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Item 1: Cover Page
Part 2A of Form ADV: Firm Brochure
July 2025
1980 E River Road #120
Tucson, AZ 85718
www.wmpaz.com
Firm Contact:
Hollie Butler
Chief Compliance Officer
firm
is also available on
This brochure provides information about the qualifications and business practices of Wealth
Management Partners, LLC. If clients have any questions about the contents of this brochure, please
contact us at 520-297-7999. 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.
the SEC’s website at
information about our
Additional
www.adviserinfo.sec.gov by searching CRD #309790.
Please note that the use of the term “registered investment adviser” and description of our firm
and/or our associates as “registered” does not imply a certain level of skill or training. Clients are
encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise
clients for more information on the qualifications of our firm and our employees.
Item 2: Material Changes
Wealth Management Partners, LLC is required to notify clients of any information that has changed
since the last annual update of the Firm Brochure (“Brochure”) that may be important to them.
Clients can request a full copy of our Brochure or contact us with any questions that they may have
about the changes.
Since our most recent annual amendment filing, we have the following material changes to disclose:
• Our firm has amended Item 10 of this brochure to disclose that the representatives of our
firm who are licensed insurance agents do not recommend insurance products in connection
with the advisory services offered and receive no compensation from insurance-related
products.
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Wealth Management Partners, LLC
Item 3: Table of Contents
Item 1: Cover Page ....................................................................................................................................... 1
Item 2: Material Changes ............................................................................................................................ 2
Item 3: Table of Contents ............................................................................................................................ 3
Item 4: Advisory Business .......................................................................................................................... 4
Item 5: Fees & Compensation ..................................................................................................................... 6
Item 6: Performance-Based Fees & Side-By-Side Management .............................................................. 7
Item 7: Types of Clients & Account Requirements ................................................................................... 7
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ........................................................ 8
Item 9: Disciplinary Information .............................................................................................................. 16
Item 10: Other Financial Industry Activities & Affiliations .................................................................... 16
Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading .......... 16
Item 12: Brokerage Practices ................................................................................................................... 17
Item 13: Review of Accounts .................................................................................................................... 20
Item 14: Client Referrals & Other Compensation ................................................................................... 21
Item 15: Custody ....................................................................................................................................... 21
Item 16: Investment Discretion ............................................................................................................... 22
Item 17: Voting Client Securities .............................................................................................................. 22
Item 18: Financial Information ................................................................................................................ 22
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Wealth Management Partners, LLC
Item 4: Advisory Business
Our firm provides individuals and other types of clients with a wide array of investment advisory
services. Our firm is a limited liability company formed under the laws of the State of Arizona in 2004
and has been in business as a registered investment adviser since 2020. Our firm is owned by Morgan
Brown and Thomas Curtis.
The purpose of this Brochure is to disclose the conflicts of interest associated with the investment
transactions, compensation and any other matters related to investment decisions made by our firm
or its representatives. As a fiduciary, it is our duty to always act in the client’s best interest. This is
accomplished in part by knowing our client. Our firm has established a service-oriented advisory
practice with open lines of communication for many different types of clients to help meet their
financial goals while remaining sensitive to risk tolerance and time horizons. Working with clients to
understand their investment objectives while educating them about our process, facilitates the kind
of working relationship we value.
Types of Advisory Services Offered
Asset Management:
As part of our Asset Management service, a portfolio is created, consisting of individual stocks, bonds,
exchange traded funds (“ETFs”), options, mutual funds and other public and private securities or
investments. The client’s individual investment strategy is tailored to their specific needs and may
include some or all of the previously mentioned securities. Portfolios will be designed to meet a
particular investment goal, determined to be suitable to the client’s circumstances. Once the appropriate
portfolio has been determined, portfolios are continuously and regularly monitored, and if necessary,
rebalanced based upon the client’s individual needs, stated goals and objectives.
Financial Planning & Consulting:
Our firm provides a variety of standalone financial planning and consulting services to clients for the
management of financial resources based upon an analysis of current situation, goals, and objectives.
Financial planning services will typically involve preparing a financial plan or rendering a financial
consultation for clients based on the client’s financial goals and objectives. This planning or
consulting may encompass Investment Planning, Retirement Planning, Estate Planning, Charitable
Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study,
Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of
Credit Evaluation, or Business and Personal Financial Planning.
Written financial plans or financial consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the clients.
Implementation of the recommendations will be at the discretion of the client. Our firm provides
clients with a summary of their financial situation, and observations for financial planning
engagements. Financial consultations are not typically accompanied by a written summary of
observations and recommendations, as the process is less formal than the planning service. Assuming
that all the information and documents requested from the client are provided promptly, plans or
consultations are typically completed within 6 months of the client signing a contract with our firm.
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Wealth Management Partners, LLC
Retirement Plan Consulting:
Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing
basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing,
monitoring and reviewing their company's participant-directed retirement plan. As the needs of the
plan sponsor dictate, areas of advising may include:
•
• Establishing an Investment Policy Statement – Our firm will assist in the development of
a statement that summarizes the investment goals and objectives along with the broad
strategies to be employed to meet the objectives.
Investment Options – Our firm will work with the Plan Sponsor to evaluate existing
investment options and make recommendations for appropriate changes.
•
• Asset Allocation and Portfolio Construction – Our firm will develop strategic asset
allocation models to aid Participants in developing strategies to meet their investment
objectives, time horizon, financial situation and tolerance for risk.
Investment Monitoring – Our firm will monitor the performance of the investments and
notify the client in the event of over/underperformance and in times of market volatility.
• Participant Education – Our firm will provide opportunities to educate plan participants
about their retirement plan offerings, different investment options, and general guidance on
allocation strategies.
In providing services for retirement plan consulting, our firm does not provide any advisory services
with respect to the following types of assets: employer securities, real estate (excluding real estate
funds and publicly traded REITS), participant loans, non-publicly traded securities or assets, other
illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement
plan consulting services shall be in compliance with the applicable state laws regulating retirement
consulting services. This applies to client accounts that are retirement or other employee benefit
plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended
(“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to provide
services to such accounts, our firm acknowledges its fiduciary standard within the meaning of Section
3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to
the provision of services described therein.
Tailoring of Advisory Services
Our firm offers individualized investment advice to our Asset Management clients. General
investment advice will be offered to our Financial Planning & Consulting and Retirement Plan
Consulting clients.
Each Asset Management client has the opportunity to place reasonable restrictions on the types of
investments to be held in the portfolio. Restrictions on investments in certain securities or types of
securities may not be possible due to the level of difficulty this would entail in managing the account.
Participation in Wrap Fee Programs
Our firm does not offer or sponsor a wrap fee program.
