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ITEM 1 – COVER PAGE
West End Wealth Management, LLC
8055 E. Tufts Ave., Suite 830
Denver, CO 80237
Phone: 720 593 9396
February 15, 2026
Part 2A Brochure
This brochure provides information about the qualifications and business practices of West End Wealth
Management, LLC (“West End”) If you have any questions about the contents of this brochure, please
contact us at 720 593 9396. The information in this brochure has not been approved or verified by the
United States Securities and Exchange Commission or by any state securities authority. West End is a
Registered Investment Adviser. Registration with the United States Securities and Exchange Commission or
any state securities authority does not imply a certain level of skill or training.
Additional information about West End Wealth Management is available on the SEC’s website at
www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a IARD
number. The IARD number for West End Wealth Management is 234791.
West End Wealth Management, LLC – 8055 E. Tufts Ave., Suite 830, Denver, CO 80237
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ITEM 2 – MATERIAL CHANGES
Summary of Material Changes
This section of the Brochure will address only those “material changes” that have been
incorporated since our last delivery or posting of this document on the SEC’s public
disclosure website (IAPD) www.adviserinfo.sec.gov. Our Firm has made the following
changes since our last annual amendment filed January 22, 2025:
• There are no material changes to disclose.
If you would like another copy of this Brochure, please download it from the SEC Website
as indicated above or you may contact our Chief Compliance Officer, John Trujillo at 303-
596-6068.
We encourage you to read this document in its entirety.
West End Wealth Management, LLC – 8055 E. Tufts Ave., Suite 830, Denver, CO 80237
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TEM 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 .......................................................................................7
ITEM 6 - PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT ............................... 10
ITEM 7 - TYPES OF CLIENTS ................................................................................................... 10
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS .................... 10
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 ............................................................................................................ 17
ITEM 12 - BROKERAGE PRACTICES ........................................................................................ 18
ITEM 13 - REVIEW OF ACCOUNTS.......................................................................................... 22
ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION ................................................... 23
ITEM 15 - CUSTODY .............................................................................................................. 25
ITEM 16 - INVESTMENT DISCRETION ..................................................................................... 26
ITEM 17 - VOTING CLIENT SECURITIES ................................................................................... 27
ITEM 18 - FINANCIAL INFORMATION .................................................................................... 27
West End Wealth Management, LLC – 8055 E. Tufts Ave., Suite 830, Denver, CO 80237
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ITEM 4 – ADVISORY BUSINESS
This Disclosure document is being offered to you by West End Wealth Management, LLC
(“West End”) about the investment advisory services we provide. It discloses information
about the services that we provide and the way those services are made available to you,
the client.
We are an investment management firm located in Colorado. We specialize in investment
advisory services for high-net-worth individuals, institutions, families, trusts and estates.
The firm was established by John Trujillo and Marti Brust in 2015 and became licensed as
a Registered Investment Adviser in July 2015. Mr. Trujillo owns 50% of the firm and Mrs.
Brust owns 50% of the firm.
We are committed to helping clients build, manage, and preserve their wealth, and to
provide assistance that helps clients to achieve their stated financial goals. We will offer
an initial complimentary meeting upon our discretion, however, investment advisory
services are initiated only after you and West End execute an investment management
agreement.
Investment and Wealth Management Services
We offer discretionary investment management and investment supervisory services for a
fee based on a percentage of your assets under management or on a flat fee. These services
include investment analysis, allocation of investments, monthly portfolio reports, financial
commentaries, and ongoing monitoring of client portfolios. We primarily allocate client
assets among various mutual funds, exchange-traded funds (“ETFs”), and individual debt
(bonds) and equity securities in accordance with the client’s stated investment objectives.
Cash and cash equivalents and any margin debt balances are included in the calculation of
advisory fees, unless otherwise noted and agreed to in the executed Agreement.
We will work with you to obtain necessary information regarding your financial condition,
investment objectives, liquidity requirements, risk tolerance, time horizons, and any
restrictions on investing. This information enables us to determine the portfolio best suited
for your investment objective and needs.
In performing our services, we shall not be required to verify any information received from
you or from other professionals on your behalf. If you request, we will recommend you
engage the services of other professionals for implementation purposes. You have the right
to decide whether or not to engage the services of any such recommended professional.
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Once we have determined the types of investments to be included in your portfolio and
have allocated them, we will provide ongoing portfolio review and management services.
