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Wager Wealth Management and Financial Planning, LLC
4204 Redmond Dr.
Longmont, CO 80503
P: 720-745-5010
February 20, 2026
Part 2A Brochure
This brochure provides information about the qualifications and business practices of Wager Wealth
Management and Financial Planning, LLC (“WWM”). If you have any questions about the contents of this
brochure, please contact us at 720-745-5010. 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.
WWM is a Registered Investment Adviser. Registration with the United States Securities and Exchange
Commission or any state securities authority does not imply a certain level of skill or training.
Additional information about Wager Wealth Management and Financial Planning is available on the SEC’s
website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a
CRD number. The CRD number for Wager Wealth Management and Financial Planning, LLC is 285107.
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ITEM 2 – MATERIAL CHANGES
Summary of Material Changes
This section of the Brochure will address only those “material changes” that have been
incorporated since our last delivery or posting of this document on the SEC’s public
disclosure website (IAPD) www.adviserinfo.sec.gov.
The following material changes have occurred since our last annual amendment filing
dated January 28, 2025.
There are no material changes to report.
If you would like another copy of this Brochure, please download it from the SEC Website
as indicated above or you may contact our Chief Compliance Officer, Glenn Wager at 720-
745-5010 or glenn@wagerwm.com.
We encourage you to read this document in its entirety.
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ITEM 3 – TABLE OF CONTENTS
ITEM 2 – MATERIAL CHANGES ................................................................................................2
ITEM 3 – TABLE OF CONTENTS ................................................................................................3
ITEM 4 – ADVISORY BUSINESS ................................................................................................4
ITEM 5 - FEES AND COMPENSATION .......................................................................................7
ITEM 6 - PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT .................................9
ITEM 7 - TYPES OF CLIENTS .....................................................................................................9
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS .................... 10
ITEM 9 - DISCIPLINARY INFORMATION .................................................................................. 13
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS .................................. 13
ITEM 11 - CODE OF ETHICS PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND
PERSONAL TRADING ............................................................................................................ 13
ITEM 12 - BROKERAGE PRACTICES ........................................................................................ 15
ITEM 13 - REVIEW OF ACCOUNTS.......................................................................................... 19
ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION ................................................... 20
ITEM 15 - CUSTODY .............................................................................................................. 20
ITEM 16 - INVESTMENT DISCRETION ..................................................................................... 21
ITEM 17 - VOTING YOUR SECURITIES .................................................................................... 22
ITEM 18 - FINANCIAL INFORMATION .................................................................................... 22
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ITEM 4 – ADVISORY BUSINESS
This Disclosure document is being offered to you by Wager Wealth Management and
Financial Planning, LLC (“WWM”) in connection with the investment advisory services we
provide. It discloses information about the services that we provide and the manner in
which those services are made available to you, the client.
We are an investment management firm located in Colorado. The firm was established
by Glenn Wager in 2016. We specialize in investment advisory services for individuals,
institutions, families, trusts and estates. We are committed to helping clients build,
manage, and preserve their wealth, and to provide assistance that helps clients to achieve
their stated financial goals. We will offer an initial complimentary meeting upon our
discretion; however, investment advisory services are initiated only after you and WWM
execute an engagement letter or client agreement.
Investment and Wealth Management and Supervision Services
We offer discretionary investment management and investment supervisory services for
a fee based on a percentage of your assets under management. These services include
investment analysis, allocation of investments, quarterly portfolio statements, financial
commentaries, and ongoing monitoring of client portfolios. We primarily allocate client
assets among various mutual funds, exchange-traded funds (“ETFs”), and individual debt
(bonds) and equity securities in accordance with their stated investment objectives. Cash
and cash equivalents and any margin debt balances are included in the calculation of
advisory fees, unless otherwise noted and agreed to in the executed Agreement.
We will work with you to obtain necessary information regarding your financial condition,
investment objectives, liquidity requirements, risk tolerance, time horizons, and any
restrictions on investing. This information enables us to determine the portfolio best
suited for your investment objective and needs.
In performing our services, we shall not be required to verify any information received
from you or from other professionals. If you request, we may recommend and/or engage
the services of other professionals for implementation purposes. You have the right to
decide whether or not to engage the services of any such recommended professional.
Once we have determined the types of investments to be included in your portfolio and
allocated them, we will provide ongoing portfolio review and management services. This
approach requires us to review your portfolio at least quarterly.
We will rebalance the portfolio, as we deem appropriate, to meet your financial
objectives. We trade these portfolios and rebalance them based on the combination of
our market views and your objectives, using our investment process. We tailor our
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advisory services to meet the needs of our clients and seek to ensure that your portfolio
is managed in a manner consistent with those needs and objectives.
In all cases, you have a direct and beneficial interest in your securities, rather than an
undivided interest in a pool of securities. We do have limited authority to direct the
Custodian to deduct our investment advisory fees from your accounts, but only with the
appropriate authorization from you.