Regulatory Assets Under Management
As of December 31, 2024, our firm manages $642,395,934 on a discretionary basis and $24,646,758
on a non-discretionary basis for a total of $667,042,692 in regulatory assets under management.
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Wealth Management Partners, LLC
Item 5: Fees & Compensation
Compensation for Our Advisory Services
Asset Management:
The maximum annual fee charged for this service will not exceed 1.50%. Fees to be assessed will be
outlined in the advisory agreement to be signed by the Client. Annualized fees are billed on a pro-
rata basis quarterly in advance or arrears based on the value of the account(s) on the last day of the
quarter (previous quarter for clients billed in advance), as applicable. Fees are negotiable and will be
deducted from client account(s). Adjustments will be made for withdrawals only if the entire balance
of the account is withdrawn. In rare cases, our firm will agree to directly invoice. Further, it is
important to note that our firm will assess advisory fees on cash and cash equivalents held in client
accounts. As part of this process, Clients understand the following:
a) The client’s independent custodian sends statements at least quarterly showing the market
values for each security included in the Assets and all account disbursements, including the
amount of the advisory fees paid to our firm;
b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our
firm will send an invoice directly to the custodian; and
c) If our firm sends a copy of our invoice to the client, a legend urging the comparison of
information provided in our statement with those from the qualified custodian will be
included.
Financial Planning & Consulting:
Our firm charges on an hourly or flat fee basis for financial planning and consulting services. The total
estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of our
engagement with the client. The maximum hourly fee to be charged will not exceed $400. Flat fees
will not exceed $10,000. The fee-paying arrangements will be determined on a case-by-case basis
and will be detailed in the signed consulting agreement. Our firm will not require a retainer exceeding
$1,200 when services cannot be rendered within 6 months.
Retirement Plan Consulting:
Our Retirement Plan Consulting services are billed on a flat fee or a fee based on the percentage of
Plan assets under management. The total estimated fee, as well as the ultimate fee charged, is based
on the scope and complexity of our engagement with the client. Our flat fees will not exceed $50,000.
Fees will not exceed 1.00% annually. The fee-paying arrangements will be determined on a case-by-
case basis and will be detailed in the signed consulting agreement.
Other Types of Fees & Expenses
Clients will incur transaction fees for trades executed by their chosen custodian, via individual
transaction charges. These transaction fees are separate from our firm’s advisory fees and will be
disclosed by the chosen custodian. Our firm’s recommended custodian, Raymond James and
Associates, Inc., does not charge transaction fees for U.S. listed equities and exchange traded funds.
Clients may also pay holding charges imposed by the chosen custodian for certain investments,
charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be
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Wealth Management Partners, LLC
disclosed in the fund’s prospectus (i.e., fund management fees, initial or deferred sales charges,
mutual fund sales loads, 12b-1 fees, surrender charges, variable annuity fees, IRA and qualified
retirement plan fees, and other fund expenses), mark-ups and mark-downs, spreads paid to market
makers, fees for trades executed away from custodian, wire transfer fees and other fees and taxes on
brokerage accounts and securities transactions. Our firm does not receive a portion of these fees.
Termination & Refunds
Either party may terminate the advisory agreement signed with our firm for our Asset Management
service in writing at any time. Upon notice of termination our firm will either process a pro-rata
refund of the unearned portion of the advisory fees charged in advance or charge the client for
services rendered up to the point of termination if charged in arrears. If advisory fees cannot be
deducted, our firm will send an invoice for due advisory fees to the client.
Financial Planning & Consulting clients may terminate their agreement at any time before the
delivery of a financial plan by providing written notice. For purposes of calculating refunds, all work
performed by us up to the point of termination shall be calculated at the hourly fee currently in effect.
Clients will receive a pro-rata refund of unearned fees based on the time and effort expended by our
firm.
Either party to a Retirement Plan Consulting Agreement may terminate at any time by providing
written notice to the other party. Full refunds will only be made in cases where cancellation occurs
within 5 business days of signing an agreement. After 5 business days from initial signing, either
party must provide the other party 30 days written notice to terminate billing. Billing will terminate
30 days after receipt of termination notice. Clients will be charged on a pro-rata basis, which takes
into account work completed by our firm on behalf of the client. Clients will incur charges for bona
fide advisory services rendered up to the point of termination (determined as 30 days from receipt
of said written notice) and such fees will be due and payable.
Commissionable Securities Sales
Our firm and representatives do not sell securities for a commission in advisory accounts.
Item 6: Performance-Based Fees & Side-By-Side Management
Our firm does not charge performance-based fees.
Item 7: Types of Clients & Account Requirements
Our firm has the following types of clients:
Individuals and High Net Worth Individuals;
•
• Trusts or Estates;
• Pension and Profit-Sharing Plans;
• Corporations, Limited Liability Companies and/or Other Business Types
Our requirements for opening and maintaining accounts or otherwise engaging us:
• Our firm requires a minimum account balance of $500,000 for our Asset Management service.
Generally, this minimum account balance requirement is not negotiable and would be
required throughout the course of the client’s relationship with our firm. Exceptions may be
made by a case-by-case basis and must be approved by a principal of the firm.
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Wealth Management Partners, LLC
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
Methods of Analysis
We use the following methods of analysis in formulating our investment advice and/or managing
client assets:
Charting: In this type of technical analysis, our firm reviews charts of market and security activity in
an attempt to identify when the market is moving up or down and to predict how long the trend may
last and when that trend might reverse.
Fundamental Analysis: The analysis of a business's financial statements (usually to analyze the
business's assets, liabilities, and earnings), health, and its competitors and markets. When analyzing
a stock, futures contract, or currency using fundamental analysis there are two basic approaches one
can use: bottom up analysis and top down analysis. The terms are used to distinguish such analysis
from other types of investment analysis, such as quantitative and technical. Fundamental analysis is
performed on historical and present data, but with the goal of making financial forecasts. There are
several possible objectives: (a) to conduct a company stock valuation and predict its probable price
evolution; (b) to make a projection on its business performance; (c) to evaluate its management and
make internal business decisions; (d) and/or to calculate its credit risk.; and (e) to find out the
intrinsic value of the share.
When the objective of the analysis is to determine what stock to buy and at what price, there are two
basic methodologies investors rely upon: (a) Fundamental analysis maintains that markets may
misprice a security in the short run but that the "correct" price will eventually be reached. Profits can
be made by purchasing the mispriced security and then waiting for the market to recognize its
"mistake" and reprice the security.; and (b) Technical analysis maintains that all information is
reflected already in the price of a security. Technical analysts analyze trends and believe that
sentiment changes predate and predict trend changes. Investors' emotional responses to price
movements lead to recognizable price chart patterns. Technical analysts also analyze historical
trends to predict future price movement. Investors can use one or both of these different but
complementary methods for stock picking. This presents a potential risk, as the price of a security
can move up or down along with the overall market regardless of the economic and financial factors
considered in evaluating the stock.
