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Wealthcare Capital Partners LLC
Form ADV Part 2A – Disclosure Brochure
Wealthcare Capital Partners LLC
1065 Andrew Drive
West Chester, PA 19380
Phone: (804) 644-4711
http://www.wealthcaregdx.com/
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and
business practices of Wealthcare Capital Partners LLC (“WCP” or the “Advisor”). If you have any
questions about the contents of this Disclosure Brochure, please contact the Advisor at (804) 644-4711 or
by email at compliance@wealthcarecapital.com.
WCP is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”).
The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state
securities authority. Registration of an investment advisor does not imply any specific level of skill or
training. This Disclosure Brochure provides information about WCP to assist you in determining
whether to retain the Advisor.
Additional information about WCP and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 330300.
Date: October 17, 2025
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Item 2 – Material Changes
Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure
Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an
Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information
about Advisory Persons of WCP.
WCP believes that communication and transparency are the foundation of its relationship with clients
and will continually strive to provide you with complete and accurate information at all times. WCP
encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions
you may have with the Advisor.
Material Changes
The following material change has been made to this Disclosure Brochure since the last annual amendment
filing on 3/24/2025:
• The Advisor has amended Item 4 to reflect a new principal owner of the firm. Please see Item 4 for
more details.
• The Advisor has amended Item 12 to add disclosure surrounding certain instances where the Advisor
engages in trade away transactions. Please see Item 12 for further details.
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business
practices, changes in regulations or routine annual updates as required by the securities regulators. This
complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and
if a material change occurs.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or
CRD# 330300. You may also request a copy of this Disclosure Brochure at any time, by contacting the
Advisor at (804) 644-4711 or by email at compliance@wealthcarecapital.com.
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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 and Compensation ................................................................................................... 9
Item 6 – Performance‐Based Fees and Side‐By‐Side Management ................................................ 12
Item 7 – Types of Clients ............................................................................................................. 12
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss........................................... 12
Item 9 – Disciplinary Information ................................................................................................ 16
Item 10 ‐ Other Financial Industry Activities and Affiliations ......................................................... 16
Item 11 ‐ Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...... 18
Item 12 ‐ Brokerage Practices ...................................................................................................... 18
Item 13 – Review of Accounts ..................................................................................................... 20
Item 14 ‐ Client Referrals and Other Compensation ...................................................................... 20
Item 15 ‐ Custody ....................................................................................................................... 22
Item 16 ‐ Investment Discretion .................................................................................................. 23
Item 17 ‐ Voting Client Securities ................................................................................................. 23
Item 18 ‐ Financial Information ................................................................................................... 23
Form ADV Part 2A – Appendix 1 .................................................................................................. 24
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Item 4 – Advisory Business
A. FIRM INFORMATION
Wealthcare Capital Partners LLC (“WCP” or the “Advisor”) is a registered investment advisor with the U.S.
Securities and Exchange Commission (“SEC”). WCP is organized as a limited liability company (“LLC”)
under the laws of the state of Delaware. WCP was founded in February 2024. WCP is 100% owned by
Wealthcare Parent Holdings LLC (which is principally owned by Sammons Financial Group Wealth
Management Holdings, LLC). WCP is operated by Matthew T. Regan (President), Ronald E. Madey (Chief
Investment Officer), James J. Krause (Chief Compliance Officer) and Justin DuBrueler (Chief Financial
Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and
the advisory services provided by WCP. For additional information about our ownership structure, please see
our Form ADV Part 1A, Schedules A and B.
WCP offers services through its Advisory Persons. Advisory Persons may have their own legal business
entities whose trade names and logos are used for marketing purposes and may appear on marketing
materials and/or Client statements. The Client should understand that the businesses are legal entities of the
Advisory Person and not of WCP. The Advisory Persons are under the supervision of WCP, and the
advisory services of Advisory Persons are provided through WCP. Advisory Persons provide services
and charge fees based in accordance with the descriptions detailed in this Disclosure Brochure and the terms
of the Client agreement. However, the exact service and fees charged to the Client are dependent upon the
Advisory Person that is working with the Client. Advisory Persons are appropriately licensed and
authorized to provide advisory services on behalf of WCP.
B. ADVISORY SERVICES OFFERED
WCP offers investment advisory services to individuals, high net worth individuals, trusts, estates,
retirement plans, charitable organizations and other businesses (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a
fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to
mitigate potential conflicts of interest. WCP’s fiduciary commitment is further described in the Advisor’s
Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics,
Participation or Interest in Client Transactions and Personal Trading.
WCP's mission is to provide sound customized financial advice in the best interest of the Client. For many
Clients, the Advisor utilizes a financial advising discipline focused on helping Clients live the one life they
have the best way they can. This goals-based financial advisory experience is based upon several U.S. and
International patents of Wealthcare Capital Management LLC (“WCM”), a registered investment adviser
with the SEC that is affiliated through common ownership. WCM is the first company to provide U.S. and
Canadian professional financial advisers and financial institutions with a web‐based, goals-based wealth
management software product, and also the first to do so with an integrated simulated market return
analysis. Depending on their objectives and needs, some Clients have their needs met by WCP, and some
may have third-party managers, as determined by their individual financial situation and investment
objectives.
Wealth Management Services
WCP provides tailored investment advisory solutions to its Clients. This is achieved through personal Client
contact and interaction while providing discretionary or non-discretionary investment management over Client
portfolios and a broad range of comprehensive financial planning. Investment Management and Financial
Planning services are also offered as standalone services. These services are described below.
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Investment Management Services
WCP provides customized investment advisory solutions for its Clients. This is achieved through
continuous personal Client contact and interaction while providing discretionary and/or non-discretionary
investment management and related advisory services. WCP works with each investment management
Client to identify their investment goals and objectives as well as risk tolerance and financial situation in
order to create an investment strategy. WCP will then design a portfolio with its internal investment
strategies, or select from its available models.
WCP will select its portfolios to meet the needs of each Client. Portfolios may be customized to each
Client and may include, but are not limited to, mutual funds and exchange-traded funds (“ETFs”),
individual stocks, bonds and alternative investments. The Advisor may retain other types of investments
from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other
reasons as identified between the Advisor and the Client.
Alternative Investments – As noted above, certain models may include the use of alternative
investments when deemed appropriate and in the Client’s best interest. Investing directly in hedge funds,
private equity, and/or real estate funds can be difficult for many individuals given due diligence
requirements, portfolio construction complexity, large minimum investments which limit an individual’s
ability to diversify his/her investments, restrictive liquidity terms, and other access
limitations. To help
offset these potential barriers to entry into these types of investment opportunities, WCP engages with
alternative investment platforms to: (i) provide due diligence resources and services; (ii) facilitate access
to managers at lower minimums; and (iii) structure multi-manager private investment solutions that allow
WCP qualified clients to access relatively diversified and carefully constructed pools of institutional-
quality alternative investments, including hedge funds and private equity and real asset funds, managed by
unaffiliated investment advisers. WCP structures these opportunities by leveraging third-party platform
resources (investment research, risk management, legal and operational due diligence) to supplement its
in- house resources.
in a
Through these third-party platforms, WCP can offer single strategy and multi-strategy investments
private fund construct, a private fund-of-funds construct, or a custom private multi-strategy portfolio
(e.g..: arbitrage; credit; equity long/short; global macro; event driven; private equity; and real estate) using
private limited liability companies or limited partnerships that are exempt from registration under federal
securities regulations, including the Investment Company Act of 1940 (the “Investment Company Act”)
and the Securities Act of 1933 (the “Securities Act”).Investment in these alternative investments is limited
to persons who are “accredited investors” as defined under the Securities Act and, depending on the fund,
the Investment Company Act. Clients should refer to the private
“qualified purchasers” as defined in
placement memoranda and class supplement documents, as well as the underlying funds’ private placement
memoranda, for a more complete discussion of these investments.
Delaware Statutory Trusts (“DSTs”) – When appropriate Advisors of WCP will recommend to accredited
investor Client’s investment in DSTs. Investments in DSTs are billed as assets undermanagement and follow
the billing schedule identified in Item 5 and agreed upon by Clients in their advisory agreement.
WCP’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate
positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. WCP will construct, implement and monitor the portfolio to ensure it meets the goals,
objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity
to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject
to acceptance by the Advisor. WCP evaluates and selects investments for inclusion in Client portfolios
only after applying its internal due diligence process. WCP may recommend, on occasion, redistributing
investment allocations to diversify the portfolio. WCP may recommend selling positions for reasons that
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include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a
specific security or class of securities, overvaluation or over-weighting of the position[s] in the portfolio,
change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable
for the Client’s risk tolerance.
At no time will WCP accept or maintain custody of a Client’s funds or securities, except for the limited
authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated
account[s] at the Custodian, pursuant to the terms of the agreement. Please see Item 12 – Brokerage
Practices.
Use of Affiliated Manager – Under the discretionary authority granted to WCP, Clients may be referred to
utilize the portfolio management services of WCM for all or a portion of the Client’s portfolio. Please see
Item 10 for additional information. The Client will be provided with WCM’s Form ADV Part 2A (or a
brochure that makes the appropriate disclosures) of those parties.
Selection of Other Advisor – Additionally, WCP may recommend Assetmark, Inc. (“AssetMark”) for
investment advisory services. WCP will receive a portion of the investment advisory fee for the
solicitation and referral of the Client to AssetMark, and may assist the Client in completing their Client
questionnaire and account opening paperwork. WCP may also assist in the development of the initial
policy recommendations and managing the ongoing Client relationship.