Where appropriate, we may also provide advice about any type of legacy position or
other investment held in client portfolios. Clients may engage us to manage and/or
advise on certain investment products that are not maintained at their primary
custodian, such as variable life insurance and annuity contracts and assets held in
employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans).
Disclosure Regarding Rollover Recommendations
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 also fiduciaries within the meaning of Title I of the Employee Retirement
Income Security Act and/or the Internal Revenue Code, 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.
A client or prospect leaving an employer typically has four options regarding an existing
retirement plan (and may engage in a combination of these options): (i) leave the money
in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s
plan, if one is available and rollovers are permitted, (iii) rollover to an Individual
Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending
upon the client’s age, result in adverse tax consequences). Our Firm may recommend an
investor roll over plan assets to an IRA for which our Firm provides investment advisory
services. As a result, our Firm and its representatives may earn an asset-based fee. In
contrast, a recommendation that a client or prospective client leave their plan assets with
their previous employer or roll over the assets to a plan sponsored by a new employer
will generally result in no compensation to our Firm. Our Firm therefore has an economic
incentive to encourage a client to roll plan assets into an IRA that our Firm will manage,
which presents a conflict of interest. To mitigate the conflict of interest, there are various
factors that our Firm will consider before recommending a rollover, including but not
limited to: (i) the investment options available in the plan versus the investment options
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available in an IRA, (ii) fees and expenses in the plan versus the fees and expenses in an
IRA, (iii) the services and responsiveness of the plan’s investment professionals versus
those of our Firm, (iv) protection of assets from creditors and legal judgments, (v)
required minimum distributions and age considerations, and (vi) employer stock tax
consequences, if any. Our Firm’s Chief Compliance Officer remains available to address
any questions that a client or prospective client has regarding the oversight.
Financial Planning
Through the Financial Planning process, our team strives to engage our clients in
conversations around the family’s goals, objectives, priorities, vision, and legacy – both
for the near and long term. With the unique goals and circumstances of each family in
mind, our team will offer financial planning ideas and strategies to address the client’s
holistic financial picture, including estate, income tax, charitable, cash flow, wealth
transfer and family legacy objectives. Our team partners with our client’s other advisors
(CPA, Estate Attorney, Insurance broker, etc.) to ensure a coordinated effort of all
parties toward the client’s stated goals. Such services include various reports on specific
goals and objectives or general investment and/or planning recommendations,
guidance to outside assets and periodic updates.
Our specific services in preparing your plan include:
• Review and clarification of your financial goals.
• Assessment of your overall financial position including cash flow, balance sheet,
investment strategy, risk management and estate planning.
• Creation of a unique plan for each goal you have including real estate, education,
retirement or financial independence, charitable giving, estate planning, and
other personal goals.
• Development of a goal-oriented investment plan, with input from various
advisors to our clients around tax suggestions, asset allocation, expenses, risk
and liquidity factors for each goal. This includes IRA and qualified plans, taxable
and trust accounts that require special attention.
• Design of a risk management plan including risk tolerance, risk avoidance,
mitigation and transfer, including liquidity as well as various insurance and
possible company benefits.
• Crafting and implementation of, in conjunction with your estate and/or
corporate attorneys as tax advisor, an estate plan to provide for you and/or your
heirs in the event of an incapacity or death.
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You are advised and are expected to understand that our past performance is not a
guarantee of future results. Certain market and economic risks exist that may adversely
affect an account’s performance. This could result in capital losses in your account.
Consulting Services
We also provide clients investment advice on a more-limited basis on one-or-more
isolated areas of concern such as estate planning, real estate, retirement planning, or any
other specific topic. Additionally, we may provide advice on non-securities matters in
connection with the rendering of estate planning, insurance, real estate, and/or annuity
advice. In these cases, you may be required to select your own investment managers,
broker-dealer and/or insurance companies for the implementation of consulting
recommendations. If your needs include brokerage and/or other financial services, we
may recommend the use of one of several investment managers, brokers, banks,
custodians, insurance companies or other financial professionals ("Firms"). You must
independently evaluate these Firms before opening an account or transacting business
and have the right to effect business through any firm you choose. You have the right to
choose whether to follow the consulting advice that we provide.
Wrap Fee Programs
We do not place Client assets into a wrap fee program.
Assets
As of December 31, 2025, we have $152,764,456 in assets under our management. We
manage $145,232,925 in discretionary assets and $7,531,531 in non-discretionary assets.
ITEM 5 - FEES AND COMPENSATION
Investment Management Fees and Compensation
WWM charges a fee as compensation for providing Investment Management services on
your account. These services include advisory and comprehensive planning services, trade
entry, investment supervision, and other account-maintenance activities. Our custodian
may charge transaction costs, custodial fees, redemption fees, retirement plan and
administrative fees or commissions. See Additional Fees and Expenses below for
additional details.
