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Wealth Compass Financial, Inc.
CRD number: 290139
Form ADV Part 2A
Disclosure Brochure
Version Date: 4/27/2026
This brochure provides information about the qualifications and business practices of Wealth Compass Financial,
Inc. If you have any questions about the contents of this brochure, please contact us at (760) 509-4000 or by email
at: info@wealthcompass.com. The information in this brochure has not been approved or verified by the United
States Securities and Exchange Commission or by any state securities authority. Registration does not imply a
certain level of skill or training.
Additional information about Wealth Compass Financial, Inc. is also available on the SEC’s website at
www.adviserinfo.sec.gov.
5860 Owens Ave. #100
Carlsbad, CA 92008
(760) 509-4000
info@wealthcompass.com
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Item 2: Material Changes
Wealth Compass Financial, Inc. (“WCF” or “Firm”) is an RIA registered with the U.S. Securities
and Exchange Commission, located in Carlsbad, California. The Material Changes section of this
Brochure is intended to point out any material changes that have been made to our business and
to this Disclosure Brochure since our prior Brochure, and to provide you with a summary of those
changes. This Brochure will be updated at least annually, or when material changes occur since
the previous release of the Brochure.
Material Changes since the last Brochure Update
This Brochure is dated 4/27/2026. WCF is required to advise you of any material changes made
to their business since their prior Brochure dated 3/19/2026.
Since our prior Brochure we have moved our main business office. We formerly operated from
5860 Owens Ave. Suite 150, and have moved our firm to Suite 100 of the same building on
4/27/2026.
Full Brochure Available
In lieu of sending a notice of material changes, WCF chooses to send the entire Form ADV Part 2
Disclosure Brochure to its clients. This Firm Brochure being delivered is the updated and
complete brochure for the Firm. Copies are available at no cost and are also available here:
https://adviserinfo.sec.gov/firm/summary/290139.
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Item 3: Table of Contents
Item 1: Cover Page
Item 2: Material Changes .................................................................................................................................. 1
Material Changes since the last Brochure Update .................................................................................... 1
Full Brochure Available ................................................................................................................................ 1
Item 3: Table of Contents .................................................................................................................................. 2
Item 4: Advisory Business ................................................................................................................................ 4
A. Description of the Advisory Firm........................................................................................................... 4
B. Types of Advisory Services ...................................................................................................................... 4
C. Client Tailored Services and Client Imposed Restrictions .................................................................. 5
D. Wrap Fee Programs .................................................................................................................................. 5
E. Assets Under Management ...................................................................................................................... 6
Item 5: Fees and Compensation ....................................................................................................................... 7
A. Fee Schedule .............................................................................................................................................. 7
B. Payment of Fees ......................................................................................................................................... 7
C. Client Responsibility for Third Party Fees ............................................................................................ 7
D. Prepayment of Fees .................................................................................................................................. 8
E. Outside Compensation for the Sale of Securities to Clients ................................................................ 8
Item 6: Performance-Based Fees and Side-By-Side Management ............................................................... 8
Item 7: Types of Clients ..................................................................................................................................... 8
Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss .......................................................... 9
A. Methods of Analysis and Investment Strategies ............................................................................ 9
B. Material Risks Involved ..................................................................................................................... 9
C.
Risks of Specific Securities Utilized .................................................................................................. 9
Item 9: Disciplinary Information ................................................................................................................... 11
A.
Criminal or Civil Actions ................................................................................................................. 11
B.
Administrative Proceedings ............................................................................................................ 11
Self-regulatory Organization (SRO) Proceedings ........................................................................ 11
C.
Item 10: Other Financial Industry Activities and Affiliations ................................................................... 11
A.
Registration as a Broker/Dealer or Broker/Dealer Representative .......................................... 11
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Registration as a Futures Commission Merchant, Commodity Pool Operator, or a
B.
Commodity Trading Advisor .................................................................................................................... 11
C.
Registration Relationships Material to this Advisory Business and Conflicts of Interests .... 11
D.
Selection of Other Advisers or Managers and How This Adviser is Compensated ............... 11
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .......... 12
A.
Code of Ethics .................................................................................................................................... 12
B.
Recommendations Involving Material Financial Interests ......................................................... 12
C.
Investing Personal Money in the Same Securities as Clients ...................................................... 12
D.
Trading Securities At/Around the Same Time as Clients’ Securities ....................................... 13
Item 12: Brokerage Practices ........................................................................................................................... 13
A.
Factors Used to Select Custodians and/or Broker/Dealers ....................................................... 13
1.
Research and Other Soft-Dollar Benefits ................................................................................... 13
2.
Brokerage for Client Referrals ..................................................................................................... 14
3.
Clients Directing Which Broker/Dealer/Custodian to Use ................................................... 14
B.
Aggregating (Block) Trading for Multiple Client Accounts ....................................................... 14
Item 13: Review of Accounts .......................................................................................................................... 14
A.
Frequency and Nature of Periodic Reviews and Who Makes Those Reviews ........................ 14
B.
Factors That Will Trigger a Non-Periodic Review of Client Accounts ..................................... 14
C.
Content and Frequency of Regular Reports Provided to Clients ............................................... 15
Item 14: Client Referrals and Other Compensation .................................................................................... 15
A.
Economic Benefits Provided by Third Parties for Advice Rendered to Clients
B.
