ad hoc
meetings. In addition, Michelle T. Robinson regularly reviews client reports, emails and trading,
as well as employee’s personal securities transaction and holdings reports. Michelle T. Robinson
may be reached at (253) 272-3441.
31
Form ADV Part 2B – Investment Advisor Brochure Supplement
Stolz & Associates, PS
Form ADV Part 2B
Investment Advisor Brochure Supplement
3102 Ruston Way, Suite A
Tacoma, WA 98402
Phone: (253) 272-3441
www.stolzassoc.com
Michelle T. Robinson
February 2026
This Brochure Supplement provides information about the Firm’s (“we,” “us,” “our”) employees
that supplements our Brochure. You should have received a copy that Brochure. Please contact
Michelle T. Robinson, Vice President and Chief Compliance Officer at (253) 272-3441 or
michelle@stolzassoc.com if you did not receive our Brochure or if you have any questions
about the contents of this Supplement.
Additional information about our employee(s) referenced above is also available on the SEC’s
website at www.adviserinfo.sec.gov. You may search this site using a unique identifying
number, known as a CRD number for each employee.
32
Item 2: Educational Background and Business Experience
Born 1967
Michelle T. Robinson
CRD #: 5250539
2007 to Present
Business Background:
Stolz & Associates, PS
Vice President and Chief Compliance Officer
2001 to 2007
Stolz & Associates, PS
Account Manager
Professional Designations:
CERTIFIED FINANCIAL PLANNERTM (CFP®)
Professional Certifications
Michelle T. Robinson maintains a professional designation, which require the following
minimum requirements:
CERTIFIED FINANCIAL PLANNER™ (CFP®)
Issued By
Certified Financial Planner Board of Standards, Inc.
Candidate must meet the following requirements:
• A bachelor’s degree (or higher) from an accredited college or
Prerequisites
university, and
• 3 years of full-time personal financial planning experience
Candidate must complete a CFP®-board registered program, or hold
one of the following:
Education
Requirements
CPA
ChFC®
Chartered Life Underwriter® (CLU®)
CFA®
Ph.D. in business or economics
Doctor of Business Administration
Attorney's License
•
•
•
•
•
•
•
CFP® Certification Examination
30 hours every 2 years
Exam Type
Continuing Education
Requirements
Item 3: Disciplinary Information
Michelle T. Robinson has not been involved in any activities resulting in a disciplinary disclosure.
33
Item 4: Other Business Activities
Michelle T. Robinson does not have any outside business activities.
Item 5: Additional Compensation
Michelle T. Robinson does not receive any economic benefit outside of regular salaries or
bonuses.
Item 6: Supervision
Andrew C. Stolz, President and Chief Investment Officer, supervises the persons named in this
Form ADV Part 2B Investment Adviser Brochure Supplement. Andrew C. Stolz supervises this
person by holding regular staff, investment, and other ad hoc meetings. In addition, Andrew C.
Stolz regularly reviews client reports, emails and trading, as well as employee’s personal
securities transaction and holdings reports. Andrew C. Stolz may be reached at (253) 272-3441.
34
Form ADV Part 2B – Investment Advisor Brochure Supplement
Stolz & Associates, PS
Form ADV Part 2B
Investment Advisor Brochure Supplement
3102 Ruston Way, Suite A
Tacoma, WA 98402
Phone: (253) 272-3441
www.stolzassoc.com
Derek C. Dzingle
February 2026
This Brochure Supplement provides information about the Firm’s (“we,” “us,” “our”) employees
that supplements our Brochure. You should have received a copy that Brochure. Please contact
Michelle T. Robinson, Vice President and Chief Compliance Officer at (253) 272-3441 or
michelle@stolzassoc.com if you did not receive our Brochure or if you have any questions
about the contents of this Supplement.
Additional information about our employee(s) referenced above is also available on the SEC’s
website at www.adviserinfo.sec.gov. You may search this site using a unique identifying
number, known as a CRD number for each employee.
35
Item 2: Educational Background and Business Experience
Born 1998
Derek C. Dzingle
CRD #: 3268892
2026 to Present
Business Background:
Stolz & Associates, PS
Wealth Manager
2024 to 2026
Stolz & Associates, PS
Associate Wealth Manager
2022 to 2024
Stolz & Associates, PS
Client Service Coordinator
2021 to 2022
Mercer
Health & Benefits Consulting Analyst
2020 to 2020
Our National Conversation
Lead Economics Intern
Formal Education after High School:
Gonzaga University
Bachelor of Science in Economics, Minor in Mathematics and Political Science
Professional Designations:
CERTIFIED FINANCIAL PLANNERTM (CFP®)
Professional Certifications
Derek C. Dzingle maintains a professional designation, which requires the following minimum
requirements:
CERTIFIED FINANCIAL PLANNER™ (CFP®)
Issued By
Certified Financial Planner Board of Standards, Inc.
Candidate must meet the following requirements:
• A bachelor’s degree (or higher) from an accredited college or
Prerequisites
university, and
• 3 years of full-time personal financial planning experience
Candidate must complete a CFP®-board registered program, or hold
one of the following:
Education
Requirements
CPA
ChFC®
Chartered Life Underwriter® (CLU®)
•
•
•
36
CFA®
Ph.D. in business or economics
Doctor of Business Administration
Attorney's License
•
•
•
•
CFP® Certification Examination
30 hours every 2 years
Exam Type
Continuing Education
Requirements
Item 3: Disciplinary Information
Derek C. Dzingle has not been involved in any activities resulting in a disciplinary disclosure.
Item 4: Other Business Activities
Derek C. Dzingle does not have any outside business activities.
Item 5: Additional Compensation
Derek C. Dzingle does not receive any economic benefit outside of regular salaries or bonuses.
Item 6: Supervision
Michelle T. Robinson, Vice President and Chief Compliance Officer, supervises the persons
named in this Form ADV Part 2B Investment Advisor Brochure Supplement. Michelle T.
Robinson supervises this person by holding regular staff, investment, and other ad hoc
meetings. In addition, Michelle T. Robinson regularly reviews client reports, emails and trading,
as well as employee’s personal securities transaction and holdings reports. Michelle T. Robinson
may be reached at (253) 272-3441.
37