Use of Independent Managers and Managed Account Programs - WCP may also recommend to Clients
that all or a portion of their investment portfolio be implemented by utilizing one or more unaffiliated
money managers/investment platforms (collectively “Independent Managers”), which are available through
the recommended Custodians. The Advisor may also utilize an unaffiliated money manager participating in
a turnkey asset management program (“TAMP”).
The Client may be required to enter into a separate agreement with the Independent Manager[s]. In these
instances, WCP serves as the Client’s primary advisor and relationship manager. However, the
Independent Manager[s] will assume discretionary authority for the day-to-day investment management of
those assets placed in their control. WCP will assist and advise the Client in establishing investment
objectives for their account[s], the selection of the Independent Manager[s], and defining any restrictions
on the account[s]. WCP will continue to provide oversight of the Client’s account[s] and ongoing
monitoring of the activities of these unaffiliated parties. The Independent Manager[s] will implement the
selected investment strategies based on their investment mandates. The Client may be able to impose
reasonable investment restrictions on these accounts, subject to the acceptance of these third parties.
For Client’s whose assets are placed in a TAMP, the Client will enter into a program and investment
advisory agreement with the TAMP (the “Program Sponsor”) and the participating money manager[s]. The
Advisor will assist and advise the Client in establishing investment objectives for the account[s], the
selection of the money manager[s], and defining any restrictions on the account[s] and determining any
changes to portfolio strategy. WCP will provide ongoing oversight of the Client accounts and the activities of
the unaffiliated money managers selected to manage the Client’s assets. These money managers will
develop an investment strategy to meet those objectives by identifying appropriate investments and
monitoring such investments. In consideration for such services, the Program Sponsor will charge a
program fee that includes the investment advisory fee of the money managers, the administration of the
program and trading, clearance and settlement costs. The Program Sponsor will add WCP’s investment
advisory fee (described below in Item 5) and will deduct the overall fee from the Client’s account[s],
pursuant to the agreement between the Program Sponsor and the Client.
The Client, prior to entering into an agreement with an Independent Manager and/or Program Sponsor, will
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be provided with the Form ADV Part 2A (or a brochure that makes the appropriate disclosures) of those
parties. WCP does not receive any compensation from these Independent Managers or Investment
Platforms, other than WCP’s investment advisory fee, as described in Item 5.
Non-Purpose Loans - The Advisor introduces certain Clients to a non-purpose loan program made available
through a Custodian’s banking partner affiliate (“Lending Program”). In such instances, the Client’s assets
in their account[s] at the Custodian will be utilized as collateral for a non-purpose loan. The
recommendation of a Lending Program presents a conflict of interest as the Advisor will continue to receive
investment advisory fees for managing the collateralized assets in the Client’s account[s]. Clients are not
obligated to engage the Advisor for the Lending Program. For additional information related to the risks
involved non-purpose loans and lines of credit, please see Item 8 - Methods of Analysis, Investment
Strategies and Risk of Loss.
Financial Planning and Consulting Services
WCP will typically provide a variety of financial planning and consulting services to individuals and
families, either as a component of wealth management services or pursuant to a written financial planning or
consulting agreement. Services are offered in several areas of a Client’s financial situation, depending on
their goals and objectives. Generally, such financial planning services involve preparing a formal financial
plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This
planning or consulting may encompass one or more areas of need, including but not limited to, investment
planning, retirement planning, personal savings, education savings, insurance needs and other areas of a
Client’s financial situation.
A financial plan developed for or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs.
WCP may also refer Clients to an accountant, attorney or another specialist, as appropriate for their unique
situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s
financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor
may not provide a written summary. Plans or consultations are typically completed within six months of
contract date, assuming all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a potential conflict between the interests of the
Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients
engage the Advisor for investment management services or to increase the level of investment assets with
the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated
to implement any recommendations made by the Advisor or maintain an ongoing relationship with the
Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under
no obligation to implement the transaction through the Advisor.
Retirement Plan Advisory Services
WCP provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the
company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the
Plan Sponsor in meeting its fiduciary obligations to the Plan. Each engagement is customized to the needs
of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Due Diligence and Oversight Services (ERISA 3(21))
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• Investment Management Services (ERISA 3(38))
• Ongoing Investment Recommendation and Assistance
These services are provided by WCP serving in the capacity as a fiduciary under the Employee Retirement
Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the
Plan Sponsor is provided with a written description of WCP’s fiduciary status, the specific services to be
rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement.
C. CLIENT ACCOUNT MANAGEMENT
Prior to engaging WCP to provide investment advisory services, each Client is required to enter into one or
more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the
Advisor and the Client. These services may include:
▪ Establishing an Investment Strategy – WCP, in connection with the Client, will develop a strategy
that seeks to achieve the Client’s goals and objectives.
▪ Asset Allocation – WCP will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation and tolerance for risk for each Client.
▪ Portfolio Construction – WCP will develop a portfolio for the Client that is intended to meet the stated
▪
goals and objectives of the Client.
Investment Management and Supervision – WCP will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. WRAP FEE PROGRAM
For some Clients, WCP may include the securities transaction fees together with investment advisory fees to
provide the Client with a single, bundled fee structure. This combination of fees is typically referred to as
a “Wrap Fee Program”. WCP customizes its investment management services for Clients. This Wrap Fee
Program Brochure is included as Appendix 1 to this Disclosure Brochure solely to discuss the fees and
potential conflicts associated with a bundled fee. Depending on the level of trading required for the Client’s
account[s] in a particular year, the Client may pay more or less in total fees than if the Client paid its own
transaction fees. Please see Appendix 1 – Wrap Fee Program Brochure, which is always included with this
Disclosure Brochure.
Additionally, WCP may recommend the investment strategies of various third-party advisors (“TPAs”) to
its Clients. The TPA selected may offer a model portfolio that is available as part of a wrap fee program. In
such instances, the wrap fee agreement is inclusive of the TPA’s fee and custody fees. If a TPA’s wrap fee
program is selected for a Client’s account, the wrap fee program brochure for the TPA’s program will be
presented to the Client. The wrap fee program brochure will describe the investment strategy as well as the
fees and services performed by the program manager.
In some instances, WCP Advisory Persons have Client relationships which are held at wrap fee sponsors,
such as Lockwood, in which a TPA is managing the Client assets. Those relationships generally predate the
IAR’s affiliation with WCP and remain as is, if it is deemed to be in the Client’s best interests.
E. ASSETS UNDER MANAGEMENT
As of December 31, 2024, WCP manages $330,922,755 in Client assets, all of which is managed on a
discretionary basis. Clients may request more current information at any time by contacting the Advisor.
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Item 5 – Fees and Compensation
A. FEES FOR ADVISORY SERVICES
Wealth Management/Investment Management Services (“Management Services”)
Management Service fees (“Management fees”) are generally paid quarterly, in advance of each calendar
quarter, pursuant to
the terms of the Management Services agreement (“management agreement”).
Management fees are based on the market value of assets under management at the end of the prior quarter.
Management fees are at a rate of up to 1.85% based on several factors including the types of investments,
size of the Client relationship, reporting requirements, portfolio restrictions and other factors. Fees may be
negotiable at the sole discretion of the Advisor. WCP may offer discounted rates to its employees and
their families as well as to institutional and very high net worth Clients with substantial account balances.
Additionally, certain Clients may have their fees billed using a different fee methodology, pursuant to
the management agreement.
The management fee in the first quarter of service is prorated from the inception date of the account[s]
to the end of the first quarter. All securities held in accounts managed by WCP will be independently
valued by the Custodian. WCP will conduct periodic reviews of the Custodian’s valuations to ensure
accurate billing.
Use of Affiliated Manager – For Clients referred to WCM, WCP will deduct the advisory fee from the
Client account and a portion of the fee will be provided to WCM.
Use of Independent Managers – For Client account[s] implemented through an Independent Manager
and/or Program Sponsor, the Client’s overall fees will include WCP’s investment advisory fee (as noted
above) plus advisory fees and/or platform fees charged by the Independent Manager[s] and/or Program
Sponsor, as applicable. The Independent Manager and/or Program Sponsor may assume responsibility for
calculating the Client’s fees and deduct all fees from the Client’s account[s]. In such instances, WCP’s fee
will be included and will not charge its fee separately on those assets.
Financial Planning and Consulting Services
Project-based financial planning and consulting fees are on an hourly or fixed fee basis. Hourly fees are at
a rate ranging from $150 to $400 per hour. Fixed fee engagements are offered based on the expected effort
and duration at the Advisor’s hourly rate. An estimate for total hours and/or costs will be provided to
the Client in advance of engaging for these services. Ongoing financial planning and consulting fees
range up to $15,000 which is invoiced in advance of each quarter. Ongoing consulting fees may also be
based on the value of the assets being consulted on at the end of the previous calendar quarter. Ongoing
asset-based consulting fees range up to 1% of the assets being consulted on, and are paid quarterly in advance
of each calendar quarter, pursuant to the terms of the consulting agreement. Fees may be negotiable
depending on the nature and complexity of each Client’s circumstances and the experience of the personnel
financial planning fee included with the overall investment
providing services. Clients may have their
management fee as described above.
Retirement Plan Advisory Services
Fees for retirement plan advisory services are charged an annual asset-based fee of up to 1.25% pursuant
to the terms of the retirement plan advisory agreement. Fees may be negotiable depending on the size and
complexity of the Plan as well as the services to be provided.