Compensation to Non – Advisory Personnel for Client Referrals ............................................. 16
Item 15: Custody .............................................................................................................................................. 16
Item 16: Investment Discretion ...................................................................................................................... 17
Item 17: Voting Client Securities (Proxy Voting) ......................................................................................... 17
Item 18: Financial Information ....................................................................................................................... 17
Business Continuity Plan Client Notice .................................................................................................... 18
Client Privacy Policy Notice ....................................................................................................................... 19
Form ADV Part 2B – Individual Disclosure Brochure for Steven T. Nuckols.......................................... 22
Form ADV Part 2B – Individual Disclosure Brochure for Tod L. Lenhoff ............................................... 25
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Item 4: Advisory Business
A. Description of the Advisory Firm
Wealth Compass Financial, Inc. (“WCF”) is a corporation organized in the State of Georgia,
located in Carlsbad, CA. WCF is an investment adviser registered with the U.S. Securities and
Exchange Commission, and notice filed in the state of California. The firm was formed in
September 2017, and the principal owner is Steven Nuckols.
WCF’s main office is located at 5860 Owens Avenue, Ste: 100, Carlsbad, CA 92008. WCF may also
see clients and prospective clients at the offices of WCF’s affiliated Tax and Accounting firm
located at 940 Canterbury Place, Suite 100, Escondido, CA 92025, BY APPOINTMENT ONLY.
B. Types of Advisory Services
Portfolio Management Services
WCF offers ongoing portfolio management services based on the individual goals, objectives,
time horizon, and risk tolerance of each client. WCF creates an Investment Policy Statement
(“IPS”) for each client, which outlines the client’s current situation (income, tax levels, and risk
tolerance levels). Portfolio management services include, but are not limited to, the following:
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Investment strategy
Asset allocation
Asset selection
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Personal investment policy
Selection of other advisers
Regular portfolio monitoring
WCF evaluates the current investments of each client with respect to their risk tolerance levels
and investment time horizon. WCF will request discretionary authority from clients to select
securities and execute transactions without permission from the client prior to each transaction.
Risk tolerance levels are documented in the Investment Policy Statement (“IPS”) and given to
each client.
WCF seeks to provide that investment decisions are made in accordance with the fiduciary duties
owed to its accounts and without consideration of WCF’s economic, investment or other financial
interests. To meet its fiduciary obligations, WCF attempts to avoid, among other things,
investment or trading practices that systematically advantage or disadvantage certain client
portfolios, and accordingly, WCF’s policy is to seek fair and equitable allocation of investment
opportunities/transactions among its clients to avoid favoring one client over another over time.
It is WCF’s policy to allocate investment opportunities and transactions it identifies as being
appropriate and prudent among its clients on a fair and equitable basis over time.
When appropriate and when WCF believes it is in the clients’ best interest, WCF may recommend
other carefully chosen advisers (Third-Party Money Managers) to professionally allocate and
manage your account.
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Financial Planning
WCF believes that financial planning is a necessary step in portfolio management and provides
this service as a standard part of its portfolio management to its clients at no additional fee.
Financial planning may include, but is not limited to investment planning, life insurance and
long-term care, tax considerations and concerns, retirement planning, college planning (as
applicable), and debt /credit review and planning. In our standard client engagement, WCF will
furnish a written disclosure in its report or summary indicating:
a. whether the investment adviser, or an affiliate or associated person of the investment
adviser, will receive commissions from the sale of insurance or real estate or will receive
fees or other compensation from the sale of securities or other products or services
recommended in the financial planning process or otherwise have a conflict of interest.
b.
the client is under no obligation to act on the investment adviser's or associated person's
recommendation(s).
c.
if the client elects to act on any of the recommendations, the client is under no obligation to
affect the transaction through the investment adviser or the associated person when such
person is employed as an agent with a licensed broker-dealer or is licensed as a broker-
dealer or through any associate or affiliate of such person.
Services Limited to Specific Types of Investments
WCF generally limits its investment advice to mutual funds, fixed income securities, insurance
products including annuities (through individually licensed insurance agents), equities, ETFs,
and non-U.S. securities. WCF may use other securities as well to help diversify a portfolio when
appropriate.
C. Client Tailored Services and Client Imposed Restrictions
WCF offers the same suite of services to all its clients. However, specific client investment
strategies and their implementation are dependent upon the client Investment Policy Statement
(“IPS”) which outlines each client’s current suitability, investment objectives, and financial
situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions on
investing in certain securities or types of securities in accordance with their values or beliefs.
However, if the restrictions prevent WCF from properly servicing the client account, or if the
restrictions would require WCF to deviate from its standard suite of services, WCF reserves the
right to end the relationship.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees, transaction costs, fund expenses, and other administrative fees. WCF
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is not a wrap fee program sponsor or wrap program portfolio manager but may recommend
carefully selected wrap fee program models to clients when appropriate.
E. Assets Under Management
WCF has the following calculated regulatory assets under management (“RAUM”) as of our last
fiscal year end of December 31, 2025:
Discretionary Assets:
Total AUM:
Non-discretionary
Assets:
$ 115,254,613
$ 146,699
$ 115,401,312
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Item 5: Fees and Compensation
A. Fee Schedule
Portfolio Management Fees
Total Assets Under Management Annual Fees
$1 - $500,000
1.50%
$500,001 - $1,000,000
1.25%
$1,000,001 - $3,000,000
1.00%
$3,000,001 – And Up
0.75%
Advisory fees are expressed as an annual percentage rate. Advisory fees are calculated in a
straight tier schedule (shown above) using the average daily value of the assets in the account for
the monthly billing period and divided by twelve (12) to determine the monthly charge. Fees are
due monthly in arrears. Comparable services may be available at lower cost from other providers.