The fees for portfolio management are based on an annual percentage of assets under
management. The fees are applied to the account asset value on a pro-rata basis and
billed quarterly in arrears. The initial fee will be based upon the value of the assets on
the date the account is accepted for management by execution of the advisory agreement
by WWM or when the assets are transferred through the last day of the current quarter.
Thereafter, the quarterly fee will be calculated on last day of the calendar quarter. The
market value will be determined as reported by the Custodian. Fees are assessed on all
assets under management, including securities, cash and money market balances.
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Our annual advisory fee is a percentage of assets under management based on the fee
schedule below:
0.90% on assets of less than $300,000;
0.80% on assets up to $600,000;
0.70% on assets up to $1,000,000;
0.60% on assets $1,000,001 to $2,000,000; and
0.50% on assets above $2,000,000.
The minimum annual fee is $1,000 and is negotiable. Current client relationships may
exist where the fees are lower than the fee schedule above.
The specific advisory fees are set forth in your Client Engagement Agreement. Fees may
vary based on the size of the account, complexity of the portfolio, extent of activity in the
account or other reasons agreed upon by us and you as the client. In some cases,
additional deposits and withdrawals will be added or subtracted from portfolio assets, as
the case may be, which may lead to an adjustment of the account fee. In certain
circumstances, our fees and the timing of the fee payments may be negotiated. Our
employees and their family related accounts are charged a reduced fee for our services.
At our discretion, we will aggregate asset amounts in accounts from your same household
together to determine the advisory fee for all your accounts. We may do this, for
example, where we also service accounts on behalf of your minor children, individual and
joint accounts for a spouse, and/or other types of related accounts. This consolidation
practice is designed to allow you the benefit of an increased asset total, which could
potentially cause your account(s) to be assessed a lower advisory fee.
The independent qualified custodian holding your funds and securities will debit your
account directly for the advisory fee and pay that fee to us. You will provide written
authorization permitting the fees to be paid directly from your account held by the
qualified custodian. Further, the qualified custodian agrees to deliver an account
statement at least quarterly directly to you indicating all the amounts deducted from the
account including our advisory fees. At our discretion, you may pay the advisory fees by
check. You are encouraged to review your account statements for accuracy.
Either WWM or you may terminate the management agreement immediately upon
written notice to the other party. The management fee will be pro-rated to the date of
termination, for the month in which the cancellation notice was given and billed to your
account. Upon termination, you are responsible for monitoring the securities in your
account, and we will have no further obligation to act or advise with respect to those
assets. In the event of client’s death or disability, WWM will continue management of the
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account until we are notified of client’s death or disability and given alternative
instructions by an authorized party.
Fees for financial planning services are included in the investment management fees
described above.
We will not require prepayment of more than $1200 in fees per client, six (6) or more
months in advance of providing any services.
Consulting
WWM provides consulting services for clients who need advice on a limited scope of
work. WWM will negotiate consulting fees with you. Fees may vary based on the extent
and complexity of the consulting project. Fees are negotiated and you will be billed as
services are rendered. Our maximum hourly fee is $300/hour.
Either party may terminate the agreement. Upon termination, fees will be prorated to
the date of termination and any unearned portion of the fee will be refunded to you as
described above.
Additional Fees and Expenses:
In addition to the advisory fees paid to WWM, clients may also incur certain charges
imposed by other third parties, such as broker-dealers, custodians, trust companies,
banks and other financial institutions (collectively “Financial Institutions”). These
additional charges may include securities brokerage commissions, transaction fees,
custodial fees, fees charged by the Independent Managers, margin costs, charges
imposed directly by a mutual fund or ETF in a client’s account, as disclosed in the fund’s
prospectus (e.g., fund management fees and other fund expenses), deferred sales
charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and
other fees and taxes on brokerage accounts and securities transactions. WWM’s
brokerage practices are described at length in Item 12, below.
ITEM 6 - PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT
We do not charge advisory fees on a share of the capital appreciation of the funds or
securities in a client account (so-called performance-based fees).
ITEM 7 - TYPES OF CLIENTS
We provide investment advice to individuals, high-net-worth individuals, institutions,
trusts and estates. We have no minimum initial account value.
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ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
Security analysis methods may include fundamental analysis, technical analysis, and
cyclical analysis. The main sources of information that WWM uses include Morningstar
Principia mutual fund information, Morningstar Principia stock information, Charles
Schwab & Co. equity reports, and third party information from financial journals and
websites.
Other sources of information include financial newspapers and magazines, research
materials prepared by others, and modern portfolio theory statistics. Employees of
WWM also attend on- and off-site visits with fund and portfolio managers, conferences
calls and industry conferences.
The primary investment strategy used on client accounts is asset allocation utilizing equity
and fixed income mutual funds. Portfolios are diversified to control the risk associated
with traditional markets.
The investment strategy for a specific client is based upon the objectives stated by the
client during consultations. The client may change these objectives at any time.
Other strategies may include long-term purchases, short term purchases, trading, margin
transactions, and option writing (covered options).