B. FEE BILLING
Management Services
Generally, management fees are calculated by the Custodian and deducted from the Client’s account[s].
from the Client’s
The Client shall instruct the Custodian to automatically deduct the management fee
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account[s] for each quarter and pay the management fee[s] to the Advisor. The Custodian will utilize the
fee rate, as defined in the custodial paperwork, to indicate the fee to be deducted from the Client’s
account[s] at the respective quarter-end date. In such circumstances, fees may be prorated for capital
contributions or withdrawals made into a managed account following the initial establishment of a
managed account during the applicable quarter.
In certain instances, management fees will be calculated by the Advisor or its delegate and deducted
from the Client’s account[s] at the Custodian. The Advisor or its delegate shall send an invoice to the
Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the respective
quarter-end date. In such circumstances, fees will not be prorated for capital contributions or
withdrawals made into a managed account following the initial establishment of a managed account
during the applicable quarter.
When calculated by Advisor, the amount due is calculated by applying the quarterly rate (annual rate
divided by 4) to the total Client assets under management with WCP at the end of the previous quarter. It is
the responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s quarterly
statement as the Custodian and Advisor do not assume this responsibility. Clients provide written
authorization permitting the Custodian to pay WCP by direct deduction from their account[s] held by the
Custodian as part of the management agreement and separate account forms provided by the Custodian.
Use of Independent Managers – Client account[s] implemented through Independent Managers and/or
Program Sponsors will either be deducted from the Client’s account[s] at the Custodian and a portion of
the investment advisory fee will be provided to the Independent Manager, or billed in accordance to the
separate agreement[s] with the Program Sponsors. In such instances, the Program Sponsor will typically
add WCP’s investment advisory fee and deduct the overall fee from the Client’s account[s]. In such
circumstances, fees may be prorated for capital contributions or withdrawals made into a managed account
following the initial establishment of a managed account during the applicable quarter.
Financial Planning Services
Project-based financial planning fees may be invoiced up to fifty percent (50%) upon execution of the
financial planning agreement, with the balance due upon receipt of the agreed upon deliverable[s]. Ongoing
financial planning fees are invoiced quarterly, in advance of each quarter. Clients may also provide written
authorization permitting the fees to be paid directly from Client accounts.
Retirement Plan Advisory Services
Fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on
the terms of the retirement plan advisory agreement.
C. OTHER FEES AND EXPENSES
Clients may incur certain fees or charges imposed by third parties in connection with investments made on
behalf of the Client’s account[s]. WCP may include securities transactions costs as part of its overall
investment advisory fee through the WCP Wrap Fee Program. Securities transaction fees for Client-
directed trades may be charged back to the Client. Please see Item 4 above as well as Appendix 1 – Wrap
Fee Program Brochure.
In addition, all fees paid to WCP for investment advisory services or part of the WCP Wrap Fee Program are
separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if
applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will
generally be used to pay management fees for the funds, other fund expenses, account administration (e.g.,
custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest
in these products directly, without the services of WCP, but would not receive the services provided by
WCP which are designed, among other things, to assist the Client in determining which products or
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services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client
should review both the fees charged by the fund[s] and the fees charged by WCP to fully understand the
total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information.
D. ADVANCE PAYMENT OF FEES AND TERMINATION
Management Services
WCP is generally compensated for its services in advance of the quarter in which management services are
rendered. Either party may terminate the management agreement, at any time, by providing advance
written notice to the other party. Upon termination, the Advisor will refund any unearned, prepaid
management fees from the effective date of termination to the end of the quarter. The Client’s
management agreement with the Advisor is non-transferable without the Client’s prior consent.
Use of Independent Managers - In the event that a Client should wish to terminate their relationship with
an Independent Manager, the Advisor will generally remove the assets from the Independent Manager and
either place the assets with a new Independent Manager or mange the assets directly. In certain instances,
the terms for termination will be set forth in the respective agreements between the Client and the Program
Sponsor. WCP will assist the Client with the termination and transition as appropriate.
Financial Planning Services
WCP may be partially compensated for its financial planning services at the start of the engagement.
Either party may terminate the financial planning agreement, at any time, by providing written notice to the
other party. Upon termination, the Client shall be billed for actual hours logged on the planning project
times the agreed upon hourly rate or the percentage completion for a fixed fee engagement. Any unearned,
prepaid fees will be promptly refunded. The Client’s financial planning agreement with the Advisor is non-
transferable without the Client’s prior consent.
Retirement Plan Advisory Services
WCP may be compensated for its services in advance, before retirement plan advisory services are
rendered. Either party may terminate their retirement plan advisory agreement, at any time, by providing
advance written notice to the other party. Upon termination, the Client shall be responsible for fees up to
and including the effective date of termination. Additionally, the Advisor will refund any unearned, prepaid
investment advisory fees from the effective date of termination to the end of the billing period. The Client’s
retirement plan advisory agreement with the Advisor is non-transferable without the Client’s prior consent.
E. COMPENSATION FOR SALE OF SECURITIES
Broker-Dealer Affiliation
Certain Advisory Persons of WCP are also registered representatives of M.S. Howells & Co. (“M.S.
Howells”), or Arkadios Capital LLC (“Arkadios”), securities broker-dealers, and members of the Financial
Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). In
one’s separate capacity as a registered representative of M.S. Howells, or Arkadios an Advisory Person
implements securities transactions under the broker-dealer and not through WCP. In such instances, an
Advisory Person will receive commission-based compensation in connection with the purchase and sale of
securities, including 12b-1 fees for the sale of investment company products. Compensation earned by an
Advisory Person in one’s capacity as a registered representative is separate and in addition to WCP’s
advisory fees. This practice presents a conflict of interest because Advisory Persons who are registered
representatives have an incentive to effect securities transactions for the purpose of generating commissions
rather than solely based on the Client. WCP mitigates this conflict in two ways. First, Clients always have
the right to choose whether or not to purchase securities products through an Advisory Person. Second,
WCP will not charge an ongoing investment advisory fee on any assets implemented in the separate
capacity of an Advisory Person. Please see Item 10 – Other Financial Industry Activities and Affiliations.
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Insurance Agency Affiliation
Additionally, certain Advisory Persons are also licensed as independent insurance professionals. These
persons will earn commission-based compensation for selling insurance products, including insurance
products they sell to Clients. Insurance commissions earned by these persons are separate and in addition
to advisory fees. This practice presents a conflict of interest because Advisory Persons who are also
insurance agents have an incentive to recommend insurance products to Clients for the purpose of
generating commissions rather than solely based on a Client’s needs. However, to mitigate this conflict,
Clients always have the right to choose whether or not to purchase insurance products through any person
affiliated with WCP. Please see Item 10 – Other Financial Industry Activities and Affiliations.
Item 6 – Performance‐Based Fees and Side‐By‐Side Management
WCP does not charge performance-based fees for its investment advisory services. The fees charged by
WCP are as described in Item 5 above and are not based upon the capital appreciation of the funds or
securities held by any Client. WCP does not manage any proprietary investment funds or limited
partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend
any particular investment options to its Clients.
Item 7 – Types of Clients
WCP offers investment advisory services to individuals, high net worth individuals, trusts, estates,
retirement plans, charitable organizations and businesses. The Advisor’s typical Clients are those who are
experienced and comfortable with saving and investing for their retirement and their family’s future, board
members and/or trustees acting on behalf of the trust for an organization they represent, and
employers/business owners looking for an advisory group to assist them in making prudent investment
decisions. The amount of each type of Client is available on the Advisor's Form ADV Part 1A. These
amounts may change over time and are updated at least annually by the Advisor.
WCP generally does not impose a minimum size for establishing a relationship, but certain investment
strategies, TPAs and Independent Managers may require a minimum for effective implementation.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. METHODS OF ANALYSIS
WCP employs an evidence-based approach to developing investment strategies for clients and a
behavioral economics approach to make strategies available to clients. There are many plausible
allocations and strategies to achieve necessary long-term returns for financial plan success. The key is
to match a plausible strategy with client beliefs and preferences so that they are more likely to commit to
a strategy long-term, rather than be influenced to market vicissitudes to exit a strategy or allocation when
it comes under short-term pressure. The Advisor utilizes an investment choice framework to match plausible
long-term strategies to client preferences.
For active strategies, the evidence-based approach utilizes proprietary quantitative metrics, including the
Wealthcare Skill Index and break-even information ratios, to measure a manager’s skill, and potential
alpha after fees. The quantitative measures provide input to the qualitative analysis to finalize manager
selection decisions. The Advisor will allocate to selected managers using quantitative portfolio construction
techniques to build portfolios that achieve a client’s target risk allocation and to capture manager skill.
Where the Advisor dynamically manages allocations, long-term fundamental valuation analysis is used to
assess longer-term expected returns and various risk measures, including the Growth Conditions Index
(GCONIX) to adjust dynamic portfolios to maximize expected compensation for bearing risk.
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For index-tracking (passive) strategies, the Advisor will focus on minimizing costs, both manager fees and
transactions costs, while maintaining appropriate liquidity, to achieve the target risk and asset allocation
for financial plan success.
To build and implement the investment approach described above, the Advisor utilizes several forms of
analysis including fundamental, technical, and behavioral. Research and analysis from
WCP are derived from numerous sources, including databases (financial, economic, manager,
marker), primary and secondary research. Secondary research includes information derived from financial
media, third-party researchers, internet sources, and a review of the activities of manager, ETF and mutual
company activities, including reports, prospectuses, press releases and research prepared by others.
Fundamental Analysis
Fundamental analysis utilizes economic and business indicators as investment selection criteria. These
criteria consist of indicators that may indicate the overall strength and financial viability of the entity being
analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong
investment with a fair valuation. While this type of analysis helps in evaluating a potential investment, it does
not guarantee that the investment will increase in value. Assets meeting the investment criteria
utilized in the fundamental analysis may lose value and may have negative investment performance. The
Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate.