These fees are generally negotiable, and the final fee schedule is attached as “Exhibit I – Fee
Agreement” of the Investment Advisory Contract. Clients may terminate the Investment
Advisory Contract at any time with five (5) days’ written notice and will only be billed for those
days under our management. Because WCF bills fees in arrears, no additional fees will be
charged to you after termination of services.
Financial Planning
General Financial Planning is provided to WCF clients paying for portfolio management as a
complimentary process to establish client goals and needs at no additional cost. There is no need
to engage WCF for separate financial planning services to receive those services, as explained in
Item 4: Advisory Business. WCF does not charge clients additional fees for financial planning
services.
B. Payment of Fees
Payment of Portfolio Management Fees
Asset-based portfolio management fees are withdrawn directly from the client's accounts with
client's written authorization monthly in arrears. Billing occurs on the 8th of the month. Fees are
automatically withdrawn approximately one week later.
C. Client Responsibility for Third Party Fees
Clients are responsible for the payment of all third-party fees (i.e. custodian fees, brokerage fees,
mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and
expenses charged by WCF. Please see Item 12 of this brochure regarding broker-dealers and
custodians.
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D. Prepayment of Fees
WCF collects fees in arrears and therefore, there are no prepayment of advisory fees and refunds
do not apply to advisory account clients.
E. Outside Compensation for the Sale of Securities to Clients
WCF’s sole business is as a Registered Investment Adviser. WCF and its management people do
not have any other financial industry activities or affiliations.
However, WCF supervised persons also possess California insurance licenses and are therefore
licensed to offer and sell insurance products to California residents that they believe may benefit
from them in the overall financial planning process. In doing so, WCF’s supervised people can
receive a commission directly from the insurance company when a policy is sold. Even though
this would transpire outside of their investment advisory role with WCF, this presents a conflict
of interest since the insurance agent – investment professional would have an incentive to
recommend insurance products to individuals for a commission.
WCF addresses this conflict by this disclosure and advises clients that they always have the
option to purchase insurance through other insurance agents, even if it was recommended by a
WCF insurance agent – investment professional. WCF will not charge clients an investment
management fee for any commission-based investment that has resulted in a commission, such
as insurance products. If a WCF Supervised Person - investment professional receives a
commission for an insurance policy sale, clients will not also be billed through WCF for managing
the same policy.
Neither WCF nor its supervised persons accept any compensation for the sale of investment
products, including asset-based sales charges or service fees from the sale of mutual funds.
Item 6: Performance-Based Fees and Side-By-Side Management
WCF does not accept performance-based fees or other fees based on a share of capital gains or
capital appreciation of the assets of a client.
Item 7: Types of Clients
WCF generally offers advisory services to the following types of clients:
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Individuals
High-Net-Worth Individuals
Pension and Profit-Sharing Plans
There is no account minimum for any of WCF’s services.
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Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss
A. Methods of Analysis and Investment Strategies
Methods of Analysis
WCF’s methods of analysis include Modern portfolio theory.
Modern portfolio theory is a theory of investment that attempts to maximize the expected
portfolio return for a given amount of portfolio risk or equivalently minimize risk for a given
level of expected return, each by carefully choosing the proportions of various asset.
Investment Strategies
WCF generally uses long-term trading strategies. However, recommendations are based on the
individual client’s stated objectives, risk tolerance, and other important factors described in the
client’s Investment Policy Statement (“IPS”).
B. Material Risks Involved
Methods of Analysis
Modern portfolio theory assumes that investors are risk averse, meaning that given two
portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an
investor will take on increased risk only if compensated by higher expected returns. Conversely,
an investor who wants higher expected returns must accept more risk. The exact trade-off will be
the same for all investors, but different investors will evaluate the trade-off differently based on
individual risk aversion characteristics. The implication is that a rational investor will not invest
in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e.,
if for that level of risk an alternative portfolio exists which has better expected returns.
Investment Strategies
Long term trading is designed to capture market rates of both return and risk. Due to its nature,
the long-term investment strategy can expose clients to various types of risk that will typically
surface at various intervals during the time the client owns the investments. These risks include
but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market
risk, and political/regulatory risk.
Investing in securities involves a risk of loss that you, as a client, should be prepared to bear.
C. Risks of Specific Securities Utilized
Clients should be aware that there is a material risk of loss using any investment strategy. The
investment types listed below are not guaranteed or insured by the FDIC or any other
government agency.
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Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose
money investing in mutual funds. All mutual funds have costs that lower investment returns.
The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature.
Equity investment generally refers to buying shares of stocks in return for receiving future
payment of dividends and/or capital gains if the value of the stock increases. The value of equity
securities may fluctuate in response to specific situations for each company, industry conditions
and the general economic environments.
Fixed income investments generally pay a return on a fixed schedule, though the amount of the
payments can vary. This type of investment can include corporate and government debt
securities, leveraged loans, high yield, and investment grade debt and structured products, such
as mortgage and other asset-backed securities, although individual bonds may be the best-known
type of fixed income security. In general, the fixed income market is volatile and fixed income
securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa.
This effect is usually more pronounced for longer-term securities.) Fixed income securities also
carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and
counterparties. The risk of default on treasury inflation protected/inflation linked bonds is
dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a
potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed
income securities also include the general risk of non-U.S. investing described below.
Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar
to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case
of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and
increasing complexity, conflicts of interest and the possibility of inadequate regulatory
compliance.