This approach requires us to review your portfolio at least monthly.
We will rebalance the portfolio, as we deem appropriate, to meet your financial objectives.
We trade these portfolios and rebalance them based on the combination of our market
views and your objectives, using our investment process. We tailor our advisory services
to meet the needs of our clients and seek to ensure that your portfolio is managed in a
manner consistent with those needs and objectives. You will have the ability to leave
standing instructions with us to refrain from investing in particular industries or invest in
limited amounts of securities.
In all cases, you have a direct and beneficial interest in your securities. We do have limited
authority to direct the Custodian to deduct our investment advisory fees from your
accounts, but only with the appropriate written authorization from you.
You are advised and are expected to understand that our past performance is not a
guarantee of future results. Certain market and economic risks may exist that adversely
affect an account’s performance. This could result in capital losses in your account.
Disclosure Regarding Rollover Recommendations
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide
investment advice to you regarding your retirement plan account or individual retirement
account, we are also fiduciaries within the meaning of Title I of the Employee Retirement
Income Security Act and/or the Internal Revenue Code, as applicable, which are laws
governing retirement accounts. We have to act in your best interest and not put our
interest ahead of yours. At the same time, the way we make money creates some conflicts
with your interests.
A client or prospect leaving an employer typically has four options regarding an existing
retirement plan (and may engage in a combination of these options): (i) leave the money
in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s
plan, if one is available and rollovers are permitted, (iii) rollover to an Individual Retirement
Account (“IRA”), or (iv) cash out the account value (which could, depending upon the
client’s age, result in adverse tax consequences). Our Firm may recommend an investor
roll over plan assets to an IRA for which our Firm provides investment advisory services.
As a result, our Firm and its representatives may earn an asset-based fee. In contrast, a
recommendation that a client or prospective client leave their plan assets with their
previous employer or roll over the assets to a plan sponsored by a new employer will
generally result in no compensation to our Firm. Our Firm therefore has an economic
incentive to encourage a client to roll plan assets into an IRA that our Firm will manage,
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which presents a conflict of interest. To mitigate the conflict of interest, there are various
factors that our Firm will consider before recommending a rollover, including but not
limited to: (i) the investment options available in the plan versus the investment options
available in an IRA, (ii) fees and expenses in the plan versus the fees and expenses in an
IRA, (iii) the services and responsiveness of the plan’s investment professionals versus
those of our Firm, (iv) protection of assets from creditors and legal judgments, (v) required
minimum distributions and age considerations, and (vi) employer stock tax consequences,
if any. Our Firm’s Chief Compliance Officer remains available to address any questions that
a client or prospective client has regarding the oversight.
Financial Planning
Through the Financial Planning process, our team strives to engage our clients in
conversations around the family’s goals, objectives, priorities, vision, and legacy – both for
the near term as well as for future generations. With the unique goals and circumstances
of each family in mind, our team will offer financial planning ideas and strategies to address
the client’s holistic financial picture, including estate, income tax, charitable, cash flow,
wealth transfer and family legacy objectives. Our team partners with our client’s other
advisors (CPA, Estate Attorney, Insurance broker, etc.) to ensure a coordinated effort of all
parties toward the client’s stated goals. Such services include various reports on specific
goals and objectives or general investment and/or planning recommendations, guidance
to outside assets.
Our specific services in preparing your plan may include:
• Review and clarification of your financial goals.
• Assessment of your overall financial position including cash flow, balance sheet,
investment strategy, risk management and estate planning.
• Creation of a unique plan for each goal you have including personal and business
real estate, education, retirement or financial independence, charitable giving,
estate planning, business succession and other personal goals.
• Development of a goal-oriented investment plan, with input from various advisors
to our clients around tax suggestions, asset allocation, expenses, risk and liquidity
factors for each goal. This includes IRA and qualified plans, taxable and trust
accounts that require special attention.
• Design of a risk management plan including risk tolerance, risk avoidance,
mitigation and transfer, including liquidity as well as various insurance and
possible company benefits.
• Crafting and implementation of, in conjunction with your estate and/or corporate
attorneys as tax advisor, an estate plan to provide for you and/or your heirs in the
event of an incapacity or death.
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A written evaluation of each client's initial situation or Financial Plan is available to the
client. The recommendations will not be reviewed nor updated, unless requested by the
client at which point a new Agreement between Client and Adviser may be executed.