Quantitative Analysis: The use of models, or algorithms, to evaluate assets for investment. The
process usually consists of searching vast databases for patterns, such as correlations among liquid
assets or price-movement patterns (trend following or mean reversion). The resulting strategies may
involve high-frequency trading. The results of the analysis are taken into consideration in the
decision to buy or sell securities and in the management of portfolio characteristics. A risk in using
quantitative analysis is that the methods or models used may be based on assumptions that prove to
be incorrect.
Investment Strategies We Use
We use the following strategies in managing client accounts, provided that such strategies are
appropriate to the needs of the client and consistent with the client's investment objectives, risk
tolerance, and time horizons, among other considerations:
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Wealth Management Partners, LLC
Cash & Cash Equivalents: Cash and cash equivalents generally refer to either United States dollars
or highly liquid short-term debt instruments such as, but not limited to, treasury bills, bank CD’s and
commercial papers. Generally, these assets are considered nonproductive and will be exposed to
inflation risk and considerable opportunity cost risk. Investments in cash and cash equivalents will
generally return less than the advisory fee charged by our firm. Our firm may recommend cash and
cash equivalents as part of our clients’ asset allocation when deemed appropriate and in their best
interest. Our firm considers cash and cash equivalents to be an asset class.
Debt Securities (Bonds): Issuers use debt securities to borrow money. Generally, issuers pay
investors periodic interest and repay the amount borrowed either periodically during the life of the
security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero
coupon bonds, which do not pay current interest, but rather are priced at a discount from their face
values and their values accrete over time to face value at maturity. The market prices of debt
securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In
general, market prices of debt securities decline when interest rates rise and increase when interest
rates fall. Bonds with longer rates of maturity tend to have greater interest rate risks.
Certain additional risk factors relating to debt securities include: (a) When interest rates are
declining, investors have to reinvest their interest income and any return of principal, whether
scheduled or unscheduled, at lower prevailing rates.; (b) Inflation causes tomorrow’s dollar to be
worth less than today’s; in other words, it reduces the purchasing power of a bond investor’s future
interest payments and principal, collectively known as “cash flows.” Inflation also leads to higher
interest rates, which in turn leads to lower bond prices.; (c) Debt securities may be sensitive to
economic changes, political and corporate developments, and interest rate changes. Investors can
also expect periods of economic change and uncertainty, which can result in increased volatility of
market prices and yields of certain debt securities. For example, prices of these securities can be
affected by financial contracts held by the issuer or third parties (such as derivatives) relating to the
security or other assets or indices. (d) Debt securities may contain redemption or call provisions
entitling their issuers to redeem them at a specified price on a date prior to maturity. If an issuer
exercises these provisions in a lower interest rate market, the account would have to replace the
security with a lower yielding security, resulting in decreased income to investors. Usually, a bond is
called at or close to par value. This subjects investors that paid a premium for their bond risk of lost
principal. In reality, prices of callable bonds are unlikely to move much above the call price if lower
interest rates make the bond likely to be called.; (e) If the issuer of a debt security defaults on its
obligations to pay interest or principal or is the subject of bankruptcy proceedings, the account may
incur losses or expenses in seeking recovery of amounts owed to it.; (f) There may be little trading in
the secondary market for particular debt securities, which may affect adversely the account's ability
to value accurately or dispose of such debt securities. Adverse publicity and investor perceptions,
whether or not based on fundamental analysis, may decrease the value and/or liquidity of debt
securities.
Our firm attempts to reduce the risks described above through diversification of the client’s portfolio
and by credit analysis of each issuer, as well as by monitoring broad economic trends and corporate
and legislative developments, but there can be no assurance that our firm will be successful in doing
so. Credit ratings for debt securities provided by rating agencies reflect an evaluation of the safety of
principal and interest payments, not market value risk. The rating of an issuer is a rating agency's
view of past and future potential developments related to the issuer and may not necessarily reflect
actual outcomes. There can be a lag between the time of developments relating to an issuer and the
time a rating is assigned and updated.
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Wealth Management Partners, LLC
Digital Assets: Digital Assets generally refers to an asset that is issued and/or transferred using
distributed ledger or blockchain technology, including, “virtual currencies” (also known as crypto-
currencies), “coins”, and “tokens”. We may invest client accounts in and/or advise clients on the
purchase or sale of digital assets. This advice or investment may be in actual digital
coins/tokens/currencies or via investment vehicles such as exchange traded funds (ETFs) or
separately managed accounts (SMAs). The investment characteristics of Digital Assets generally
differ from those of traditional securities, currencies. Digital Assets are not backed by a central bank
or a national, international organization, any hard assets, human capital, or other form of credit and
are relatively new to the market place. Rather, Digital Assets are market-based: a Digital Asset’s value
is determined by (and fluctuates often, according to) supply and demand factors, its adoption in the
traditional commerce channels, and/or the value that various market participants place on it through
their mutual agreement or transactions. The lack of history to these types of investments entail
certain unknown risks, are very speculative and are not appropriate for all investors.
Equity Securities: Equity securities represent an ownership position in a company. Equity securities
typically consist of common stocks. The prices of equity securities fluctuate based on, among other
things, events specific to their issuers and market, economic and other conditions. For example,
prices of these securities can be affected by financial contracts held by the issuer or third parties
(such as derivatives) relating to the security or other assets or indices. There may be little trading in
the secondary market for particular equity securities, which may adversely affect our firm 's ability
to value accurately or dispose of such equity securities. Adverse publicity and investor perceptions,
whether or not based on fundamental analysis, may decrease the value and/or liquidity of equity
securities. Investing in smaller companies may pose additional risks as it is often more difficult to
value or dispose of small company stocks, more difficult to obtain information about smaller
companies, and the prices of their stocks may be more volatile than stocks of larger, more established
companies. Clients should have a long-term perspective and, for example, be able to tolerate
potentially sharp declines in value.
Fixed Income: Fixed income is a type of investing or budgeting style for which real return rates or
periodic income is received at regular intervals and at reasonably predictable levels. Fixed-income
investors are typically retired individuals who rely on their investments to provide a regular, stable
income stream. This demographic tends to invest heavily in fixed-income investments because of the
reliable returns they offer. Fixed-income investors who live on set amounts of periodically paid
income face the risk of inflation eroding their spending power.