Annuities are a retirement product for those who may have the ability to pay a premium now
and want to guarantee they receive certain monthly payments or a return on investment later in
the future. Annuities are contracts issued by a life insurance company designed to meet
requirements or other long-term goals. An annuity is not a life insurance policy. Variable
annuities are designed to be long-term investments, to meet retirement and other long-range
goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes
and insurance company charges may apply if you withdraw your money early. Variable annuities
also involve investment risks, just as mutual funds do.
Non-U.S. securities present certain risks such as currency fluctuation, political and economic
change, social unrest, changes in government regulation, differences in accounting and the lesser
degree of accurate public information available.
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Item 9: Disciplinary Information
A. Criminal or Civil Actions
There are no criminal or civil actions to report under this item.
B. Administrative Proceedings
There are no administrative proceedings to report under this item.
C. Self-regulatory Organization (SRO) Proceedings
There are no self-regulatory organization proceedings to report under this item.
Item 10: Other Financial Industry Activities and Affiliations
A. Registration as a Broker/Dealer or Broker/Dealer Representative
Neither WCF nor its representatives are registered as, or have pending applications to become, a
broker/dealer or a representative of a broker/dealer.
B. Registration as a Futures Commission Merchant, Commodity Pool
Operator, or a Commodity Trading Advisor
Neither WCF nor its representatives are registered as or have pending applications to become
either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading
Advisor or an associated person of the foregoing entities.
C. Registration Relationships Material to this Advisory Business and
Possible Conflicts of Interests
Steven Nuckols is an independent licensed insurance agent in the State of California, and from
time to time, will offer clients advice or products from those activities. Clients should be aware
that these services pay a commission or other compensation and involve a conflict of interest, as
commissionable products conflict with the fiduciary duties of a registered investment adviser.
WCF always acts in the best interest of the client, including the sale of commissionable products
to advisory clients. Clients are in no way required to utilize the services of any representative of
WCF in connection with such individual's activities outside of WCF. Clients will not be billed
advisory fees for commissionable product sales by WCF supervised persons.
D. Selection of Other Advisers or Managers and How This Adviser is
Compensated for Those Selections
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WCF may utilize the services of a Sub-Adviser to manage Clients’ investment portfolios. Sub-
Advisers will maintain the models or investment strategies agreed upon between Sub-Adviser
and WCF. Sub-Advisers execute all trades on behalf of WCF Client accounts. WCF will be
responsible for the overall direct relationship with the Client. WCF retains the authority to
terminate the Sub-Adviser relationship at WCF’s discretion.
WCF ensures that before selecting other advisers for Client that the other advisers are properly
licensed or registered as an investment advisor. In addition to the authority granted to WCF
Clients will grant WCF full discretionary authority and authorizes WCF to select and appoint one
or more independent investment advisers to provide investment advisory services to Client
without prior consultation with or the prior consent of Client. Such Advisers shall have all of the
same authority relating to the management of Client’s investment accounts as is granted to WCF
in the Agreement. This practice represents a conflict of interest as WCF may select Sub-Advisers
who charge a higher or lower fee for their services than other Sub-Advisers. This conflict is
mitigated by disclosures, procedures, and by the fact that WCF has a fiduciary duty of care to
place the best interest of the Client first and will adhere to their code of ethics.
Item 11: Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
A. Code of Ethics
WCF has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales,
Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities,
Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors,
Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting,
Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and
Education, Recordkeeping, Annual Review, and Sanctions. WCF's Code of Ethics is available free
upon request to any client or prospective client.
B. Recommendations Involving Material Financial Interests
WCF does not recommend that clients buy or sell any security in which a related person to WCF
or WCF has a material financial interest.
C. Investing Personal Money in the Same Securities as Clients
From time to time, investment adviser representatives of WCF may buy or sell securities for
themselves that they also recommend to clients. This may provide an opportunity for investment
adviser representatives of WCF to buy or sell the same securities before or after recommending
the same securities to clients resulting in investment adviser representatives profiting from the
recommendations they provide to clients. Such transactions create a conflict of interest. WCF will
always document any transactions that could be construed as conflicts of interest and will never
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engage in trading that operates to the client’s disadvantage when similar securities are being
bought or sold.
D. Trading Securities At/Around the Same Time as Clients’ Securities
From time to time, investment adviser representatives of WCF may buy or sell securities for
themselves at or around the same time as clients. This may provide an opportunity for
representatives of WCF to buy or sell securities before or after recommending securities to clients
resulting in investment adviser representatives profiting from the recommendations they provide
to clients. Such transactions create a conflict of interest; however, WCF will never engage in
trading that operates to the client’s disadvantage if investment adviser representatives of WCF
buy or sell securities at or around the same time as clients.
Item 12: Brokerage Practices
A. Factors Used to Select Custodians and/or Broker/Dealers
Custodians/broker-dealers will be recommended based on WCF’s duty to seek “best execution,”
which is the obligation to seek execution of securities transactions on the most favorable terms
for the client under the circumstances. Clients will not necessarily pay the lowest commission or
commission equivalent, and WCF may also consider the market expertise and research access
provided by the broker-dealer/custodian, including but not limited to access to written research,
oral communication with analysts, admittance to research conferences and other resources
provided by the brokers that may aid in WCF's research efforts. WCF will never charge a
premium or commission on transactions, beyond the actual cost imposed by the broker-
dealer/custodian.
WCF will require clients to use Charles Schwab Institutional (“Schwab”) or Fidelity Investments
(“Fidelity”), both FINRA (www.finra.org) and SIPC (www.sipc.org) members and SEC registered
Broker-Dealers.