Risk of Loss
Clients must understand that past performance is not indicative of future results.
Therefore, current and prospective clients should never assume that future performance
of any specific investment or investment strategy will be profitable. Investing in securities
involves risk of loss. Further, depending on the different types of investments there may
be varying degrees of risk. Clients and prospective clients should be prepared to bear
investment loss including loss of original principal.
Because of the inherent risk of loss associated with investing, WWM is unable to
represent, guarantee, or even imply that our services and methods of analysis can or will
predict future results, successfully identify market tops or bottoms, or insulate you from
losses due to market corrections or declines.
Investors should be aware that accounts are subject to the following risks:
Market Risk — Even a long-term investment approach cannot guarantee a profit.
Economic, political and issuer-specific events will cause the value of securities to
rise or fall. Because the value of investment portfolios will fluctuate, there is the
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risk that you will lose money and your investment may be worth more or less upon
liquidation.
Foreign Securities and Currency Risk — Investments in international and emerging-
market securities include exposure to risks such as currency fluctuations, foreign
taxes and regulations, and the potential for illiquid markets and political
instability.
Capitalization Risk — Small-cap and mid-cap companies may be hindered as a
result of limited resources or less diverse products or services, and their stocks
have historically been more volatile than the stocks of larger, more established
companies.
Interest Rate Risk — In a rising rate environment, the value of fixed-income
securities generally declines and the value of equity securities may be adversely
affected.
Credit Risk — Credit risk is the risk that the issuer of a security may be unable to
make interest payments and/or repay principal when due. A downgrade to an
issuer’s credit rating or a perceived change in an issuer’s financial strength may
affect a security’s value and, thus, impact the fund’s performance.
Securities Lending Risk — Securities lending involves the risk that the fund loses
money because the borrower fails to return the securities in a timely manner or
at all. The fund could also lose money if the value of the collateral provided for
loaned securities, or the value of the investments made with the cash collateral,
falls. These events could also trigger adverse tax consequences for the fund.
Derivative Risk — Derivatives are securities, such as futures contracts, whose
value is derived from that of other securities or indices. Derivatives can be used
for hedging (attempting to reduce risk by offsetting one investment position with
another) or non-hedging purposes. Hedging with derivatives may increase
expenses, and there is no guarantee that a hedging strategy will achieve the
desired results.
Exchange-Traded Funds — ETFs face market-trading risks, including the potential
lack of an active market for shares, losses from trading in the secondary markets
and disruption in the creation/redemption process of the ETF. Any of these factors
may lead to the fund’s shares trading at either a premium or a discount to its “net
asset value.”
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Performance of Underlying Managers — We select the mutual funds and ETFs in
the asset allocation models. However, we depend on the manager of such funds
to select individual investments in accordance with their stated investment
strategy.
Cybersecurity Risk - In addition to the Material Risks listed above, investing
involves various operational and “cybersecurity” risks. These risks include both
intentional and unintentional events at our Firm or one of its third-party
counterparties or service providers, that may result in a loss or corruption of data,
result in the unauthorized release or other misuse of confidential information, and
generally compromise our Firm’s ability to conduct its business. A cybersecurity
breach may also result in a third-party obtaining unauthorized access to our
clients’ information, including social security numbers, home addresses, account
numbers, account balances, and account holdings. Our Firm has established
business continuity plans and risk management systems designed to reduce the
risks associated with cybersecurity breaches. However, there are inherent
limitations in these plans and systems, including that certain risks may not have
been identified, in large part because different or unknown threats may emerge
in the future. As such, there is no guarantee that such efforts will succeed,
especially because our Firm does not directly control the cybersecurity systems of
our third-party service providers. There is also a risk that cybersecurity breaches
may not be detected.
Some Alternative
Alternative Investments: Our Firm’s use of alternative assets is limited to publicly
traded ETFs or ‘40 Act’ mutual funds with specific exposure in commodities,
long/short strategies, real estate and covered call writing. Investments classified
as "alternative investments" may include a broad range of underlying assets
including, but not limited to, hedge funds, private equity, venture capital, and
registered, publicly traded securities.
investments are
speculative, not suitable for all clients and intended for only experienced and
sophisticated investors who are willing to bear the high risk of the investment,
which can include: loss of all or a substantial portion of the investment due to
leveraging, short-selling, or other speculative investment practices; lack of
liquidity in that there may be no secondary market for the fund and none expected
to develop; volatility of returns; potential for restrictions on transferring interest
in the fund; potential lack of diversification and resulting higher risk due to
concentration of trading authority with a single advisor; absence of information
regarding valuations and pricing; potential for delays in tax reporting; less
regulation and typically higher fees than other investment options such as mutual
funds. Investing in a fund that concentrates its investments in a few holdings may
involve heightened risk and result in greater price volatility.
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ITEM 9 - DISCIPLINARY INFORMATION
WWM does not have any legal, financial or other “disciplinary” item to report.