Some examples of fixed-income investments include treasuries, money market instruments,
corporate bonds, asset-backed securities, municipal bonds and international bonds. The primary risk
associated with fixed-income investments is the borrower defaulting on his payment. Other
considerations include exchange rate risk for international bonds and interest rate risk for longer-
dated securities. The most common type of fixed-income security is a bond. Bonds are issued by
federal governments, local municipalities and major corporations. Fixed-income securities are
recommended for investors seeking a diverse portfolio; however, the percentage of the portfolio
dedicated to fixed income depends on your own personal investment style. There is also an
opportunity to diversify the fixed-income component of a portfolio. Riskier fixed-income products,
such as junk bonds and longer-dated products, should comprise a lower percentage of your overall
portfolio.
The interest payment on fixed-income securities is considered regular income and is determined
based on the creditworthiness of the borrower and current market rates. In general, bonds and fixed-
income securities with longer-dated maturities pay a higher rate, also referred to as the coupon rate,
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Wealth Management Partners, LLC
because they are considered riskier. The longer the security is on the market, the more time it has to
lose its value and/or default. At the end of the bond term, or at bond maturity, the borrower returns
the amount borrowed, also referred to as the principal or par value.
Index Fund: A mutual fund or exchange-traded fund (“ETF”) designed to follow certain preset rules
so that the fund can track specified basket of underlying investments. Those rules may include
tracking prominent indexes like the S&P 500 or the Dow Jones Industrial Average or implementation
rules, such as tax-management, tracking error minimization, large block trading or patient/flexible
trading strategies that allows for greater tracking error, but lower market impact costs. Index funds
may also have rules that screen for social and sustainable criteria. An index fund’s rules of
construction clearly identify the type of companies suitable for the fund. The most commonly known
index fund, the S&P 500 Index Fund, is based on the rules established by S&P Dow Jones Indices for
their S&P 500 Index. Equity index funds would include groups of stocks with similar characteristics
such as the size, value, profitability and/or the geographic location of the companies. A group of
stocks may include companies from the United States, Non-US Developed, emerging markets or
Frontier Market countries. Additional index funds within these geographic markets may include
indexes of companies that include rules based on company characteristics or factors, such as
companies that are small, mid-sized, large, small value, large value, small growth, large growth, the
level of gross profitability or investment capital, real estate, or indexes based on commodities and
fixed-income. Companies are purchased and held within the index fund when they meet the specific
index rules or parameters and are sold when they move outside of those rules or parameters. Think
of an index fund as an investment utilizing rules-based investing. Some index providers announce
changes of the companies in their index before the change date and other index providers do not
make such announcements.
Index funds must periodically "rebalance" or adjust their portfolios to match the new prices and
market capitalization of the underlying securities in the stock or other indexes that they track. This
allows algorithmic traders to perform index arbitrage by anticipating and trading ahead of stock
price movements caused by mutual fund rebalancing, making a profit on foreknowledge of the large
institutional block orders. This results in profits transferred from investors to algorithmic traders.
One problem occurs when a large amount of money tracks the same index. According to theory, a
company should not be worth more when it is in an index. But due to supply and demand, a company
being added can have a demand shock, and a company being deleted can have a supply shock, and
this will change the price. This does not show up in tracking error since the index is also affected. A
fund may experience less impact by tracking a less popular index
Individual Stocks: A common stock is a security that represents ownership in a corporation. Holders
of common stock exercise control by electing a board of directors and voting on corporate policy.
Investing in individual common stocks provides us with more control of what you are invested in and
when that investment is made. Having the ability to decide when to buy or sell helps us time the
taking of gains or losses. Common stocks, however, bear a greater amount of risk when compared to
certificate of deposits, preferred stock and bonds. It is typically more difficult to achieve
diversification when investing in individual common stocks. Additionally, common stockholders are
on the bottom of the priority ladder for ownership structure; if a company goes bankrupt, the
common stockholders do not receive their money until the creditors and preferred shareholders
have received their respective share of the leftover assets.
Margin Transactions: Our firm may purchase securities for your portfolio with money borrowed
from your brokerage account. This allows you to purchase more stock than you would be able to with
your available cash and allows us to purchase securities without selling other holdings. Margin
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Wealth Management Partners, LLC
accounts and transactions are risky and not necessarily appropriate for every client. It should be
noted that our firm bills advisory fees on securities purchased on margin which creates a financial
incentive for us to utilize margin in client accounts.
The potential risks associated with these transactions are (1) You can lose more funds than are
deposited into the margin account; (2) the forced sale of securities or other assets in your account;
(3) the sale of securities or other assets without contacting you; (4) you may not be entitled to choose
which securities or other assets in your account(s) are liquidated or sold to meet a margin call; and
(5) custodians charge interest on margin balances which will reduce your returns over time.
Mutual Funds: A mutual fund is a company that pools money from many investors and invests that
money in a variety of differing security types based on the objectives of the fund. The portfolio of the
fund consists of the combined holdings it owns. Each share represents an investor’s proportionate
ownership of the fund’s holdings and the income those holdings generate. The price that investors
pay for mutual fund shares are the fund’s per share net asset value (“NAV”) plus any shareholder fees
that the fund imposes at the time of purchase (such as sales loads). Investors typically cannot
ascertain the exact make-up of a fund’s portfolio at any given time, nor can they directly influence
which securities the fund manager buys and sells or the timing of those trades. With an individual
stock, investors can obtain real-time (or close to real-time) pricing information with relative ease by
checking financial websites or by calling a broker or your investment adviser. Investors can also
monitor how a stock’s price changes from hour to hour—or even second to second. By contrast, with
a mutual fund, the price at which an investor purchases or redeems shares will typically depend on
the fund’s NAV, which is calculated daily after market close.
The benefits of investing through mutual funds include: (a) Mutual funds are professionally managed
by an investment adviser who researches, selects, and monitors the performance of the securities
purchased by the fund; (b) Mutual funds typically have the benefit of diversification, which is an
investing strategy that generally sums up as “Don’t put all your eggs in one basket.” Spreading
investments across a wide range of companies and industry sectors can help lower the risk if a
company or sector fails. Some investors find it easier to achieve diversification through ownership of
mutual funds rather than through ownership of individual stocks or bonds.; (c) Some mutual funds
accommodate investors who do not have a lot of money to invest by setting relatively low dollar
amounts for initial purchases, subsequent monthly purchases, or both.; and (d) At any time, mutual
fund investors can readily redeem their shares at the current NAV, less any fees and charges assessed
on redemption.