1. Research and Other Soft-Dollar Benefits
While WCF has no formal soft dollar program in which soft dollars are used to pay for third
party services, WCF may receive research, products, or other services from custodians and
broker-dealers in connection with client securities transactions (“soft dollar benefits”). WCF
may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor
contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be
no assurance that any client will benefit from soft dollar research, whether or not the client’s
transactions paid for it, and WCF does not seek to allocate benefits to client accounts
proportionate to any soft dollar credits generated by the accounts. WCF benefits by not having
to produce or pay for research, products, or services, and WCF will have an incentive to
recommend a broker-dealer based on receiving research or services. Clients should be aware
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that WCF’s acceptance of soft dollar benefits may result in higher commissions charged to the
client.
2. Brokerage for Client Referrals
WCF receives no referrals from a broker-dealer or third party in exchange for using that
broker-dealer or third party.
3. Clients Directing Which Broker/Dealer/Custodian to Use
WCF will require clients to use a specific broker-dealer to execute transactions. Not all
advisers require clients to use a particular broker-dealer.
B. Aggregating (Block) Trading for Multiple Client Accounts
If WCF buys or sells the same securities on behalf of more than one client, then it may (but would
be under no obligation to) aggregate or bunch such securities in a single transaction for multiple
clients to seek more favorable prices, lower brokerage commissions, or more efficient execution.
In such case, WCF would place an aggregate order with the broker on behalf of all such clients in
order to ensure fairness for all clients; provided, however, that trades would be reviewed
periodically to ensure that accounts are not systematically disadvantaged by this policy. WCF
would determine the appropriate number of shares and select the appropriate brokers consistent
with its duty to seek best execution, except for those accounts with specific brokerage direction
(if any).
Item 13: Review of Accounts
A. Frequency and Nature of Periodic Reviews and Who Makes Those
Reviews
All client accounts for WCF's advisory services provided on an ongoing basis are reviewed at
least quarterly by Steven Nuckols, President, regarding clients’ respective investment policies,
stated objectives, and risk tolerance levels.
Financial planning services are generally provided to all clients to identify their financial situation
as a one-time initial service when a client signs an advisory services agreement with WCF and as
clients’ needs and financial situations change. The review and planning process is completed by
Steven Nuckols. WCF’s financial planning services are complimentary to new clients and will
generally conclude upon delivery of the initial financial planning report.
B. Factors That Will Trigger a Non-Periodic Review of Client
Accounts
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Reviews may be triggered by material market, economic or political events, or by changes in
client's financial situations (such as retirement, termination of employment, physical move, or
inheritance). Reviews will generally occur annually and will also be provided upon request.
C. Content and Frequency of Regular Reports Provided to Clients
Each client of WCF's advisory services provided on an ongoing basis will receive a quarterly
report detailing the client’s account, including assets held, asset value, and calculation of fees.
This written report will come from the account custodian. WCF will also provide a separate
written statement to the client at least quarterly. Clients are urged to compare the WCF-prepared
report to the statements provided by the account custodian. If a discrepancy is identified, clients
are urged to contact us.
Item 14: Client Referrals and Other Compensation
A. Economic Benefits Provided by Third Parties for Advice Rendered
to Clients (Includes Sales Awards or Other Prizes)
WCF does not receive any economic benefit, directly or indirectly from any third party for advice
rendered to WCF's clients.
With respect to Schwab and Fidelity, WCF receives access to their institutional trading and
custody services, which are typically not available to retail investors. These services generally are
available to independent investment advisers on an unsolicited basis, at no charge to them so
long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at
the custodian. Schwab’s and Fidelity’s services include brokerage services that are related to the
execution of securities transactions, custody, research, including that in the form of advice,
analyses and reports, and access to mutual funds and other investments that are otherwise
generally available only to institutional investors or would require a significantly higher
minimum initial investment. For WCF client accounts maintained in its custody, Schwab and
Fidelity generally do not charge separately for custody services but are compensated by account
holders through commissions or other transaction-related or asset-based fees for securities trades
that are executed through them, or that settle into their accounts.
Schwab and Fidelity also make available to WCF other products and services that benefit WCF
but may not benefit its clients’ accounts. These benefits may include national, regional or WCF
specific educational events organized and/or sponsored by them. Other potential benefits may
include occasional business entertainment of personnel of WCF, including meals, invitations to
sporting events, including golf tournaments, and other forms of entertainment, some of which
may accompany educational opportunities. Other of these products and services assist WCF in
managing and administering clients’ accounts. These include software and other technology (and
related technological training) that provide access to client account data (such as trade
confirmations and account statements), facilitate trade execution (and allocation of aggregated
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trade orders for multiple client accounts, if applicable), provide research, pricing information and
other market data, facilitate payment of WCF’s fees from its clients’ accounts (if applicable), and
assist with back-office training and support functions, recordkeeping and client reporting.
Many of these services generally may be used to service all or some substantial number of WCF’s
accounts. Schwab and Fidelity also make available to WCF other services intended to help WCF
manage and further develop its business enterprise. These services may include professional
compliance,
legal and business consulting, publications and conferences on practice
management, information technology, business succession, regulatory compliance, employee
benefits providers, human capital consultants, insurance, and marketing. In addition, they may
make available, arrange and/or pay vendors for these types of services rendered to WCF by
independent third parties. Schwab and Fidelity may discount or waive fees it would otherwise
charge for some of these services or pay all or a part of the fees of a third-party providing these
services to WCF. WCF is independently owned and operated and is not affiliated with Schwab
or Fidelity.