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Clients should be aware that the ability to receive additional compensation by our Firm
and its management persons or employees creates conflicts of interest that impair the
objectivity of the Firm and these individuals when making advisory recommendations.
Our Firm endeavors at all times to put the interest of its clients first as part of our fiduciary
duty as a registered investment adviser; we take the following steps, among others to
address this conflict:
•
•
•
•
•
•
•
we disclose to clients the existence of all material conflicts of interest,
including the potential for the Firm and our employees to earn compensation
from advisory clients in addition to the Firm's advisory fees;
we disclose to clients that they have the right to decide to purchase
recommended investment products from our employees;
we collect, maintain and document accurate, complete and relevant client
background information, including the client’s financial goals, objectives, and
liquidity needs;
the Firm conducts regular reviews of each client advisory account to verify
that all recommendations made to a client are in the best interest of the
client’s needs and circumstances;
we require that our employees seek prior approval of any outside
employment activity so that we may ensure that any conflicts of interests in
such activities are properly addressed;
we periodically monitor these outside employment activities to verify that
any conflicts of interest continue to be properly addressed by the Firm; and
we educate our employees regarding the responsibilities of a fiduciary,
including the need for having a reasonable and independent basis for the
investment advice provided to clients.
We have no other financial industry activities nor affiliations to report at this time.
ITEM 11 - CODE OF ETHICS PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS
AND PERSONAL TRADING
WWM and persons associated with us are allowed to invest for their own accounts or to
have a financial interest in the same securities or other investments that we recommend
or acquire for your account, and may engage in transactions that are the same as or
different than transactions recommended to or made for your account. This creates the
potential for a conflict of interest. We recognize the fiduciary responsibility to place your
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interests first and have established policies in this regard to avoid any potential conflicts
of interest.
We have developed and implemented a Code of Ethics that sets forth standards of
conduct expected of our advisory personnel to mitigate this conflict of interest. The Code
of Ethics addresses, among other things, personal trading, gifts, the prohibition against
the use of inside information and other situations where there is a possibility for conflicts
of interest.
The Code of Ethics is designed to protect our clients by deterring misconduct, educate
personnel regarding the firm’s expectations and laws governing their conduct, remind
personnel that they are in a position of trust and must act with complete propriety at all
times, protect the reputation of WWM, guard against violation of the securities laws, and
establish procedures for personnel to follow so that we may determine whether their
personnel are complying with the firm’s ethical principles.
We have established the following restrictions in order to ensure our firm’s fiduciary
responsibilities:
1. No director, officer or employee of WWM shall prefer his or her own interest to
that of the advisory client.
2. We maintain a list of all securities holdings and anyone associated with this
advisory practice with access to advisory recommendations. These holdings are
reviewed on a regular basis by an appropriate officer/individual of WWM.
3. We emphasize the unrestricted right of the client to decline to implement any
advice rendered, except in situations where we are granted discretionary
authority of the client’s account.
4. We emphasize the unrestricted right of the client to select and choose any broker-
dealer (except in situations where we are granted discretionary authority) he or
she wishes.
5. We require that all individuals must act in accordance with all applicable Federal
and State regulations governing registered investment advisory practices.
6. Any individual not in observance of the above may be subject to termination.
You may request a complete copy of our Code by contacting us at the address, telephone
or email on the cover page of this Part 2; Attn: Chief Compliance Officer.
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ITEM 12 - BROKERAGE PRACTICES
The Custodian and Brokers We Use
Investment Management Services
Clients must maintain assets in an account at a “qualified custodian,” generally a broker-
dealer or bank. We recommend that our clients use Charles Schwab & Co., Inc. Advisor
Services (“Schwab”), a registered broker-dealer, member SIPC, as the qualified custodian.
We are independently owned and operated, and unaffiliated with Schwab. Schwab will
hold client assets in a brokerage account, and buy and sell securities when we instruct
them to.
While we recommend that clients use Schwab as custodian/broker, client must decide
whether to do so and open accounts with Schwab by entering into account agreements
directly with them. We will open accounts with Schwab on the client’s behalf and will
notify the client in writing of the custodian’s name, address, and the title of the account,
promptly when the account is opened and following any changes to this information. The
accounts will always be held in the name of the client and never in WWM’s name. Even
though clients maintain accounts at Schwab, we can still use other brokers to execute
trades for client accounts (see Client Brokerage and Custody Costs, below).
How We Select Brokers/Custodians
We seek 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. We consider a wide range of factors, including,
among others:
1. Combination of transaction execution services and asset custody services
(generally without a separate fee for custody)
2. Capability to execute, clear, and settle trades (buy and sell securities for client
accounts)
3. Capability to facilitate transfers and payments to and from accounts (wire
transfers, check requests, bill payment, etc.)
4. Breadth of available investment products (stocks, bonds, mutual funds, exchange-
traded funds [ETFs], etc.)