Mutual funds also have features that some investors might view as disadvantages: (a) Investors must
pay sales charges, annual fees, and other expenses regardless of how the fund performs. Depending
on the timing of their investment, investors may also have to pay taxes on any capital gains
distributions they receive. This includes instances where the fund performed poorly after purchasing
shares.; (b) Investors typically cannot ascertain the exact make-up of a fund’s portfolio at any given
time, nor can they directly influence which securities the fund manager buys and sells or the timing
of those trades.; and (c) With an individual stock, investors can obtain real-time (or close to real-
time) pricing information with relative ease by checking financial websites or by calling a broker or
your investment adviser. Investors can also monitor how a stock’s price changes from hour to hour—
or even second to second. By contrast, with a mutual fund, the price at which an investor purchases
or redeems shares will typically depend on the fund’s NAV, which the fund might not calculate until
many hours after the investor placed the order. In general, mutual funds must calculate their NAV at
least once every business day, typically after the major U.S. exchanges close.
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When investors buy and hold an individual stock or bond, the investor must pay income tax each year
on the dividends or interest the investor receives. However, the investor will not have to pay any
capital gains tax until the investor actually sells and makes a profit. Mutual funds, however, are
different. When an investor buys and holds mutual fund shares, the investor will owe income tax on
any ordinary dividends in the year the investor receives or reinvests them. Moreover, in addition to
owing taxes on any personal capital gains when the investor sells shares, the investor may have to
pay taxes each year on the fund’s capital gains. That is because the law requires mutual funds to
distribute capital gains to shareholders if they sell securities for a profit, and cannot use losses to
offset these gains.
Open-End Fund: An open-end fund is a type of mutual fund that does not have restrictions on the
amount of shares the fund can issue. The majority of mutual funds are open-end, providing investors
with a useful and convenient investing vehicle. When a fund's investment manager(s) determine that
a fund's total assets have become too large to effectively execute its stated objective, the fund will be
closed to new investors, and in extreme cases, will be closed to new investment by existing fund
investors. An open-end fund is a mutual fund issuing unlimited shares of investments in stocks
and/or bonds. Purchasing shares creates new ones, whereas selling shares takes them out of
circulation. Shares are bought and sold on demand at their net asset value (“NAV”), which is based
on the value of the fund’s underlying securities and is calculated at the end of the trading day. When
a large number of shares are redeemed, the fund may sell some of its investments to pay the investor.
An open-end fund has unlimited shares issued by the fund, do not trade on an exchange, are less
liquid, and are priced at the NAV at the trading day’s end. Open-end funds must maintain cash
reserves to meet redemptions. Open-end funds typically provide more security, whereas closed-end
funds often provide a bigger return.
There may be a percentage charge levied on the purchase of shares or units. Some of these fees are
called an initial charge (UK) or 'front-end load' (US). Some fees are charged by a fund on the sale of
these units, called a 'close-end load’ or ‘back-end load’ that may be waived after several years of
owning the fund. Some of the fees cover the cost of distributing the fund by paying commission to the
adviser or broker that arranged the purchase. These fund fees and expenses are commonly referred
to as 12b-1 fees in US. Not all funds have initial charges; if there are no such charges levied, the fund
is ‘no-load’ (US). These charges may represent profit for the fund manager or go back into the fund.
Fee Based Variable Annuities (“VA”): A variable annuity is a type of annuity contract that allows
for the accumulation of capital on a tax-deferred basis. As opposed to a fixed annuity that offers a
guaranteed interest rate and a minimum payment at annuitization, variable annuities offer investors
the opportunity to generate higher rates of returns by investing in equity and bond subaccounts. If a
variable annuity is annuitized for income, the income payments can vary based on the performance
of the subaccounts. Risks associated with VAs may include:
• Taxes and federal penalties for early withdrawal
• Surrender charges for early withdrawal can last for years
• Earnings taxed at ordinary income tax rates
• Mortality expense to compensate the insurance company for insurance risks
• Fees and expenses imposed for the subaccounts
• Other features with additional fees and charges
•
Investment losses
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Wealth Management Partners, LLC
Options: An option is a financial derivative that represents a contract sold by one party (the option
writer) to another party (the option holder, or option buyer). The contract offers the buyer the right,
but not the obligation, to buy or sell a security or other financial asset at an agreed-upon price (the
strike price) during a certain period of time or on a specific date (exercise date). Options are
extremely versatile securities. Traders use options to speculate, which is a relatively risky practice,
while hedgers use options to reduce the risk of holding an asset. In terms of speculation, option
buyers and writers have conflicting views regarding the outlook on the performance of a:
• Call Option: Call options give the option to buy at certain price, so the buyer would want the
stock to go up. Conversely, the option writer needs to provide the underlying shares in the
event that the stock's market price exceeds the strike due to the contractual obligation. An
option writer who sells a call option believes that the underlying stock's price will drop
relative to the option's strike price during the life of the option, as that is how he will reap
maximum profit. This is exactly the opposite outlook of the option buyer. The buyer believes
that the underlying stock will rise; if this happens, the buyer will be able to acquire the stock
for a lower price and then sell it for a profit. However, if the underlying stock does not close
above the strike price on the expiration date, the option buyer would lose the premium paid
for the call option.
• Put Option: Put options give the option to sell at a certain price, so the buyer would want the
stock to go down. The opposite is true for put option writers. For example, a put option buyer
is bearish on the underlying stock and believes its market price will fall below the specified
strike price on or before a specified date. On the other hand, an option writer who sells a put
option believes the underlying stock's price will increase about a specified price on or before
the expiration date. If the underlying stock's price closes above the specified strike price on
the expiration date, the put option writer's maximum profit is achieved. Conversely, a put
option holder would only benefit from a fall in the underlying stock's price below the strike
price. If the underlying stock's price falls below the strike price, the put option writer is
obligated to purchase shares of the underlying stock at the strike price.
The potential risks associated with these transactions are that (1) all options expire. The closer the
option gets to expiration, the quicker the premium in the option deteriorates; and (2) Prices can move
very quickly. Depending on factors such as time until expiration and the relationship of the stock
price to the option’s strike price, small movements in a stock can translate into big movements in the
underlying options.
Covered Calls: The risks associated with this type of strategy involve having the underlying stock
called away. Each contract has a strike price at which the writer of the contract agrees to allow the
purchaser call the stock away from the writer. This can create a taxable event whereby the writer of
the option is required to recognize a capital gain on the underlying security. Furthermore, the market
price could appreciate beyond the strike price, forcing the writer to sell their holdings below current
market value.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear. While the stock
market may increase and the account(s) could enjoy a gain, it is also possible that the stock market
may decrease, and the account(s) could suffer a loss. It is important that clients understand the risks
associated with investing in the stock market, and that their assets are appropriately diversified in
investments. Clients are encouraged to ask our firm any questions regarding their risk tolerance.