B. Compensation to Non – Advisory Personnel for Client Referrals
WCF may enter into written referral arrangements with third parties to act as “solicitors”,
“promoters”, or “endorsers” for WCF's investment management services. These referral
relationships will be fully disclosed to each Client to the extent required by applicable law. WCF
will ensure each solicitor, promoter and/or endorser is exempt, notice filed or properly registered
in all appropriate jurisdictions.
WCF does not currently have any such written agreements. However, based on the tax and
accounting services offered by WCF’s affiliated firm, Wealth Compass Tax and Accounting, and
WCF’s affiliated insurance agency, Wealth Compass Insurance Services, clients of any of these
individual firms may refer clients to the others based on Client needs or requests without
exchanging fees or compensation for such referrals. Clients always have the option to refuse
WCF’s advice, or the advice of WCF’s affiliated tax and accounting firm, Wealth Compass Tax
and Accounting, and affiliated insurance agency, Wealth Compass Insurance Services.
Item 15: Custody
WCF does not maintain custody of client funds at any time. However, when advisory fees are
deducted directly from client accounts at client's custodian, WCF will be deemed to have limited
custody of client's assets and must have written authorization from the client to do so. Clients
will receive all account statements directly from the account custodian/broker-dealer (Schwab or
Fidelity) and they should carefully review those statements for accuracy.
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Item 16: Investment Discretion
WCF accepts discretionary authority to manage securities accounts on behalf of clients. The
advisory contract established with each client sets forth the discretionary authority for trading.
Where investment discretion has been granted, WCF generally manages the client’s account and
makes investment decisions without consultation with the client as to when the securities are to
be bought or sold for the account, the total amount of the securities to be bought/sold, what
securities to buy or sell, or the price per share. Clients may limit our discretionary authority in
the management of their account(s) by indicating any limitations in the client advisory contract.
Item 17: Voting Client Securities (Proxy Voting)
WCF will not ask for, nor accept voting authority for client securities. Clients will receive proxies
directly from the issuer of the security they own, or from the account custodian. Clients should
direct all proxy questions to the issuer of the security.
Item 18: Financial Information
A. Balance Sheet
WCF neither requires nor solicits prepayment of more than $1,200 in fees per client, six months
or more in advance, and therefore is not required to include a balance sheet with this brochure.
B. Financial Conditions Reasonably Likely to Impair Ability to Meet
Contractual Commitments to Clients
Neither WCF nor its management has any financial condition that is likely to reasonably impair
WCF’s ability to meet contractual commitments to clients.
C. Bankruptcy Petitions in Previous Ten Years
Neither WCF nor its owner has been the subject of a bankruptcy petition.
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Business Continuity Plan Client Notice
The Firm maintains a written business continuity plan to safeguard client data and information
from data breaches and varying levels of other unforeseen circumstances related to management
persons. The Plan includes a response and notification plan if a breach occurs involving the
exposure of client private information.
The Plan covers natural disasters such as earthquakes, hurricanes, tornados, flooding, wildfires,
and pandemics, among other natural disasters.
The Plan also covers man-made disasters such as fires, bomb threats, nuclear emergencies,
chemical events, biological events, railway accidents, cyber or ransomware events, and aircraft
accidents, as well as loss of utilities such as electrical power, loss of water pressure, T-1
communications line outages, and Internet outages. Electronic files are backed up daily and
archived offsite, as well as being archived in a cloud-based data bank.
An alternate office is identified to support ongoing operations in the event the main office is
unavailable. Our alternative office is at WCF’s affiliated Tax and Accounting firm located at 940
Canterbury Place, Suite 100, Escondido, CA 92025.
It is our intention to contact all clients within five days of a disaster that disrupts our operations,
services, and/or dictates moving our office to an alternate location.
WCF has sufficient members of the advisory and operations team to continue operations and
business in the event of a loss of key personnel member.
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Client Privacy Policy Notice
Your relationship with WCF is based on trust and confidence. To fulfill its responsibilities to
you, WCF requires that you provide current and accurate financial and personal information.
You deserve to expect that WCF will protect the information you have provided in a manner
that is safe, secure, and professional. WCF and its employees are committed to protecting
your privacy and to safeguarding that information.
Your Privacy
WCF requires that you provide current and accurate financial and personal information so that
we may make the best possible choices for your circumstances. We will protect the information
you have provided in a manner that is safe, secure, and professional.
We recognize the importance of protecting our clients’ privacy. We have policies to maintain the
confidentiality and security of your non-public personal information. The following is designed
to help you understand what information we collect from you and how we use that information
to serve you.
Information Security
WCF maintains an information security program to reduce the risk that your personal, private,
non-public, and confidential information may be breached. WCF is committed to maintaining
the confidentiality, integrity and security of our clients’ personal information that is entrusted to
us.
During regular business hours, access to client records is monitored so that only those with
approved entitlements may access the information. During hours in which the company is not in
operation, client records are secured.
We maintain a secure office to ensure that your cloud-based personal information is not placed
at unreasonable risk. We employ a firewall barrier, secure data encryption techniques and multi-
factor authentication procedures in our computer environment.
Information We Collect
To fulfill our responsibilities to you in providing you with wealth management services, WCF
requires that you provide current and accurate financial and personal nonpublic information for
which we base our recommendations on. In the normal course of business, we collect client data
in checklists, forms, in written notations, in documentation provided to us by our clients for
evaluation, planning, investing or other related consulting services, and data about client
transactions with us, such as types of investments and account status. We also create internal
lists of such data.
The categories of non-public information that we collect from you may include information about
your personal finances, information about your health to the extent that it is needed for the
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financial planning process, information about transactions between you and third parties, and
information from consumer reporting agencies, e.g., credit reports. We use this information to
help you plan, invest, and work towards your personal financial goals.