5. Availability of investment research and tools that assist us in making investment
decisions
6. Quality of services
7. Competitiveness of the price of those services (commission rates, other fees, etc.)
and willingness to negotiate the prices
8. Reputation, financial strength, and stability
9. Prior service to WWM and our other clients
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10. Availability of other products and services that benefit us, as discussed below (see
Products and Services Available to Us from Schwab)
Client Brokerage and Custody Costs
For our clients’ accounts that Schwab maintains, Schwab generally does not charge
separately for custody services. However, Schwab receives compensation by charging
ticket charges or other fees on trades that it executes or that settle into clients’ Schwab
accounts. In addition to commissions, Schwab charges a flat dollar amount as a “prime
broker” or “trade away” fee for each trade that we have executed by a different broker-
dealer but where the securities bought or the funds from the securities sold are deposited
(settled) into a client’s Schwab account. These fees are in addition to the ticket charges
or other compensation the client pays the executing broker-dealer. Because of this, in
order to minimize trading costs, we have Schwab execute most trades for client accounts.
We have determined that having Schwab execute most trades is consistent with our duty
to seek “best execution” of client trades. Best execution means the most favorable terms
for a transaction based on all relevant factors, including those listed above (see How We
Select Brokers/Custodians).
Products and Services Available to Us from Schwab
Schwab Advisor Services™ (formerly called Schwab Institutional®) is Schwab’s business
serving independent investment advisory firms like us. They provide WWM and our
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 us manage or
administer our clients’ accounts; others help us manage and grow our business. Schwab’s
support services generally are available on an unsolicited basis (we do not have to request
them) and at no charge to us.
Following is a more detailed description of Schwab’s support services:
Services That Benefit Our Clients
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 we might not
otherwise have access or that would require a significantly higher minimum initial
investment by our clients. Schwab’s services described in this paragraph generally benefit
our clients and their accounts.
Services That May Not Directly Benefit Our Clients
Schwab also makes available to us other products and services that benefit us but may
not directly benefit our clients or their accounts. These products and services assist us in
managing and administering our clients’ accounts. They include investment research,
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both Schwab’s own and that of third parties. We may use this research to service all or a
substantial number of our clients’ accounts, including accounts not maintained at
Schwab. In addition to investment research, Schwab also makes available software and
other technology that:
1. Provide access to client account data (such as duplicate trade confirmations and
account statements)
2. Facilitate trade execution and allocate aggregated trade orders for multiple
client accounts
3. Provide pricing and other market data
4. Facilitate payment of our fees from our clients’ accounts
5. Assist with back-office functions, recordkeeping, and client reporting
Services That Generally Benefit Only Us
Schwab also offers other services intended to help us manage and further develop our
business enterprise.
These services include:
1. Educational conferences and events
2. Consulting on technology, compliance, legal, and business needs
3. Publications and conferences on practice management and business succession
4. Access to employee benefits providers, human capital consultants, and
insurance providers
Schwab may provide some of these services itself. In other cases, it will arrange for third-
party vendors to provide the services to us. Schwab may also discount or waive its fees
for some of these services or pay all or a part of a third party’s fees. Schwab may also
provide us with other benefits, such as occasional business entertainment of our
personnel.
Our Interest in Schwab’s Services
The availability of these services from Schwab benefits us because we do not have to
produce or purchase them. These services are not contingent upon us committing any
specific amount of business to Schwab in trading commissions. We believe that our
selection of Schwab as custodian and broker is in the best interests of our clients.
Some of the products, services and other benefits provided by Schwab benefit WWM and
may not benefit our client accounts. Our recommendation or requirement that you place
assets in Schwab's custody may be based in part on benefits Schwab provides to us, or
our agreement to maintain certain Assets Under Management at Schwab, and not solely
on the nature, cost or quality of custody and execution services provided by Schwab.
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We place trades for our clients' accounts subject to its duty to seek best execution and its
other fiduciary duties. We may use broker-dealers other than Schwab to execute trades
for your accounts maintained at Schwab, but this practice may result in additional costs
to clients so that we are more likely to place trades through Schwab rather than other
broker-dealers. Schwab's execution quality may be different than other broker-dealers.
Brokerage for Client Referrals
WWM does not receive client referrals from any broker-dealer or third party in exchange
for using that broker-dealer or third party.
Aggregation and Allocation of Transactions
WWM may aggregate transactions if we believe that aggregation is consistent with the
duty to seek best execution for our clients and is consistent with the disclosures made to
clients and terms defined in the client investment advisory agreement. No advisory client
will be favored over any other client, and each account that participates in an aggregated
order will participate at the average share price (per custodian) for all transactions in that
security on a given business day.