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Cash & Cash Equivalent Risk: Cash and cash equivalents generally refer to either United States
dollars or highly liquid short-term debt instruments such as, but not limited to, treasury bills, bank
CD’s and commercial papers. Generally, these assets are considered nonproductive and will be
exposed to inflation risk and considerable opportunity cost risk. Investments in cash and cash
equivalents will generally return less than the advisory fee charged by our firm.
Equity (Stock) Market Risk: Common stocks are susceptible to general stock market fluctuations
and, volatile increases and decreases in value as market confidence in and perceptions of their issuers
change. If you held common stock, or common stock equivalents, of any given issuer, you would
generally be exposed to greater risk than if you held preferred stocks and debt obligations of the
issuer.
Interest Rate Risk: Certain investments involve the payment of a fixed or variable rate of interest to
the investment holder. Once an investor has acquired or has acquired the rights to an investment that
pays a particular rate (fixed or variable) of interest, changes in overall interest rates in the market
will affect the value of the interest-paying investment(s) they hold. In general, changes in prevailing
interest rates in the market will have an inverse relationship to the value of existing, interest paying
investments. In other words, as interest rates move up, the value of an instrument paying a particular
rate (fixed or variable) of interest will go down. The reverse is generally true as well.
Market Timing Risk: Market timing can include high risk of loss since it looks at an aggregate market
versus a specific security. Timing risk explains the potential for missing out on beneficial movements
in price due to an error in timing. This could cause harm to the value of an investor's portfolio because
of purchasing too high or selling too low.
Strategy Risk: There is no guarantee that the investment strategies discussed herein will work under
all market conditions and each investor should evaluate his/her ability to maintain any investment
he/she is considering in light of his/her own investment time horizon. Investments are subject to
risk, including possible loss of principal.
Liquidity Risk: Certain assets may not be readily converted into cash or may have a very limited
market in which they trade. This can create a substantial delay in the receipt of proceeds from an
investment. Liquidity risk can also result in unfavorable pricing when exiting (i.e. not being able to
quickly get out of an investment before the price drops significantly) a particular investment and
therefore, can have a negative impact on investment returns.
Price Volatility of Digital Assets Risk: A principal risk in trading Digital Assets is the rapid
fluctuation of market price. The value of client portfolios relates in part to the value of the Digital
Assets held in the client portfolio and fluctuations in the price of Digital Assets could adversely affect
the value of a client’s portfolio. There is no guarantee that a client will be able to achieve a better than
average market price for Digital Assets or will purchase Digital Assets at the most favorable price
available. The price of Digital Assets achieved by a client may be affected generally by a wide variety
of complex factors such as supply and demand; availability and access to Digital Asset service
providers (such as payment processors), exchanges, miners or other Digital Asset users and market
participants; perceived or actual security vulnerability; and traditional risk factors including inflation
levels; fiscal policy; interest rates; and political, natural and economic events.
Digital Asset Service Providers Risk: Service providers that support Digital Assets and the Digital
Asset marketplace(s) may not be subject to the same regulatory and professional oversight as
traditional securities service providers. Further, there is no assurance that the availability of and
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Wealth Management Partners, LLC
access to virtual currency service providers will not be negatively affected by government regulation
or supply and demand of Digital Assets. Accordingly, companies or financial institutions that
currently support virtual currency may not do so in the future.
Custody of Digital Assets Risk: Under the Advisers Act, SEC registered investment advisers are
required to hold securities with “qualified custodians,” among other requirements. Certain Digital
Assets may be deemed to be securities. Many Digital Assets do not currently fall under the SEC
definition of security and therefore many of the companies providing Digital Assets custodial services
fall outside of the SEC’s definition of “qualified custodian”. Accordingly, clients seeking to purchase
actual digital coins/tokens/currencies may need to use nonqualified custodians to hold all or a
portion of their Digital Assets.
Government Oversight of Digital Assets Risk: Regulatory agencies and/or the constructs
responsible for oversight of Digital Assets or a Digital Asset network may not be fully developed and
subject to change. Regulators may adopt laws, regulations, policies or rules directly or indirectly
affecting Digital Assets their treatment, transacting, custody, and valuation.
Description of Material, Significant or Unusual Risks
Our firm generally invests client cash balances in money market funds, FDIC Insured Certificates of
Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, our
firm tries to achieve the highest return on client cash balances through relatively low-risk
conservative investments. In most cases, at least a partial cash balance will be maintained in a money
market account so that our firm may debit advisory fees for our services related to our Asset
Management service.
Item 9: Disciplinary Information
There are no legal or disciplinary events that are material to the evaluation of our advisory business
or the integrity of our management.
Item 10: Other Financial Industry Activities & Affiliations
Representatives of our firm are licensed insurance agents. While this activity may create a potential
conflict of interest, the representatives of our firm who are licensed insurance agents do not engage
in insurance-related transactions with advisory clients. The representatives of our firm who are
licensed insurance agents receive no compensation related to insurance sales in connection with the
advisory services they provide.
Item 11: Code of Ethics, Participation or Interest in
Client Transactions & Personal Trading
As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material
facts and to act solely in the best interest of each of our clients at all times. Our fiduciary duty is the
underlying principle for our firm’s Code of Ethics, which includes procedures for personal securities
transaction and insider trading. Our firm requires all representatives to conduct business with the
highest level of ethical standards and to comply with all federal and state securities laws at all times.
Upon employment with our firm, and at least annually thereafter, all representatives of our firm will
acknowledge receipt, understanding and compliance with our firm’s Code of Ethics. Our firm and
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Wealth Management Partners, LLC
representatives must conduct business in an honest, ethical, and fair manner and avoid all circumstances
that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure
is provided to give all clients a summary of our Code of Ethics. If a client or a potential client wishes to
review our Code of Ethics in its entirety, a copy will be provided promptly upon request.
Our firm recognizes that the personal investment transactions of our representatives demands the
application of a Code of Ethics with high standards and requires that all such transactions be carried out
in a way that does not endanger the interest of any client. At the same time, our firm also believes that if
investment goals are similar for clients and for our representatives, it is logical, and even desirable, that
there be common ownership of some securities.
In order to prevent conflicts of interest, our firm has established procedures for transactions effected by
our representatives for their personal accounts1. In order to monitor compliance with our personal
trading policy, our firm has pre-clearance requirements and a quarterly securities transaction reporting
system for all of our representatives.
Neither our firm nor a related person recommends, buys or sells for client accounts, securities in
which our firm or a related person has a material financial interest without prior disclosure to the
client.
Related persons of our firm may buy or sell securities and other investments that are also
recommended to clients. In order to minimize this conflict of interest, our related persons will place
client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which
is available upon request.