More details on the Advisor’s review process are included below in Item 13 – Review of Accounts.
Fundamental analysis also includes Cyclical Analysis. Cyclical analysis involves the analysis of economic
and market cycles in a way that adds insight into fair valuation and risk conditions given the market cycle.
Technical Analysis
Technical analysis involves the analysis of past market prices and may involve the use of charts to
identify market patterns and trends, which may be based on investor sentiment rather than the
fundamentals of a company, market, or economy. The Advisor uses technical analysis as a supportive of
fundamental analysis. The primary risk in using technical analysis is that spotting historical trends may
not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no
guarantee that WCP will be able to accurately predict such a reoccurrence. As such, it is not used on a
stand-alone basis, but as a supplement to fundamental analysis.
Technical analysis includes Charting Analysis. Charting analysis utilizes various market indicators as
investment selection criteria. These criteria are generally price trends that may indicate movement in the
markets. Assets are deemed suitable if they meet certain criteria to indicate that they can be expected to
rise in price. Assets meeting the investment criteria utilized in the technical and charting analysis may lose
value and may have negative investment performance. For dynamic strategies, the Advisor monitors these
market indicators to determine if adjustments to strategic allocations are appropriate.
Behavioral Analysis
Behavioral economics involves an examination of conventional economics as well as behavioral and
cognitive psychological factors. Behavioral economics seeks to combine a qualitative and quantitative
approach to provide explanations for why individuals may, at times, make irrational financial decision,
when viewed from conventional economic analysis. Where conventional financial theories have failed to
explain certain patterns, the behavioral finance methodology investigates the underlying reasons and
biases that cause some people to behave against their best interests. The risks relating to behavior
economics are that it relies on spotting trends in human behavior that may not predict future trends.
The Advisor uses behavioral economics principles in two ways:
1.
To analyze crowd behavior and its influence on market prices. WCP uses technical analysis described
above to assess the group behavior of market participants and its impact on markets.
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2.
To manage behavioral risk of individual clients through the investment choice framework described
above.
As noted above, WCP generally employs long-term investment strategies for its Clients, as consistent
with their financial goals and preferences. WCP will typically hold all or a portion of a security for more
than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the
cash needs of Clients. At times, WCP may also buy and sell positions that are more short-term in nature,
depending on the goals of the Client and/or the fundamentals.
B. RISK OF LOSS
Based upon WCP’s analysis of the Client’s financial situation, WCP recommends an appropriate
investment strategy for the Client’s accounts, however all investment strategies have a risk of loss. Investing
in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should
be prepared to bear the potential risk of loss. While risk can be, and by common industry practice often is,
measured by the degree of unpredictability of a given portfolio’s return in any given period, it also includes
the possibility of losing some or all of an original investment. Even the most conservative investment
strategy is subject to risk. WCP cannot guarantee a Client will—in all circumstances of changing personal
financial goals and market conditions—be able to remain in a Client's "Comfort Zone®", as that term is
described in this disclosure document.
All investment programs carry the risk of loss and there is no guarantee that any recommended
investment strategy will meet its objectives.
All investment strategies inherently expose Clients to various types and varying degrees of risk. These risks
are discussed in greater detail below.
• Market Risks. The value of a Client’s holdings may fluctuate in response to events specific to companies
or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the
performance of the overall financial markets.
• ETF Risks. The performance of ETFs is subject to market risk, including the possible loss of principal.
The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In
addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a
liquidity risk if the ETFs have a large bid-ask spread and low trading volume. The price of an ETF fluctuates
based upon the market movements and may dissociate from the index being tracked by the ETF or the price
of the underlying investments. An ETF purchased or sold at one point in the day may have a different price
than the same ETF purchased or sold a short time later.
• Leveraged ETF Risks. Leveraged ETFs seek to deliver multiples of the performance of the index or
benchmark they track. These ETFs attempt to deliver some multiple of an index's daily returns (positive or
negative). Please consider the implications to both the upside and the downside of multipliers. While it may
seem that a 2x multiplier is a benefit in an up-market cycle' it is important to remember that the same
multiplier applies when the ETF moves against the market. This could potentially result in significant losses,
and highlights the additional risk associated with Leveraged ETFs.
• Delaware Statutory Trusts (“DSTs”). Investing in a DST can provide Clients with the potential benefits
of recurring monthly income, asset appreciation, and 1031 exchange eligibility. DSTs also carry real estate
and market risk when investing in these alternative investments. DSTs can also be illiquid, have increased
cost, potential loss in value, potential for foreclosure on a property, reduction or elimination of monthly
distributions, and lack of control over the property.
• Interval Mutual Funds / Liquidity Risk. Clients invested in an interval mutual funds should be aware of the
illiquidity of holding such a mutual fund. Liquidity for fund shares is generally provided through a repurchase
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offer with a frequency disclosed in the fund’s prospectus. An example of such a repurchase offer might be 5%
of the fund’s shares on a quarterly basis. This agreement does not guarantee that a Client will be able to sell
all the shares that the Client desires to sell in the offer. There is currently no secondary market for the shares
of these funds.
• Mutual Fund Risks. The performance of mutual funds is subject to market risk, including the possible
loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities
that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased
at one point in the day will typically have the same price as a mutual fund purchased later that same day.
• Alternative Investments (Limited Partnerships). The performance of alternative investments (limited
partnerships) can be volatile and may have limited liquidity. An investor could lose all or a portion of their
investment. Such investments often have concentrated positions and investments that may carry higher
risks. If alternative investments are used, Client should only have a portion of their assets in these
investments.
• Political Risks. Most investments have a global component, even domestic stocks. Political events
anywhere in the world may have unforeseen consequences to markets around the world.
• General Market Risks. Markets can, as a whole, go up or down on various news releases or for no
understandable reason at all. This sometimes means that the price of specific securities could go up or down
without real reason and may take some time to recover any lost value. Adding additional securities does
not help to minimize this risk since all securities may be affected by market fluctuations.
• Currency Risk. Overseas investments are subject to fluctuations in the value of the dollar against the
currency of the investment’s originating country. This is also referred to as exchange rate risk.
• Derivatives Risk. Investments in futures and options are considered “derivative” investments. A small
investment in derivatives could have a potentially large impact on performance. The use of derivatives
involves risks different from or possibly greater than the risks associated with investing directly in the
underlying assets. Derivatives can be highly volatile, illiquid and difficult to value. There is the risk that
the hedging technique will fail if changes in the value of a derivative held do not correlate with the portfolio
securities being hedged.
• Regulatory Risk. Changes in laws and regulations from any government can change the value of a given
company and its accompanying securities. Certain industries are more susceptible to government
regulation. Changes in zoning, tax structure or laws impact the return on these investments.
• Risks Related to Investment Term. If a Client requires a liquidation of their portfolio during a period in
which the price of the security is low, the Client may not realize as much value as they might have had the
investment had the opportunity to regain its value, as investments frequently do, or had it been able to be
reinvested in another security.
• Purchasing Power Risk. Purchasing power risk is the risk that an investment’s value will decline as the
price of goods rises (inflation). The investment’s value itself does not decline, but its relative value does.
Inflation can happen for a variety of complex reasons, including a growing economy and a rising money
supply.
• Business Risk. Many investments, including many Index Funds and Target‐Date Funds, contain interests
in operating businesses. Business risks are risks are associated with a particular industry or a particular
company within an industry. For example, oil‐ drilling companies depend on finding oil and then refining
it, a lengthy process, before they can generate a profit. They likely carry a higher risk of profitability than
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an electric company, which generates its income from a steady stream of customers who buy electricity no
matter what the economic environment is like.
• Liquidity Risk. Liquidity is the ability to readily convert an investment into cash. For example, Treasury
Bills are highly liquid, while real estate properties are not. Some securities are highly liquid while others
are highly illiquid. Illiquid investments carry more risk because it can be difficult to sell them.
• Financial Risk. Many investments, including many Index Funds and Target‐Date Funds, contain interests
in operating businesses. Excessive borrowing to finance a business’ operations decreases the risk of
profitability, because the company must meet the terms of its obligations in good times and bad. During
periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining
market value.
• Default Risk. This risk pertains to the ability of a company to service their debt. Ratings provided by
several rating services help to identify those companies with more risk. Obligations of the U.S. government
are said to be free of default risk.
• Non-Purpose Loans. Non-purpose loans carry a number of risks, including but not limited to the risk of
a market downturn, tax implications if collateralized securities are liquidated, and an increase in interest
rates. A decline in the market value of collateralized securities held in the account[s] at the Custodian, may
result in a reduction in the draw amount of the Client’s line of credit, a demand from the Lending Program
that the Client deposit additional funds or securities in the Client’s collateral account[s], or a forced sale of
securities in the Client’s collateral account[s].
Item 9 – Disciplinary Information
WCP does not have any legal, financial or other material “disciplinary” item to report. WCP is obligated to
disclose any disciplinary event that would be material to a Client or perspective client when evaluating to
initiate a Client/Advisor relationship, or to continue a Client /Advisor relationship with WCP. This
statement applies to WCP and all employees and independent contractors registered with WCP.
Item 10 ‐ Other Financial Industry Activities and Affiliations
Broker-Dealer Affiliation
As mentioned in Item 5.E above, certain Advisory Persons are also a registered representative of M.S.
Howells or Arkadios. In their separate capacity as registered representatives, Advisory Persons will receive
commissions for the implementation of recommendations for commissionable transactions. Clients are not
obligated to implement any recommendation provided by Advisory Persons. Neither the Advisor nor
Advisory Persons will earn ongoing investment advisory fees in connection with any services implemented
in an Advisory Person’s separate capacity as a registered representative.