If we do not receive a complete fill for an aggregated order, we will allocate the order on
a pro-rata basis. If we determine that a pro-rata allocation is not appropriate under the
particular circumstances, we will base the allocation on other relevant factors, which may
include:
1. When only a small percentage of the order is executed, with respect to purchase
allocations, allocations may be given to accounts high in cash;
2. With respect to sale allocations, allocations may be given to accounts low in cash;
3. We may allocate shares to the account with the smallest order, or to the smallest
position, or to an account that is out of line with respect to security or sector
weightings, relative to other portfolios with similar mandates;
4. We may allocate to one account when that account has limitations in its
investment guidelines prohibiting it from purchasing other securities that we
expect to produce similar investment results and that can be purchased by other
accounts in the block;
5. If an account reaches an investment guideline limit and cannot participate in an
allocation, we may reallocate shares to other accounts. For example, this may be
due to unforeseen changes in an account’s assets after an order is placed;
6. If a pro-rata allocation of a potential execution would result in a de minimis
allocation in one or more accounts, we may exclude the account(s) from the
allocation and disgorge any profits. Generally, de minimis allocations do not
exceed 5% of the total allocation. Additionally, we may execute the transactions
on a pro-rata basis.
7. We will document the reasons for any deviation from a pro-rata allocation.
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Trade Errors
We have implemented procedures designed to prevent trade errors; however, trade
errors in client accounts cannot always be avoided. Consistent with our fiduciary duty, it
is our policy to correct trade errors in a manner that is in the best interest of the client.
In cases where the client causes the trade error, the client will be responsible for any loss
resulting from the correction. Depending on the specific circumstances of the trade error,
the client may not be able to receive any gains generated as a result of the error
correction. In all situations where the client does not cause the trade error, the client will
be made whole, and we will absorb any loss resulting from the trade error if the error was
caused by the firm. If the error is caused by the broker-dealer, the broker-dealer will be
responsible for covering all trade error costs. We will never benefit or profit from trade
errors.
We do not routinely recommend, request or require that you direct us to execute
transaction through a specified broker dealer. Additionally, we typically do not permit
you to direct brokerage. We place trades for your account subject to our duty to seek
best execution and other fiduciary duties. As a matter of policy and practice, we do not
utilize research, research-related products and other services obtained from broker-
dealers, or third parties, on a soft dollar commission basis.
ITEM 13 - REVIEW OF ACCOUNTS
Account Reviews and Reviewers – Investment Supervisory Services
The underlying securities within the investment supervisory services are regularly
monitored. These reviews will be made by Glenn Wager on at least a quarterly basis. An
annual review is usually conducted in person or by telephone.
The purpose of all these reviews is to ensure that the investment plan continues to be
implemented in a manner which matches your objectives and risk tolerances. More-
frequent reviews may be triggered by material changes in variables such as your individual
circumstances, or the market, political or economic environment. You are urged to notify
us of any changes in your personal circumstances.
Statements and Reports
WWM will have the ability to provide clients with Performance/Position summary reports
upon request. Reports may also be provided at every client meeting. Communication to
clients will be done on an as needed basis with a minimum of 1 contact per calendar
quarter.
The custodian for the individual client’s account will also provide clients with an account
statement at least quarterly. You are urged to compare the reports provided by WWM
against the account statements you receive directly from your account custodian.
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ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION
The Firm receives an economic benefit from Schwab in the form of the support products
and services it makes available to us and other independent investment advisors whose
clients maintain their accounts at Schwab. Clients do not pay more for assets maintained
at Schwab as a result of these arrangements. However, the Firm benefits from the referral
arrangement because the cost of these services would otherwise be borne directly by us.
Client should consider these conflicts of interest when selecting a custodian. The products
and services provided by Schwab, how they benefit us, and the related conflicts of interest
are described above (see Item 12—Brokerage Practices).
From time to time, we may receive expense reimbursement for travel and/or marketing
expenses from distributors of investment and/or insurance products. Travel expense
reimbursements are typically a result of attendance at due diligence and/or investment
training events hosted by product sponsors. Although receipt of these travel are not
predicated upon specific sales quotas, the product sponsor reimbursements are typically
made by those sponsors for whom sales have been made or it is anticipated sales will be
made.
Our Firm may be asked to recommend a financial professional, such as an attorney,
accountant, or mortgage broker. In such cases, our Firm does not receive any direct
compensation in return for any referrals made to individuals or firms in our professional
network. Clients must independently evaluate these firms or individuals before engaging
in business with them and clients have the right to choose any financial professional to
conduct business. Individuals and firms in our financial professional network may refer
clients to our Firm. Again, our Firm does not pay any direct compensation in return for
any referrals made to our Firm. Our Firm does recognize the fiduciary responsibility to
place your interests first and have established policies in this regard to mitigate any
conflicts of interest.
ITEM 15 - CUSTODY
Custody, as it applies to investment advisors, has been defined by regulators as having
access or control over client funds and/or securities. In other words, custody is not limited
to physically holding client funds and securities. If an investment advisor has the ability
to access or control client funds or securities, the investment advisor is deemed to have
custody and must ensure proper procedures are implemented.