Likewise, related persons of our firm buy or sell securities for themselves at or about the same time they
buy or sell the same securities for client accounts. In order to minimize this conflict of interest, our
related persons will place client interests ahead of their own interests and adhere to our firm’s Code of
Ethics, a copy of which is available upon request. Further, our related persons will refrain from buying
or selling the same securities prior to buying or selling for our clients in the same day unless included in
a block trade.
Item 12: Brokerage Practices
Selecting a Brokerage Firm
While our firm does not maintain physical custody of client assets, we are deemed to have custody of
certain client assets if given the authority to withdraw assets from client accounts (see Item 15
Custody, below). Client assets must be maintained by a qualified custodian. Our firm seeks to
recommend a custodian who will hold client assets and execute transactions on terms that are overall
most advantageous when compared to other available providers and their services. The factors
considered, among others, are these:
• Timeliness of execution;
• Timeliness and accuracy of trade confirmations;
• Research services provided;
• Ability to provide investment ideas;
1 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse,
his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our
associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect
beneficial interest in.
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• Execution facilitation services provided;
• Record keeping services provided;
• Custody services provided;
• Frequency and correction of trading errors;
• Ability to access a variety of market venues;
• Expertise as it relates to specific securities;
• Financial condition;
• Business reputation; and
• Quality of services.
With this in consideration, our firm recommends the custodial services of Raymond James and
Associates, Inc. (“RJA”), member NYSE/SIPC. RJA is a corporate affiliate of Raymond James Financial,
Inc., member FINRA/SIPC. RJA is an independent [and unaffiliated] SEC-registered broker-dealer.
RJA offers services to independent investment advisers which includes custody of securities, trade
execution, clearance and settlement of transactions. RJA enables us to obtain many no-load mutual
funds without transaction charges and other no-load funds at nominal transaction charges. RJA does
not charge client accounts separately for custodial services. Client accounts will be charged transaction
fees, commissions or other fees on trades that are executed or settle into the client’s custodial account.
Transaction fees are negotiated with RJA and are generally discounted from customary retail
commission rates. This benefits clients because the overall fee paid is often lower than would be
otherwise.
Our firm utilizes RJA for custody of customer assets and execution of customer transactions. RJA acts
as the clearing agent in the execution of securities transactions placed through RJA. The firm, subject
to its best execution obligations, may trade outside of RJA. In the selection of broker-dealers, the firm
may consider all relevant factors, including the commission rate, the value of research provided,
execution capability, speed, efficiency, confidentiality, familiarity with potential purchasers and
sellers, financial responsibility, responsiveness, and other relevant factors. The firm has retained and
will compensate RJA and or RJA to provide various administrative services which include
determining the fair market value of assets held in the account at least quarterly and producing a
brokerage statement and performance reporting for client detailing account assets, account
transactions, receipt and disbursement of funds, interest and dividends received, and account gain
or loss by security as well as for the total account.
RJA may make certain research and brokerage services available at no additional cost to our firm.
Research products and services provided by RJA may include: research reports on recommendations or
other information about particular companies or industries; economic surveys, data and analyses;
financial publications; portfolio evaluation services; financial database software and services;
computerized news and pricing services; quotation equipment for use in running software used in
investment decision-making; and other products or services that provide lawful and appropriate
assistance by RJA to our firm in the performance of our investment decision-making responsibilities.
The aforementioned research and brokerage services qualify for the safe harbor exemption defined in
Section 28(e) of the Securities Exchange Act of 1934.
RJA does not make client brokerage commissions generated by client transactions available for our
firm’s use. The aforementioned research and brokerage services are used by our firm to manage
accounts for which our firm has investment discretion. Without this arrangement, our firm might be
compelled to purchase the same or similar services at our own expense.
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As part of our fiduciary duty to our clients, our firm will endeavor at all times to put the interests of
our clients first. Clients should be aware, however, that the receipt of economic benefits by our firm
or our related persons creates a potential conflict of interest and may indirectly influence our firm’s
choice of RJA as a custodial recommendation. Our firm examined this potential conflict of interest when
our firm chose to recommend RJA and have determined that the recommendation is in the best interest
of our firm’s clients and satisfies our fiduciary obligations, including our duty to seek best execution.
Our clients may pay a transaction fee or commission to RJA that is higher than another qualified
broker dealer might charge to effect the same transaction where our firm determines in good faith
that the commission is reasonable in relation to the value of the brokerage and research services
provided to the client as a whole.
In seeking best execution, the determinative factor is not the lowest possible cost, but whether the
transaction represents the best qualitative execution, taking into consideration the full range of a
broker-dealer’s services, including the value of research provided, execution capability, commission
rates, and responsiveness. Although our firm will seek competitive rates, to the benefit of all clients,
our firm may not necessarily obtain the lowest possible commission rates for specific client account
transactions.
Soft Dollars
Our firm does not receive soft dollars in excess of what is allowed by Section 28(e) of the Securities
Exchange Act of 1934. The safe harbor research products and services obtained by our firm will
generally be used to service all of our clients but not necessarily all at any one particular time.
Client Brokerage Commissions
RJA does not make client brokerage commissions generated by client transactions available for our
firm’s use.
Client Transactions in Return for Soft Dollars
Our firm does not direct client transactions to a particular broker-dealer in return for soft dollar
benefits.
Brokerage for Client Referrals
Our firm does not receive brokerage for client referrals.
Directed Brokerage
Neither our firm nor any of our firm’s representatives have discretionary authority in making the
determination of the brokers-dealers and/or custodians with whom orders for the purchase or sale
of securities are placed for execution, and the commission rates at which such securities transactions
are effected. Our firm routinely requests that clients direct us to execute through a specified broker-
dealer. Our firm recommends the use of RJA. Each client will be required to establish their account(s)
with RJA if not already done. Please note that not all advisers have this requirement.
Special Considerations for ERISA Clients
A retirement or ERISA plan client may direct all or part of portfolio transactions for its account
through a specific broker or dealer in order to obtain goods or services on behalf of the plan. Such
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direction is permitted provided that the goods and services provided are reasonable expenses of the
plan incurred in the ordinary course of its business for which it otherwise would be obligated and
empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services
purchased are not for the exclusive benefit of the plan. Consequently, our firm will request that plan
sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will
be for the exclusive benefit of the plan.
Client-Directed Brokerage
Our firm does not allow client-directed brokerage outside our recommendations.