Transitional Investment Advisor Affiliation
On a temporary basis, certain Advisory Persons of WCP also serve as Investment Advisor Representatives of
a non-affiliated Registered Investment Advisor (“RIA”). As a financial advisor of a non-affiliated RIA, the
Advisory Person will receive investment advisory fees for investment management services offered. At no time
will the Advisory Person or the Advisor earn both ongoing investment advisory fees under the Advisor and
ongoing investment advisory fees through the non-affiliated RIA on the same investment assets.
Insurance Agency Affiliation
As mentioned in Item 5.E above, certain Advisory Persons are also licensed insurance professionals.
Implementations of insurance recommendations are separate and apart from one’s role with WCP. As an
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insurance professional, an Advisory Person receives customary commissions and other related revenues
from the various insurance companies whose products are sold. An Advisory Person is not required to offer
the products of any particular insurance company. Commissions generated by insurance sales do not offset
regular advisory fees. This presents a conflict of interest in recommending certain products of the insurance
companies. Clients are under no obligation to implement any recommendations made by Advisory Persons
or the Advisor.
Wealthcare Capital Management LLC (“WCM”)
The Advisor is affiliated, through common control and ownership, with WCM, a registered investment
advisor with the SEC. In certain circumstances, WCP may select WCM to act as sub-advisor for the
provision of advisory services. WCM may provide financial planning, investment advisory and certain
portfolio management services to WCP. This poses a conflict of interest as owners may benefit from
additional revenues generated. Additionally, certain Advisory Persons of WCP, in their individual capacity,
are also Advisory Persons of WCM. In their separate capacity they may recommend, on a fully disclosed
basis, the investment advisory services of WCM. A conflict of interest exists to the extent that Advisory
Persons recommend the services of WCM to Clients of WCP. Clients of WCP are under no obligation to
accept the recommendations of WCP to engage with WCM for services.
Additionally, WCP has engaged WCM to perform certain corporate and administrative functions, including
administering payroll to certain supervised persons.
Wealthcare Advisory Partners LLC (“WCAP”)
The Advisor is affiliated, through common control and ownership, with WCAP, a registered investment
advisor with the SEC. WCAP provides Investment Management and Financial Planning services to primarily
individuals and high net worth individuals, but has Advisory Persons who are registered representatives of
LPL Financial, LLC (“LPL”). Clients of WCAP will not be referred to WCP, and clients of WCP will not be
referred to WCAP for advisory services.
DPL Financial Partners, LLC
DPL Financial Partners, LLC (“DPL”) is a third-party provider of a platform of insurance consultancy
services to Clients with a current or future need for insurance products. DPL offers WCP a membership to
its platform for a fixed annual fee and, through its licensed insurance agents who are also registered
representatives of The Leaders Group, Inc. (“The Leaders Group”), an unaffiliated SEC-registered broker-
dealer and FINRA member, offers WCP a variety of services relating to fee-based insurance products.
These services include, among others, providing WCP with analyses of their current methodology for
evaluating client insurance needs, educating and acting as a resource to members regarding insurance
products generally and specific insurance products owned by their clients or that their clients are
considering purchasing, and providing members access to and product marketing support regarding fee-
based products that insurers have agreed to offer to Clients through DPL’s platform. For providing platform
services to WCP, DPL receives service fees from the insurers that offer their fee-based products through
the platform. These service fees are based on the insurance premiums received by the insurers.
DPL is licensed as an insurance producer in Kentucky and other jurisdictions where required to perform
the platform services. Its representatives are also licensed as insurance producers, appointed as insurance
agents of the insurers offering their products through the platform, and registered representatives of The
Leaders Group.
Use of Independent Managers
As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio with one
or more Independent Managers. The Advisor does not receive any compensation, nor does this present a
material conflict of interest. The Advisor will only earn its investment advisory fee as described in Item
5.A.
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Item 11 ‐ Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
WCP has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to
each Client. This Code applies to all persons associated with WCP (herein “Supervised Persons”). The Code
was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties
to each Client. WCP and its Supervised Persons owe a duty of loyalty, fairness and good faith towards
each Client. It is the obligation of WCP Supervised Persons to adhere not only to the specific provisions
of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that
address ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at
compliance@wealthcarecapital.com.
WCP's Code provides for (1) a high ethical standard of conduct; 2) compliance with all federal securities
laws; and (3) policies and procedures for the reporting of certain personal securities transactions on a
quarterly basis as well as upon hire and annually for all WCP's professionals and employees. The Chief
Compliance Officer of WCP reviews on a test basis employee trades periodically. The Chief Compliance
Officer’s trades are reviewed by the President of WCP or a designee. These reviews help ensure that the
personal trading of employees complies with WCP’s Code.
WCP allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. WCP does not act as principal in any transactions. In addition, the Advisor
does not act as the general partner of a fund, or advise an investment company. It is generally WCPs
policy that WCP and its Supervised Persons do not have a material interest, based on the total market
capitalization, in any securities traded in Client accounts. It should be noted that some Supervised Persons
of WCP are considered Clients of the Firm or of WCM and will have the ability to participate in many of the
same model portfolios that are available to Clients. The Advisor does not feel this presents a conflict of
interest because the minimal exposure that WCP’s overall ownership of these securities (through Client and
employee accounts) would not have a significant impact on their pricing given the large capitalization and
market liquidity of the securities recommended.
A copy of WCP's Code is available to WCPs advisory Clients upon written request to Compliance Staff at
WCP's principal office address or by email request to the WCP Chief Compliance Officer at
sdiberardino@wealthcarecapital.com.
Item 12 ‐ Brokerage Practices
A. RECOMMENDATION OF CUSTODIAN[S]
WCP does not have discretionary authority to select the broker-dealer/custodian for custody and execution
services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client
assets and authorize WCP to direct trades to the Custodian as agreed upon in the investment advisory
agreement. Further, WCP does not have the discretionary authority to negotiate commissions on behalf of
Clients on a trade-by-trade basis. Under certain instances, the Client may grant the Advisor limited authority
to place trades away from the Custodian. Please see Prime Brokerage Authorization below.
Where WCP does not exercise discretion over the selection of the Custodian, it may recommend the
Custodian[s] to Clients for custody and execution services. Clients are not obligated to use the
recommended Custodian and will not incur any extra fee or cost from the Advisor associated with using a
custodian not recommended by WCP. WCP may recommend that Clients establish accounts at TD
Ameritrade Institutional, a division of TD Ameritrade, Inc. (“TD Ameritrade”), Pershing LLC (“Pershing”),
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Charles Schwab & Co., Inc. (“Schwab”), and/or Fidelity Clearing & Custody Solutions, a related entity
of Fidelity Investments, Inc. (collectively “Fidelity”). TD Ameritrade, Pershing, Schwab and Fidelity are
independent and unaffiliated SEC-registered broker-dealers and members FINRA/SIPC. TD Ameritrade,
Pershing, Schwab and Fidelity offer to independent investment Advisors services, which include custody
of securities, trade execution, clearance and settlement of transactions. The Advisor receives some
benefits from TD Ameritrade, Pershing, Schwab and Fidelity through its participation in the program.
Please see the disclosure under Item 14 below.
Trade-Away Arrangements – WCP may obtain limited one-time ability to execute trades through other
broker-dealers when placing securities transactions on behalf of Clients. In such instances where WCP
trades away from the Custodian, the account will often incur a trade-away fee for each transaction that is
executed on a trade-away basis. The fee is separate from the commission/transaction fee or mark-up/mark-
down imposed by the broker-dealer through which the trade was executed.
Trading away may be advantageous for the Client because: the broker-dealer may have expertise in a
particular security or market; the broker-dealer makes a market in a particular security; a particular security
is thinly traded; or the broker-dealer can identify a counter-party for a trade. A Client may pay higher net
execution costs than would have paid if the transaction were placed through the Custodian holding his or
her assets. WCP will periodically review its arrangements with the Custodian against other possible
arrangements in the marketplace as it strives to achieve best execution on behalf of its Clients.
1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor
enters into an agreement to place security trades with the broker-dealer/custodian in exchange for research
and other services. WCP does not participate in soft dollar programs sponsored or offered by any
broker-dealer/custodian. However, the Advisor may receive certain economic benefits from the
Custodians. Please see Item 14 below.
2. Brokerage Referrals - WCP does not receive any compensation from any third party in connection with the
recommendation for establishing an account.
3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where WCP will place
trades within the established account[s] at the Custodian designated by the Client, unless otherwise
instructed. Further, all Client accounts are traded within their respective account[s] at the Custodian. The
Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s
own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client
account from another Client’s account[s]). WCP will not be obligated to select competitive bids on
securities transactions and does not have an obligation to seek the lowest available transaction costs. These
costs are determined by the Custodian.
4. Prime Brokerage – The Advisor may execute securities transactions either through the Custodian or
through another unaffiliated broker-dealer in connection with a prime brokerage relationship established with
the Custodian. Should a Client’s account[s] make use of prime brokerage, the Client is required to execute
additional agreement[s] with the Custodian authorizing the Advisor to trade-away from and settle to the
Client’s established account[s] at the Custodian. The Custodian may charge an additional trade-away fee for
these transactions in addition to the normal securities transaction costs.