Safeguarding Customer Documents
We have physical, electronic, and procedural security safeguards to protect and secure the
information we collect. We restrict access to nonpublic personal information about our clients
to those employees and agents who need to know that information to provide products and
services to our clients.
During regular business hours, access to client records is monitored so that only those with
approved entitlements may access the files. During hours in which the company is not in
operation, the client records will be secured. No individual who is not so authorized shall obtain
or seek to obtain personal and financial client information. No individual with authorization
to access personal and financial client information shall share that information in any manner
without the specific consent of a firm principal. Failure to observe WCF procedures regarding
client and consumer privacy will result in disciplinary action and may include termination.
Although we make good-faith efforts to maintain the security of your personal information, we
cannot guarantee that it will remain free from unauthorized access, use, disclosure, or alteration
or that our security measures will prevent unauthorized persons and bad actors from accessing
or obtaining this information.
Notification in the Event of a Data Breach
WCF has adopted an incident response program in the event of a data breach event. If your non-
public information is breached by an unauthorized party, we will comply with applicable laws
in notifying you of the breach as soon as possible, within 30 days of discovery. This includes
critical third parties we do business with that may experience a breach affecting information
about you that could be used to harm you.
Sharing Non‐Public Personal and Financial Information
WCF will not share such information with any affiliated or non-affiliated third party except:
When necessary to complete a transaction in a client account, such as with the clearing
firm or account custodians;
When required to maintain or service a client account;
To resolve client disputes or inquiries;
With persons acting in a fiduciary or representative capacity on behalf of the
client;
With rating agencies, persons assessing compliance with industry standards, or to the
attorneys, accountants and auditors of the firm;
In connection with a sale or merger of WCF’s business;
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To protect against or prevent actual or potential fraud, identity theft, unauthorized
transactions, claims or other liability;
To comply with federal, state or local laws, rules and other applicable legal
requirements;
In connection with a written agreement to provide investment management or
advisory services when the information is released for the sole purpose of providing the
products or services covered by the agreement;
In any circumstances with the client’s instruction or consent; or
Pursuant to any other exceptions enumerated in the California Consumer Information
Privacy Act.
Updating Your Personal Information and Privacy Preferences
You have the right to access and correct or change any personal information that you provide to
us at any time. If you believe that an error has been made in accordance with the information
collected from you, we will correct such errors upon adequate verification of the error and the
identity of the person seeking the correction. Contact your IAR or send us an email or letter. Any
changes to the information that you have provided may affect the recommendations we make to
you, the management of your account, or the delivery of other services and information to you.
We will respond to your request within thirty days.
Personally identifiable information (“PII”) about you will be maintained while you are a client,
and for the required period thereafter that records are required to be maintained by federal and
state securities laws. After that time, information will be securely destroyed.
Opt‐Out Provisions
It is a policy of WCF to not share non-public personal and financial information with affiliated or
unaffiliated third parties except under the circumstances noted above. Since sharing under
the circumstances noted above is necessary to service client accounts or is mandated by
law, there are no allowances made for clients to “opt out”.
If you decide to close your account(s) or become an inactive client, we will continue to adhere to
the privacy policies and practices described in this notice. We reserve the right to change this
policy at any time, and you will be notified if any changes do occur.
We are required by law to deliver this Privacy Notice to you annually, in writing. If you have
any questions after reading this Privacy Policy, please contact us at (760) 509-4000.
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This ADV Part 2B Brochure Supplement provides information about Steven T. Nuckols that supplements
the Wealth Compass Financial, Inc. ADV Part 2A Disclosure Brochure. You should have received a copy of
that Disclosure Brochure. Please contact Steven Nuckols if you did not receive Wealth Compass Financial,
Inc.’s ADV Part 2A Disclosure Brochure, or if you have any questions about the contents of this supplement.
Additional information about Steven Nuckols (CRD# 6320555) is also available on the SEC’s website at
www.adviserinfo.sec.gov.
Wealth Compass Financial, Inc.
Form ADV Part 2B – Individual Disclosure Brochure
for
Steven T. Nuckols
Personal CRD Number: 6320555
President, Founder, and Investment Adviser Representative
Wealth Compass Financial, Inc.
5860 Owens Ave #100
(760) 509-4000
snuckols@wealthcompass.com
Updated: 3/19/2026
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Item 2: Educational Background and Business Experience
Steven T. Nuckols
Name:
Born:
1990
Education: B.A. Russian, Brigham Young University - 2014
Business Background:
09/2017 - Present
President, Founder & CCO
Wealth Compass Financial, Inc.
03/2021 – Present
Founder, Insurance Agent
Wealth Compass Insurance Services
01/2024 – Present
Founder, Owner
Wealth Compass Tax and Accounting
02/2017 – 08/2017
Unemployed
10/2016 - 01/2017
Advisor Assistant
Blankinship and Foster
06/2015 - 09/2016
Financial Planner
Gunderson Capital Management
05/2014 - 05/2015
Financial Representative
Northwestern Mutual
Item 3: Disciplinary Information
There are no legal or disciplinary events that are material to a client’s or prospective client’s
evaluation of this advisory business. Additional information regarding Steven Nuckols’
registration as an investment adviser representative may be found by accessing the SEC’s
public disclosure website at www.adviserinfo.sec.gov.