Standing Letters of Authorization (“SLOA”)
WWM is deemed to have custody of clients’ funds or securities when clients have
standing authorizations with their custodian to move money from a client’s account to a
third-party (“SLOA”) and authorize us to designate the amount or timing of transfers with
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the custodian. The SEC has set forth a set of standards intended to protect client assets
in such situations, which we follow. We do not have a beneficial interest on any of the
accounts we are deemed to have Custody where SLOAs are on file. In addition, account
statements reflecting all activity on the account(s), are delivered directly from the
qualified custodian to each client or the client’s independent representative, at least
quarterly. You should carefully review those statements and are urged to compare the
statements against reports received from us. When you have questions about your
account statements, you should contact us, your Advisor or the qualified custodian
preparing the statement.
Deduction of Advisory Fees
WWM is deemed to have custody of client funds and securities whenever WWM is given
the authority to have fees deducted directly from client accounts. For accounts in which
WWM is deemed to have custody, the firm has established procedures to ensure all client
funds and securities are held at a qualified custodian in a separate account for each client
under that client’s name. Clients or an independent representative of the client will
direct, in writing, the establishment of all accounts and therefore are aware of the
qualified custodian’s name, address and the manner in which the funds or securities are
maintained. Finally, account statements are delivered directly from the qualified
custodian to each client, or the client’s independent representative, at least quarterly.
You should carefully review those statements and are urged to compare the statements
against reports received from WWM. When you have questions about your account
statements, you should contact WWM or the qualified custodian preparing the
statement.
When fees are deducted from an account, WWM is responsible for calculating the fee and
delivering instructions to the custodian. At the same time WWM instructs the custodian
to deduct fees from the client’s account; WWM will send you a notification itemizing the
fee. Itemization shall include the formula used to calculate the fee, the amount of assets
under management the fee is based on, and the time period covered by the fee.
ITEM 16 - INVESTMENT DISCRETION
Prior to engaging WWM to provide investment advisory services, you will enter into a
written Agreement with us granting the firm the authority to supervise and direct, on an
on-going basis, investments in accordance with the client’s investment objective and
guidelines. In addition, you will need to execute additional documents required by the
Custodian so as to authorize and enable WWM, in its sole discretion, without prior
consultation with or ratification by you, to purchase, sell or exchange securities in and for
your accounts. We are authorized, in our discretion and without prior consultation with
you to: (1) buy, sell, exchange and trade any stock, bonds or other equities or securities
and (2) determine the amount of securities to be bought or sold and (3) place orders with
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the custodian. Any limitations to such authority will be communicated by you to us in
writing.
The limitations on investment and brokerage discretion held by WWM for you are:
1. For discretionary clients, we require that we be provided with authority to
determine which securities and the amounts of securities to be bought or sold.
2. Any limitations on this discretionary authority shall be included in this written
authority statement. You may change/amend these limitations as required. Such
amendments shall be submitted in writing.
In some instances, we may not have discretion. On non-discretionary accounts, we will
discuss all transactions with you prior to execution or you will be required to make the
trades if in an employer sponsored account.
ITEM 17 - VOTING CLIENT SECURITIES
We will not vote proxies under our limited discretionary authority. You are welcome to
vote proxies or designate an independent third-party at your own discretion. You
designate proxy voting authority in the custodial account documents. You must ensure
that proxy materials are sent directly to you or your assigned third party. We do not take
action with respect to any securities or other investments that become the subject of any
legal proceedings, including bankruptcies. Clients are able to contact our office with
questions about a particular solicitation by phone at 720-745-5010.
Class Action Suits - A class action is a procedural device used in litigation to determine the
rights of and remedies, if any, for large numbers of people whose cases involve common
questions of law and/or fact. Class action suits frequently arise against companies that
publicly issue securities, including securities recommended by investment advisors to
clients. With respect to class action suits and claims, you (or your agent) will have the
responsibility for class actions or bankruptcies, involving securities purchased for or held
in your account. We do not provide such services and are not obligated to forward copies
of class action notices we may receive to you or your agents.
ITEM 18 - FINANCIAL INFORMATION
This item is not applicable to this brochure. We do not require or solicit prepayment of
more than $1,200 in fees per client, six months or more in advance. Therefore, we are
not required to include a balance sheet for our most recent fiscal year. We are not subject
to a financial condition that is reasonably likely to impair our ability to meet contractual
commitments to clients. Finally, we have not been the subject of a bankruptcy petition
at any time.
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PRIVACY POLICY
Our Firm collects nonpublic personal information about Clients from information
provided on applications or other forms, as well as from information regarding Client
transactions with our Firm, our affiliates, or others. In accordance with Regulation S-P,
our Firm does not disclose any nonpublic personal information about current or former
Clients to third parties, except as permitted or required by law, or as necessary to service
Client accounts. Access to Client information is restricted to Firm personnel who require
such information to provide investment advisory services. Our Firm maintains physical,
electronic, and procedural safeguards designed to protect Client information in
compliance with federal standards and Regulation S-P. Our Firm provides a copy of its
Privacy Policy to Clients at the time of account opening, upon request, and annually if the
Policy is amended.
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