B. TRADE AGGREGATION
Transactions for each Client account generally will be executed independently unless the Firm decides to
purchase or sell the same securities for several Clients at approximately the same time. WCP will execute its
transactions through the Custodian as authorized by the Client, unless otherwise authorized by the Client through
a trade-away agreement. WCP may, but is not obligated to, combine or “batch” such orders in an effort to
favorable commission rates or to allocate equitably among its
obtain best execution, to negotiate more
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Clients differences in prices and commissions or other transaction costs that might have been obtained had
such orders been placed independently. Under this procedure, transactions will be averaged as to price and
transaction costs and will be allocated among WCP Clients in proportion to the purchase and sale orders
placed for each Client account at the same time. If WCP cannot obtain execution of all the combined orders
at prices or for transactions costs that it believes are desirable, the Firm will allocate the securities that it
does buy or sell as part of the combined orders by following WCP order allocation procedures.
Item 13 – Review of Accounts
RECONCILIATION OF CLIENT ACCOUNTS
All active WCP Client accounts are reconciled to their most recent month‐end custodial statement before the
end of the next calendar month by Portfolio Operations, administered by WCM. Portfolio Operations is
supervised by the department head. In most cases, where an electronic reconciliation link has been
established between the custodian and the portfolio accounting system, the accounts are reconciled on a
daily basis. Whenever valuation information differs between the Custodian’s records and the Advisor’s
accounting system’s records, the differences are investigated and resolved.
FINANCIAL PLAN REVIEW
For Clients receiving ongoing financial planning services, each Client’s Advisory Person will initiate a
review and update the Client’s financial plan on at least an annual basis for changes in the Client's financial
situation and plan objectives. Additional reviews may be initiated for several reasons including 1) due to
changes in a Client’s priorities, 2) upon demand by the Client, 3) whenever the Adviser considers a plan
update and review is in the Client’s best interest, 4) should there be a material change in circumstances for
the Client or 5) should the Client’s financial plan fall materially outside its Comfort Zone®.
REGULAR REPORTS
For Clients receiving financial planning services, method and frequency of the delivery of status reports
vary by advisor or Client preference. They may be delivered in person, in physical or virtual Client meeting,
via regular mail or via secure online or electronic delivery. Status reports generated utilizing the GDX360®
platform typically include information on portfolio holdings, Client goals, values, and the funded Comfort
Zone® status of the Client’s financial plan. Each report will contain an offer to the Client to request and
receive WCP's most current Form ADV Part 2A which includes the firm’s privacy policy. The Status
Reports are prepared solely for information purposes only and are not an official record of Client’s accounts.
Clients will receive monthly statements from the Custodian for each household account held by the
custodian. If the Client’s account has no activity, the Custodian, at a minimum, will provide a quarterly
statement. The custodian’s statement will include information about the assets held in the account, the
current value of each asset as well as reflect the deduction of any fees from the Client’s account. Clients
are encouraged to review their statements for discrepancies.
Item 14 ‐ Client Referrals and Other Compensation
A. COMPENSATION RECEIVED BY WCP
AssetMark
Under AssetMark’s business development allowance program, WCP may receive a quarterly business
development allowance for reimbursement of qualified marketing and practice development expenses
incurred by the Advisory Person. These amounts vary depending on the value of the assets on the AssetMark
Platform held by Clients of the Advisor.
Forgivable Transition notes
WCP Financial provides forgivable transition notes to Advisory Persons based on the expected transfer
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Client assets onto the WCP platform. However, the receipt of forgivable transition notes creates conflicts
of interest relating to advisory business because it creates a financial incentive for Advisory Persons to
recommend that its Clients transition their accounts to the WCP platform. However, clients should be aware
of this conflict and take it into consideration in making a decision whether to transition Client assets onto
the WCP platform.
Participation in Institutional Advisor Platform – TD Ameritrade
As disclosed under Item 12, above, the Advisor participates in TD Ameritrade’s institutional customer
program and the Advisor may recommend TD Ameritrade to Clients for custody and brokerage services.
There is no direct link between the Advisor’s participation in the program and the investment advice it gives
to its Clients, although the Advisor receives economic benefits through its participation in the program that
are typically not available to TD Ameritrade retail investors. These benefits include the following products
and services (provided without cost or at a discount): receipt of duplicate Client statements and
confirmations; research related products and tools; consulting services; access to a trading desk serving the
Advisor participants; access to block trading (which provides the ability to aggregate securities transactions
for execution and then allocate the appropriate shares to Client accounts); the ability to have advisory fees
deducted directly from Client accounts; access to an electronic communications network for Client order
entry and account information; access to mutual funds and ETFs with no transaction fees and to certain
institutional money managers; and discounts on compliance, marketing, research, technology, and practice
management products or services provided to the Advisor by third party vendors. TD Ameritrade may also
have paid for business consulting and professional services received by the Advisor’s related persons. Some
of the products and services made available by TD Ameritrade through the program may benefit the Advisor
but may not benefit its Client accounts. These products or services may assist the Advisor in managing and
administering Client accounts, including accounts not maintained at TD Ameritrade. Other services made
available by TD Ameritrade are intended to help the Advisor manage and further develop its business
enterprise. The benefits received by the Advisor or its personnel through participation in the program do
not depend on the amount of brokerage transactions directed to TD Ameritrade. As part of its fiduciary
duties to Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be
aware, however, that the receipt of economic benefits by the Advisor or its related persons in and of itself
creates a conflict of interest and may indirectly influence the Advisor’s choice of TD Ameritrade for custody
and brokerage services.
Participation in Institutional Advisor Platform – Fidelity, Pershing
The Advisor has established an institutional relationship with Pershing and Fidelity to assist the Advisor in
managing Client account[s]. Access to the Custodian’s Institutional platform is provided at no charge to the
Advisor. The Advisor receives access to software and related support without cost because the Advisor
renders investment management services to Clients that maintain assets at the Custodian. The software and
related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its
Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware,
however, that the receipt of economic benefits from a custodian creates a conflict of interest since these
benefits may influence the Advisor’s recommendation of this custodian over one that does not furnish
similar software, systems support, or services.
Additionally, the Advisor may receive the following benefits from the Custodians: receipt of duplicate
Client confirmations and bundled duplicate statements; access to a trading desk that exclusively services
its institutional participants; access to block trading which provides the ability to aggregate securities
transactions and then allocate the appropriate shares to Client accounts; and access to an electronic
communication network for Client order entry and account information.
Participation in Institutional Advisor Platform - Schwab
WCP has established an institutional relationship with Schwab through its “Schwab Advisor Services”
unit, a division of Schwab dedicated to serving independent advisory firms like WCP. As a registered
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investment advisor participating on the Schwab Advisor Services platform, WCP receives access to
software and related support without cost because the Advisor renders investment management services to
Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor
and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients,
the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however,
that the receipt of economic benefits from a custodian creates a conflict of interest since these benefits may
influence the Advisor's recommendation of this custodian over one that does not furnish similar software,
systems support, or services.
Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range
of investment products, execution of securities transactions, and custody of Client’s funds and securities.
Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client
would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in
certain mutual funds and other investments without having to adhere to investment minimums that might
be required if the Client were to directly access the investments and, in some cases, Schwab may waive trade
ticket charges.
Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to
technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for
Client accounts, the ability to deduct advisory fees, trading tools, and back-office support services as part of
its relationship with Schwab. These services are intended to assist the Advisor in effectively managing
accounts for its Clients, but may not directly benefit all Clients.
Services that May Only Benefit the Advisor – Schwab also offers other services to WCP that may not
benefit the Client, including: educational conferences and events, consulting services and discounts for
various service providers. Access to these services creates a financial incentive for the Advisor to
recommend Schwab, which results in a conflict of interest. WCP believes, however, that for Client who
open Schwab account, the selection of Schwab as Custodian is in the best interests of its Clients.
B. COMPENSATION FOR CLIENT REFERRALS
Certain Clients may be referred to the Advisor by either an affiliated or unaffiliated party (herein
"Promoter") and receive, directly or indirectly, compensation for the Client referral. In such instances,
the Advisor will compensate the Promoter a fee in accordance with Rule 206(4)-1 of the Advisers Act
and any corresponding state securities requirements. Any such compensation shall be paid solely from
the investment advisory fees earned by the Advisor, and shall not result in any additional charge to the
Client.
Item 15 ‐ Custody
WCP does not accept or maintain custody of Client accounts, except for the limited circumstances outlined
below:
Deduction of Advisory Fees - To ensure compliance with regulatory requirements associated with the deduction
of advisory fees, all Clients for whom WCP exercises discretionary authority must hold their assets with a
"qualified custodian." Clients are responsible for engaging a “qualified custodian” to safeguard their funds and
securities and must instruct WCP to utilize that Custodian for securities transactions on their behalf. Clients are
encouraged to review statements provided by the Custodian and compare to any reports provided by WCP to
ensure accuracy, as the Custodian does not perform this review.
Money Movement Authorization - For instances where Clients authorize WCP to move funds between their
accounts, WCP and the Custodian have implemented safeguards to ensure that all money movement activities
are conducted strictly in accordance with the Client’s documented instructions.
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Item 16 ‐ Investment Discretion
WCP receives discretionary authority from most of its Clients at the outset of an advisory relationship to
select the types of securities and model portfolios as well as the allocation of those securities in a Client’s
account(s). This is documented normally via a Client’s execution of the advisory agreement between the
Client and WCP. Additionally, the Custodian may require the Client to execute a limited power of attorney
(“LPOA”) when opening or turning over the custodial account to WCP’s discretionary management. The
LPOA will grant WCP the authority 1) to trade securities on the Client’s behalf in the account, 2) to
authorize the disbursement of WCP’s quarterly investment advisory fee and 3) to authorize WCP to
instruct the custodian to disburse a check or money electronic transfers from the Client’s custodial account
to their address of record or, with additional paperwork signed by the Client, to a bank account registered
in the Client’s name.