Item 4: Other Business Activities
Steven Nuckols is an independent licensed insurance agent, and from time to time will offer
clients advice or products from those activities. Clients should be aware that these services pay a
commission or other compensation and involve a conflict of interest, as commissionable products
conflict with the fiduciary duties of a registered investment adviser. When he sells an insurance
product, Mr. Nuckols receives a commission. This presents a conflict of interest because it creates
an incentive to recommend investment products based on the compensation received, rather than
on the needs of clients. WCF always acts in the best interests of the client, including the sale of
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commissionable products to advisory clients. Clients are in no way required to utilize the services
of any representative of WCF in connection with such individual's activities outside of WCF.
Item 5: Additional Compensation
Steven Nuckols does not receive any economic benefit from any person, company, or
organization, other than Wealth Compass Financial, Inc. in exchange for providing clients
investment advisory services through Wealth Compass Financial, Inc.
Mr. Nuckols receives compensation or other benefits through his CA insurance license through
Wealth Compass Insurance Services when he sells an insurance policy or product, as disclosed in
Item 4.
Mr. Nuckols also receives net income of business revenue as owner and officer of Wealth
Compass Tax & Accounting, which provides tax services. Mr. Nuckols is not a tax professional
or an accountant, and does not provide tax advice or services.
Mr. Nuckols may also receive compensation or benefits through his affiliation with Advisors
Excel, LLC (and/or its affiliated companies). Such additional compensation and benefits
generally consist of cash bonus payments and reward trips based on insurance product sales
performance.
Item 6: Supervision
As the President and Chief Compliance Officer of Wealth Compass Financial, Inc., Steven
Nuckols supervises all activities of the firm. Mr. Nuckols' contact information is on the cover
page of this disclosure document. Mr. Nuckols adheres to applicable regulatory requirements,
together with the firm’s compliance policies and procedures, its outlined code of ethics and
conduct standards.
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This ADV Part 2B Brochure Supplement provides information about Tod Leighton Lenhoff that supplements
the Wealth Compass Financial, Inc. ADV Part 2A Disclosure Brochure. You should have received a copy of
that Disclosure Brochure. Please contact Steven Nuckols if you did not receive Wealth Compass Financial,
Inc.’s ADV Part 2A Disclosure Brochure, or if you have any questions about the contents of this supplement.
Additional information about Tod Lenhoff (CRD# 3255143) is also available on the SEC’s website at
www.adviserinfo.sec.gov.
Wealth Compass Financial, Inc.
Form ADV Part 2B – Individual Disclosure Brochure
for
Tod L. Lenhoff
Personal CRD Number: 3255143
Wealth Compass Financial, Inc.
5860 Owens Ave #100
(760) 509-4000
tlenhoff@wealthcompass.com
Updated: 3/19/2026
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Item 2: Educational Background and Business Experience
Tod L. Lenhoff
Name:
Born:
1960
Education: B.A. Business, Cal State Northridge – 1982
Professional Designations:
CPA (Certified Public Accountant)
Business Background:
06/2021 - Present Wealth Manager / Investment Adviser Representative
Wealth Compass Financial, Inc.
03/2021 – Present
Insurance Agent
Wealth Compass Insurance Services
12/2016 – 06/2021
Investment Advisor Representative
AE Wealth Management, LLC
07/2002 - 03/2021 President
Lenhoff Senior Planning, Inc
07/2002 - 03/2021 President/Insurance Agent
Lenhoff Financial Group
12/2016 - 11/2017 Registered Representative
Madison Avenue Securities, LLC
10/2014 - 12/2016 Registered Representative
GF Investment Services LLC
10/2014 - 12/2016
Investment Advisor Representative
Global Financial Private Capital, LLC
Item 3: Disciplinary Information
Tod L. Lenhoff has no civil, criminal, administrative or regulatory events to report.
Additional information regarding Mr. Lenhoff’s registration as an investment adviser may
be found by accessing the SEC’s public disclosure website at www.adviserinfo.sec.gov.
Item 4: Other Business Activities
Mr. Lenhoff is licensed in California as an insurance agent with Wealth Compass Insurance
Services to offer insurance and annuities, and may offer life insurance and annuity products to
people that may also be clients of Wealth Compass Financial, Inc. When he sells an insurance or
annuity product, Mr. Lenhoff may receive a commission directly from Wealth Compass
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Insurance Services. This presents a conflict of interest because it creates an incentive to
recommend insurance products based on the compensation received, rather than on the needs of
clients.
Wealth Compass Financial, Inc. addresses this conflict with disclosures and compliance and
supervisory policies and procedures, which require all investment advisory recommendations to
be made in the best interest of our clients. Clients are under no obligation to purchase any product
or service. But when doing so, you are not obligated to purchase through Mr. Lenhoff, but may
choose another
insurance agent or agency, even when acting upon Mr. Lenhoff’s
recommendation(s).
Mr. Lenhoff is a Certified Public Accountant (CPA) in good standing. However, Mr. Lenhoff
does not operate a tax business or receive compensation for any tax advice.
Item 5: Additional Compensation
Tod Lenhoff does not receive any economic benefit from any person, company, or organization
other than Wealth Compass Financial, Inc. in exchange for providing clients advisory services
through Wealth Compass Financial, Inc.
Mr. Lenhoff may receive compensation or benefits through his insurance licensing from Wealth
Compass Insurance Services.
Item 6: Supervision
Wealth Compass Financial’s CCO, Steven Nuckols, supervises all activities of the firm. Tod
Lenhoff adheres to applicable regulatory requirements, together with all policies and procedures
outlined in the firm’s code of ethics and compliance policies and procedures manual. Clients may
contact Mr. Nuckols at (760) 509-4000 with any questions regarding supervision or compliance
procedures.
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