Aggregation of Purchase or Sale
Our firm provides investment management services for various clients. There are occasions on which
portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same
security for numerous accounts served by our firm, which involve accounts with similar investment
objectives. Although such concurrent authorizations potentially could be either advantageous or
disadvantageous to any one or more particular accounts, they are affected only when our firm believes
that to do so will be in the best interest of the effected accounts. When such concurrent authorizations
occur, the objective is to allocate the executions in a manner which is deemed equitable to the accounts
involved. In any given situation, our firm attempts to allocate trade executions in the most equitable
manner possible, taking into consideration client objectives, current asset allocation and availability of
funds using price averaging, proration and consistently non-arbitrary methods of allocation.
Item 13: Review of Accounts
Our management personnel or financial advisors review accounts on at least an annual basis for our
Asset Management clients. The nature of these reviews is to learn whether client accounts are in line
with their investment objectives, appropriately positioned based on market conditions, and
investment policies, if applicable. Our firm does not provide written reports to clients, unless asked
to do so. Verbal reports to clients take place on at least an annual basis when our Asset Management
clients are contacted.
Our firm may review client accounts more frequently than described above. Among the factors which
may trigger an off-cycle review are major market or economic events, the client’s life events, requests
by the client, etc.
Financial Planning clients do not receive reviews of their written plans unless they take action to
schedule a financial consultation with us. Our firm does not provide ongoing services to financial
planning clients, but are willing to meet with such clients upon their request to discuss updates to
their plans, changes in their circumstances, etc. Financial Planning clients do not receive written or
verbal updated reports regarding their financial plans unless they separately engage our firm for a
post-financial plan meeting or update to their initial written financial plan.
Retirement Plan Consulting clients receive reviews of their retirement plans for the duration of the
service. Our firm also provides ongoing services where clients are met with upon their request to
discuss updates to their plans, changes in their circumstances, etc. Retirement Plan Consulting clients
do not receive written or verbal updated reports regarding their plans unless they choose to engage
our firm for ongoing services.
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Item 14: Client Referrals & Other Compensation
Raymond James and Associates, Inc.
Our firm recommends that clients establish brokerage accounts with RJA. RJA provides us with access
to its institutional trading and operations services, which typically are not available to RJA retail
customers. These services are generally available, without cost, to financial advisory firms who
maintain a minimum threshold of client assets with RJA. RJA is a full-service registered broker-dealer
and registered investment adviser. Our firm has no formal relationship with RJA for client referrals
and receives no compensation from RJA (other than the services and arrangements described herein)
for accounts opened by firm clients. On an informal basis, RJA occasionally may make referrals to our
firm as a courtesy or accommodation. Nothing of value, monetary or otherwise, is given, paid, or
received in exchange for such referrals.
Services provided by RJA to financial advisory firms include research (including mutual fund
research, third-party research, and RJA proprietary research), brokerage, custody, and access to
mutual funds and other investments that are available only to institutional investors or would
require a significantly higher minimum initial investment. In addition, RJA makes available software
and other technologies that provide access to client account data (such as trade confirmations and
account statements), facilitate trade execution, provide research, pricing information, quotation
services, and other market data, assist with contact management, facilitate payment of fees to our
firm from client accounts, assist with performance reporting, facilitate trade allocation, and assist
with back-office support, record-keeping, and client reporting. RJA also provides access to financial
planning software, practice management consulting support, best execution assistance, consolidated
statements assistance, educational and industry conferences, marketing and educational materials,
technological and information technology support, and RJA corporate discounts. Many of these
services may be used to service all or a substantial number of RWIs' accounts, including accounts not
maintained at RJA.
Referral Fees
In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm does not provide
cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or
endorsements (which include client referrals).
Item 15: Custody
Deduction of Advisory Fees:
While our firm does not maintain physical custody of client assets (which are maintained by a
qualified custodian, as discussed above), we are deemed to have custody of certain client assets if
given the authority to withdraw assets from client accounts, as further described below under “Third
Party Money Movement.” All our clients receive account statements directly from their qualified
custodian(s) at least quarterly upon opening of an account. We urge our clients to carefully review
these statements. Additionally, if our firm decides to send its own account statements to clients, such
statements will include a legend that recommends the client compare the account statements
received from the qualified custodian with those received from our firm. Clients are encouraged to
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Wealth Management Partners, LLC
raise any questions with us about the custody, safety or security of their assets and our custodial
recommendations.
Third Party Money Movement:
On February 21, 2017, the SEC issued a no‐action letter (“Letter”) with respect to Rule 206(4)‐2
(“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided
guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client
funds to a third party under a standing letter of authorization (“SLOA”) is deemed to have custody.
As such, our firm has adopted the following safeguards in conjunction with our custodian:
• The client provides an instruction to the qualified custodian, in writing, that includes the
client’s signature, the third party’s name, and either the third party’s address or the third
party’s account number at a custodian to which the transfer should be directed.
• The client authorizes the investment adviser, in writing, either on the qualified custodian’s
form or separately, to direct transfers to the third party either on a specified schedule or from
time to time.
• The client’s qualified custodian performs appropriate verification of the instruction, such as
a signature review or other method to verify the client’s authorization and provides a transfer
of funds notice to the client promptly after each transfer.
• The client has the ability to terminate or change the instruction to the client’s qualified
custodian.
• The investment adviser has no authority or ability to designate or change the identity of the
third party, the address, or any other information about the third party contained in the
client’s instruction.
• The investment adviser maintains records showing that the third party is not a related party
of the investment adviser or located at the same address as the investment adviser.
• The client’s qualified custodian sends the client, in writing, an initial notice confirming the
instruction and an annual notice reconfirming the instruction.
Item 16: Investment Discretion
Clients have the option of providing our firm with investment discretion on their behalf, pursuant to
an executed investment advisory client agreement. By granting investment discretion, our firm is
authorized to execute securities transactions, determine which securities are bought and sold, and
the total amount to be bought and sold. Should clients grant our firm non-discretionary authority,
our firm would be required to obtain the client’s permission prior to effecting securities transactions.
Limitations may be imposed by the client in the form of specific constraints on any of these areas of
discretion with our firm’s written acknowledgement.
Item 17: Voting Client Securities
Our firm does not accept the proxy authority to vote client securities. Clients will receive proxies or
other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent
to our firm, our firm will forward them to the appropriate client and ask the party who sent them to
mail them directly to the client in the future. Clients may call, write or email us to discuss questions
they may have about particular proxy votes or other solicitations.
Item 18: Financial Information
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Our firm is not required to provide financial information in this Brochure because:
• Our firm does not require the prepayment of more than $1,200 in fees when services cannot
be rendered within 6 months.
• Our firm does not take custody of client funds or securities.
• Our firm does not have a financial condition or commitment that impairs our ability to meet
contractual and fiduciary obligations to clients.
• Our firm has never been the subject of a bankruptcy proceeding.
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