The Client can provide WCP restrictions as to the degree of discretion the Firm has in trading one or more of
the Client’s investment accounts or specific investment securities. If planning services are included, the
Client’s financial plan is used to determine the Client’s targeted investment allocation which WCP
monitors. If WCM is engaged for investment management services, it generally maintains the allocation at
the combined household versus individual account level.
Item 17 ‐ Voting Client Securities
WCP does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements
directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however,
the Client retains the sole responsibility for proxy decisions and voting.
Item 18 ‐ Financial Information
Advisors are required in this Item to provide certain financial information or disclosures about their
financial condition. WCP has no financial commitment or condition that impairs its ability to meet
contractual and fiduciary commitments to Clients, and has not been the subject of a bankruptcy proceeding.
A balance sheet is not required to be provided because WCP does not serve as a custodian for Client funds or
securities and does not require prepayment of fees of more than $1,200 per Client six months or more in
advance.
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Wealthcare Capital Partners LLC
Wealthcare Capital Partners LLC
2 James Center
1065 Andrew Drive
West Chester, PA 19380
Phone: (804) 644-4711 * Fax: (804) 433-1188
Form ADV Part 2A – Appendix 1
(“Wrap Fee Program Brochure”)
This Form ADV2A - Appendix 1 (“Wrap Fee Program Brochure”) provides information about the
qualifications and business practices for Wealthcare Capital Partners LLC (“WCP” or the “Advisor”)
services when offering services pursuant to a wrap program. This Wrap Fee Program Brochure shall
always be accompanied by the WCP Disclosure Brochure, which provides complete details on the
business practices of the Advisor. If you did not receive the complete WCP Disclosure Brochure or you
have any questions about the contents of this Wrap Fee Program Brochure or the WCP Disclosure
Brochure, please contact the Advisor at (804) 644-4711 or by email at
compliance@wealthcarecapital.com.
WCP is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”).
The information in this Wrap Fee Program Brochure has not been approved or verified by the SEC or by
any state securities authority. Registration of an investment advisor does not imply any specific level of
skill or training. This Wrap Fee Program Brochure provides information about WCP to assist you in
determining whether to retain the Advisor.
Additional information about WCP and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 330300.
Date: October 17, 2025
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Item 2 – Material Changes
Form ADV 2 - Appendix 1 provides information about a variety of topics relating to an Advisor’s
business practices and conflicts of interest. In particular, this Wrap Fee Program Brochure discusses the
wrap fee program offered by the Advisor.
Material Changes
There have been no material changes to this Wrap Fee Program Brochure since the last filing and
distribution to clients on 8/19/2024. This is the Advisor’s first annual amendment filing.
Future Changes
From time to time, the Advisor may amend this Wrap Fee Program Brochure to reflect changes in
business practices, changes in regulations and routine annual updates as required by the securities
regulators. This complete Wrap Fee Program Brochure (along with the complete WCP Disclosure
Brochure) or a Summary of Material Changes shall be provided to you annually and if a material change
occurs in the business practices of WCP.
At any time, you may view this Wrap Fee Program Brochure and the current Disclosure Brochure on-line
at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with
the Advisor’s firm name or CRD# 330300. You may also request a copy of this Disclosure Brochure at
any time, by contacting the Advisor at (804) 644-4711 or by email at
compliance@wealthcarecapital.com.
Item 3 – Table of Contents
Form ADV Part 2A – Appendix 1 ..................................................................................................23
Item 2 – Material Changes ...........................................................................................................24
Item 3 – Table of Contents ..........................................................................................................24
Item 4 – Advisory Business..........................................................................................................25
Item 5 – Account Requirements and Types of Clients .......................................................................... 27
Item 6 – Portfolio Manager Selection and Evaluation ...........................................................................27
Item 7 – Client Information Provided to Portfolio Managers ..................................................................28
Item 8 – Client Contact with Portfolio Managers ................................................................................28
Item 9 – Additional Information ....................................................................................................28
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Item 4 – Advisory Business
SERVICES
WCP provides customized investment management services for its Clients. This Wrap Fee Program
Brochure is provided as a supplement to the WCP Form ADV 2A (“Disclosure Brochure”). This Wrap
Fee Program Brochure is provided along with the complete Disclosure Brochure to provide full details of
the business practices and fees when selecting WCP as your investment advisor.
If an account is opened with a wrap fee program structure, investment advisory fees will be inclusive of
normal securities transaction fees as part of the overall investment advisory fee. Securities regulations often
refer to this combined fee structure as a “Wrap Fee Program”. The Advisor sponsors the WCP Wrap Fee
Program.
The sole purpose of this Wrap Fee Program Brochure is to provide additional disclosure relating the
combination of securities transaction fees into the single “bundled” investment advisory fee. This Wrap Fee
Program Brochure references back to the WCP Disclosure Brochure in which this Wrap Fee Program
Brochure serves as an Appendix. Please see Item 4 – Advisory Services of the Disclosure Brochure for
details on WCP’s investment philosophy and related services.
PROGRAM COSTS
Advisory services provided by WCP are offered in a Wrap Fee Program structure whereby normal
securities transaction costs are included in the overall investment advisory fee paid to WCP. As the level of
trading in a Client’s account[s] may vary from year to year, the annual cost to the Client may be more or less
than engaging for advisory services where the transactions costs are borne separately by the Client. The
cost of the Wrap Fee Program varies depending on services to be provided to each Client, however, the
Client is not charged more if there is higher trading activity in the Client’s account[s]. A Wrap Fee
Program structure has a conflict of interest as the Advisor has an incentive to limit the number of trades
placed in the Client’s account[s] or to utilize securities that do not have transaction fees. Certain of the
Advisor’s recommended Custodians do not charge securities transaction fees for exchange traded fund
(“ETF”) and equity trades in Client accounts, but do charge for mutual funds and other types of investments.
As such, the Advisor is incentivized to utilize ETFs and other equity securities to limit the overall cost to
the Advisor. The Advisor will only place Client assets into a Wrap Fee Program when it is believed to be
in the Client’s best interest. Please see Item 5 – Fees and Compensation of the Disclosure Brochure for
complete details on fees.
FEES
Management fees are typically paid quarterly, in advance of each calendar quarter, pursuant to the terms of
the management agreement, custodial agreement or third party manager agreement. Management fees are
based on the market value of assets under management at the end of the prior quarter. Management fees
are at a rate of up to 1.85% based on several factors including the types of investments, size of the Client
relationship, reporting requirements, portfolio restrictions and other factors. Fees may be negotiable at the
sole discretion of the Advisor. WCP may offer discounted rates to its employees and their families as
well as to institutional and very high net worth Clients with substantial account balances.
The management fee in the first quarter of service is prorated from the inception date of the account[s]
to the end of the first quarter. The Client’s fees will take into consideration the aggregate assets under
management with Advisor. All securities held in accounts managed by WCP will be independently valued by the
Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing..
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Generally, management fees are calculated by the Custodian and deducted from the Client’s account[s].
The Client shall instruct the Custodian to automatically deduct the management fee
from the Client’s
account[s] for each quarter and pay the management fee[s] to the Advisor. The Custodian will utilize the
fee rate, as defined in the custodial paperwork, to indicate the fee to be deducted from the Client’s
account[s] at the respective quarter-end date. In such circumstances, fees may be prorated for capital
contributions or withdrawals made into a managed account following the initial establishment of a
managed account during the applicable quarter.
In certain instances, management fees will be calculated by the Advisor, its delegate or an Independent
Manager and deducted from the Client’s account[s] at the Custodian. The Advisor or its delegate shall
send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s
account[s] at the respective quarter-end date. In such circumstances, fees will not be prorated for capital
contributions or withdrawals made into a managed account following the initial establishment of a
managed account during the applicable quarter.
When calculated by Advisor, the amount due is calculated by applying the quarterly rate (annual rate
divided by 4) to the total assets under management with WCP at the end of the previous quarter. It is the
responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s quarterly
statement as the Custodian and Advisor do not assume this responsibility. Clients provide written
authorization permitting the Custodian to pay WCP by direct deduction from their account[s] held by the
Custodian as part of the management agreement and separate account forms provided by the Custodian.
As noted above, the Wrap Fee Program includes normal securities trading costs incurred in connection with
the discretionary management services provided by WCP. Securities transaction fees for Client-directed
trades may be charged back to the Client.
Clients may incur certain fees or charges imposed by third parties in connection with investments made on
behalf of the Client’s account[s]. Under this Wrap Fee Program, WCP includes securities transactions
costs as part of its overall investment advisory fee.
WCP will select investments in both mutual funds and ETFs. WCP selects mutual fund share classes on a
fund-by-fund basis and seeks to eliminate 12b-1 fees where possible. This practice presents a conflict of
interest; however, WCP will seek to use non-retail or institutional classes where these share classes are
available. Additionally, WCP will seek to select the lowest cost share class available that aligns the stated
program account minimum and allocation weighting of funds held with the fund’s prospectus requirements.
Due to specific custodial or mutual fund company constraints, there may be situations where a specific
share class is not consistently available. In those cases, Clients will be invested in the lowest cost share
class that is commonly available.
In addition, all fees paid to WCP for management services or part of the Wrap Fee Program are separate
and distinct from the expenses charged by mutual funds and exchange-traded funds to their shareholders,
if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses
will generally be used to pay management fees for the funds, other fund expenses, account administration
(e.g., custody, brokerage and account reporting), and a possible distribution fee. The Client may also incur
other costs assessed by the Custodian or other parties for account related activity fees, such as wire transfer
fees, fees for trades executed away from the Custodian and other fees. The Advisor does not control nor
share in these fees. The Client should review both the fees charged by the fund[s] and the fees charged by
WCP to fully understand the total fees to be paid. Please see Item 5.C – Other Fees and Expenses of the
Disclosure Brochure.
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COMPENSATION
WCP is the sponsor and may be the portfolio manager of this Wrap Fee Program. WCP receives
investment advisory fees paid by Clients for participating in the Wrap Fee Program and pays the Custodian
for the costs associated with the normal trading activity in the Client’s account[s].
Item 5 – Account Requirements and Types of Clients
WCP offers investment advisory services to individuals, high net worth individuals, trusts, estates,
retirement plans, charitable organizations and businesses. WCP generally does not impose a minimum size
for establishing a relationship. Please see Item 7 – Types of Clients of the Disclosure Brochure for
additional information.
Item 6 – Portfolio Manager Selection and Evaluation
PORTFOLIO MANAGER SELECTION
WCP serves as sponsor for the services under this Wrap Fee Program. Either WCP or Wealthcare
Capital Management LLC (“WCM”), an affiliated registered investment advisor will serve as portfolio
manager of selected accounts within the Wrap Fee Program.
RELATED PERSONS
Either WCP or WCM personnel will serve as portfolio manager of selected accounts within the Wrap Fee
Program.
PERFORMANCE BASED FEES
WCP does not charge performance-based fees.
SUPERVISED PERSONS
WCP Advisory Persons may serve as portfolio managers for all accounts, including the services described in
this Wrap Fee Program Brochure. Details of the advisory services provided are included in Item 4 –
Advisory Services of the Disclosure Brochure.
METHODS OF ANALYSIS
Please see Item 8.A – Methods of Analysis of the Disclosure Brochure for details on the research and
analysis methods employed by the Advisor.
RISK OF LOSS
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value.
Clients should be prepared to bear the potential risk of loss. WCP will assist Clients in determining an
appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no
guarantee that a Client will meet their investment goals.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time
horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's
account[s]. Client participation in this process, including full and accurate disclosure of requested
information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and
other information provided by the Client or their designees without the duty or obligation to validate the
accuracy and completeness of the provided information. It is the responsibility of the Client to inform the
Advisor of any changes in financial condition, goals or other factors that may affect this analysis.
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Past performance is not a guarantee of future returns. Investing in securities and other investments involve
a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss
these risks with the Advisor. Please see Item 8.B – Risk of Loss of the Disclosure Brochure for details on
investment risks.
PROXY VOTING
WCP does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements
directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however,
the Client retains the sole responsibility for proxy decisions and voting.
Item 7 – Client Information Provided to Portfolio Managers
WCP is the sponsor and may be the portfolio manager for the Program. Additionally, for selected accounts
within the program, WCM may serve as portfolio manager. Client information is shared with WCM in both
its capacity as portfolio manager of the selected accounts for this Wrap Fee Program and in services as
described within Item 4 – Advisory Services of the Disclosure Brochure. Please also see the WCP Privacy
Policy.
Item 8 – Client Contact with Portfolio Managers
WCP is a full-service investment management advisory firm. Clients always have direct access to the
Portfolio Managers at WCP.
Item 9 – Additional Information
DISCIPLINARY INFORMATION
WCP values the trust Clients place in the Advisor. The Advisor encourage Clients to perform the requisite due
diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor and
its Advisory persons are available on the Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 330300. Please see Item 9
– Disciplinary Information of the WCP Disclosure Brochure as well as Item 3 – Disciplinary Information of
each Advisory Person’s Brochure Supplement for additional information on how to research the
background of the Advisor and its Advisory Persons.
OTHER FINANCIAL ACTIVITIES AND AFFILIATIONS
Please see Item 10 – Other Financial Industry Activities and Affiliations and Item 14 – Other
Compensation and Client Referrals of the Disclosure Brochure.
CODE OF ETHICS
WCP has implemented a Code of Ethics that defines the Advisor’s fiduciary commitment to each Client.
This Code of Ethics applies to all persons subject to WCP’s compliance program (“Supervised Persons”).
Complete details on the WCP Code of Ethics can be found under Item 11 – Code of Ethics, Participation in
Client Transactions and Personal Trading of the Disclosure Brochure.
REVIEW OF ACCOUNTS
Securities in Client accounts are monitored on a regular and continuous basis by Advisory Persons of
WCP under the supervision of the Chief Compliance Officer (“CCO”). Details of the review policies and
practices are provided in Item 13 – Review of Accounts of the Disclosure Brochure.
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OTHER COMPENSATION
Use of Independent Managers - The Advisor may be indirectly compensated by an Independent Manager
as described in Item 5 – Fees and Compensation of the Disclosure Brochure and does not receive any other
forms of compensation with such arrangements.
Participation in Institutional Advisor Platform (TD Ameritrade) - As disclosed under Item 12, above, the
Advisor participates in TD Ameritrade’s institutional customer program and the Advisor may recommend
TD Ameritrade to Clients for custody and brokerage services. There is no direct link between the Advisor’s
participation in the program and the investment advice it gives to its Clients, although the Advisor receives
economic benefits through its participation in the program that are typically not available to TD Ameritrade
retail investors. These benefits include the following products and services (provided without cost or at a
discount): receipt of duplicate Client statements and confirmations; research related products and tools;
consulting services; access to a trading desk serving the Advisor participants; access to block trading (which
provides the ability to aggregate securities transactions for execution and then allocate the appropriate
shares to Client accounts); the ability to have advisory fees deducted directly from Client accounts; access
to an electronic communications network for Client order entry and account information; access to mutual
funds and ETFs with no transaction fees and to certain institutional money managers; and discounts on
compliance, marketing, research, technology, and practice management products or services provided to
the Advisor by third party vendors. TD Ameritrade may also have paid for business consulting and
professional services received by the Advisor’s related persons. Some of the products and services made
available by TD Ameritrade through the program may benefit the Advisor but may not benefit its Client
accounts. These products or services may assist the Advisor in managing and administering Client accounts,
including accounts not maintained at TD Ameritrade. Other services made available by TD Ameritrade are
intended to help the Advisor manage and further develop its business enterprise. The benefits received by
the Advisor or its personnel through participation in the program do not depend on the amount of brokerage
transactions directed to TD Ameritrade. As part of its fiduciary duties to Clients, the Advisor endeavors at
all times to put the interests of its clients first. Clients should be aware, however, that the receipt of economic
benefits by the Advisor or its related persons in and of itself creates a conflict of interest and may indirectly
influence the Advisor’s choice of TD Ameritrade for custody and brokerage services.
Participation in Institutional Advisor Platform (Fidelity, Pershing) - The Advisor has established an
institutional relationship with Pershing and Fidelity to assist the Advisor in managing Client account[s].
Access to the Custodian’s Institutional platform is provided at no charge to the Advisor. The Advisor
receives access to software and related support without cost because the Advisor renders investment
management services to Clients that maintain assets at the Custodian. The software and related systems
support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor
endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the
receipt of economic benefits from a custodian creates a conflict of interest since these benefits may
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influence the Advisor’s recommendation of this custodian over one that does not furnish similar software,
systems support, or services.
Participation in Institutional Advisor Platform (Schwab) - WCP has established an institutional
relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to
serving independent advisory firms like WCP. As a registered investment advisor participating on the
Schwab Advisor Services platform, WCP receives access to software and related support without cost
because the Advisor renders investment management services to Clients that maintain assets at Schwab.
Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided
by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to
put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits
from a custodian creates a conflict of interest since these benefits may influence the Advisor's
recommendation of this custodian over one that does not furnish similar software, systems support, or
services.
Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range
of investment products, execution of securities transactions, and custody of Client’s funds and securities.
Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client
would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in
certain mutual funds and other investments without having to adhere to investment minimums that might
be required if the Client were to directly access the investments and in some cases Schwab may waive trade
ticket charges.
Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to
technology, research, discounts and other services. In addition, the Advisor receives duplicate statements
for Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as
part of its relationship with Schwab. These services are intended to assist the Advisor in effectively
managing accounts for its Clients, but may not directly benefit all Clients.
Services that May Only Benefit the Advisor – Schwab also offers other services to WCP that may not
benefit the Client, including: educational conferences and events, consulting services and discounts for
various service providers. Access to these services creates a financial incentive for the Advisor to
recommend Schwab, which results in a conflict of interest. WCP believes, however, that for Client who
open Schwab account, the selection of Schwab as Custodian is in the best interests of its Clients.
Please see Item 14 – Other Compensation of the Disclosure Brochure for details on additional compensation
that may be received by WCP and/or its Advisory Persons. Each Advisory Person’s Brochure Supplement
provides details on any outside business activities and the associated compensation.
COMPENSATION FOR CLIENT REFERRALS
Certain Clients may be referred to the Advisor by either an affiliated or unaffiliated party (herein
"Promoter") and receive, directly or indirectly, compensation for the Client referral. In such instances,
the Advisor will compensate the Promoter a fee in accordance with Rule 206(4)-1 of the Advisers Act
and any corresponding state securities requirements. Any such compensation shall be paid solely from
the investment advisory fees earned by the Advisor, and shall not result in any additional charge to the
Client.
FINANCIAL INFORMATION
Advisors are required in this Item to provide certain financial information or disclosures about their
financial condition. WCP has no financial commitment or condition that impairs its ability to meet
contractual and fiduciary commitments to Clients, and has not been the subject of a bankruptcy proceeding.
WCP is not required to deliver a balance sheet along with this Disclosure Brochure, as the firm does not
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collect advance fees of $1,200 or more for services to be performed six months or more in advance. Please
see Item 18 – Financial Information of the Disclosure Brochure.
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