Our Wrap Advisory Services
We do not offer a Wrap Fee Program.
Assets
As of December 31, 2025, we have $170,387,515 under discretionary management and $0
under non-discretionary management.
ITEM 5 - FEES AND COMPENSATION
Investment Management Fees and Compensation
Our maximum fee for our Portfolio Management service is 1.25% of the assets under
management. The fee is negotiable at the sole discretion of the firm. Our firm’s annualized
fees are billed on a pro-rata basis monthly in arrears based on the value of your account on
the last trading day of the month. Fees will be deducted from your managed account as we
do not offer direct billing.
In certain circumstances, our fees and the timing of the fee payments may be negotiated.
Our employees and their family related accounts are charged a reduced fee for our
services.
Unless otherwise instructed by the client, we will aggregate asset amounts in accounts
from your same household together to determine the advisory fee for all your accounts.
We would do this, for example, where we also service accounts on behalf of your minor
children, individual and joint accounts for a spouse, and/or other types of related accounts.
This consolidation practice is designed to allow you the benefit of an increased asset total,
which could cause your account(s) to be assessed a lower advisory fee.
The investment advisory Agreement may be terminated by the client within five (5)
business days of signing the Agreement without penalty or incurring any advisory
fees. After the 5 business days, either West End or you may terminate the management
agreement immediately upon written notice to the other party. The management fee will
be pro-rated to the date of termination, for the month in which the cancellation notice was
given and billed to your account. Upon termination, you are responsible for monitoring
the securities in your account, and we will have no further obligation to act or advise with
respect to those assets. In the event of client’s death or disability, West End will continue
management of the account until we are notified of client’s death or disability and given
alternative instructions by an authorized party.
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Financial Planning Fees
Our Financial Planning Fees are included in the Investment Management fees outlined
above.
Administrative Services Provided by ORION Advisor Services, LLC
We have contracted with ORION Advisor Services, LLC (referred to as “ORION”) to utilize its
technology platforms to support data reconciliation, performance reporting, fee
calculation and billing, research, client database maintenance, quarterly performance
evaluations, payable reports, web site administration, models, trading platforms, and other
functions related to the administrative tasks of managing client accounts. Due to this
arrangement, ORION will have access to client accounts, but ORION will not serve as an
investment advisor to our clients. West End Wealth Management and ORION are non-
affiliated companies. ORION charges our Firm an annual fee for each account administered
by ORION. Please note that the fee charged to the client will not increase due to the annual
fee West End Wealth Management pays to ORION, the annual fee is paid from the portion
of the management fee retained by West End Wealth Management.
There may be a possibility for price or account value discrepancies due to quarter-end
transactions in an account. Dividends or trade date settlements may occur and our third
party billing software may report a slight difference in account valuation at quarter end
compared to what is reported on your Statement from the Custodian. Our firm has the
ability to produce billing summaries, which can be provided upon request.
Additional Fees and Expenses:
In addition to the advisory fees paid to West End, clients may also incur certain charges
imposed by other third parties, such as broker-dealers, custodians, trust companies, banks
and other financial institutions (collectively “Financial Institutions”). These additional
charges may include securities brokerage commissions, transaction fees, custodial fees,
fees charged by the Independent TPMs, charges imposed directly by a mutual fund or ETF
in a client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees and
other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire
transfer and electronic fund fees, fees for trades executed away from custodian, and other
fees and taxes on brokerage accounts and securities transactions. West End’s brokerage
practices are described at length in Item 12, below. Neither our Firm nor its supervised
persons accept compensation for the sale of securities or other investment products.
Further, our firm does not share in any of these additional fees and expenses outlined
above.
OTHER ADDITIONAL FEES
Advisory Fees in General: Clients should note that similar advisory services may (or may
not) be available from other registered (or unregistered) investment advisers for similar or
lower fees.
West End Wealth Management, LLC – 8055 E. Tufts Ave., Suite 830, Denver, CO 80237
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Mutual Fund Fees: Mutual funds often offer multiple share classes with differing internal
fee and expense structures. West End endeavors to identify and utilize the share class with
the lowest internal fee and expense structure for each mutual fund. However, instances
occur in which the lowest cost share class is not used. These instances include but are not
limited to: Instances in which a certain custodian has a share class available that has a lower
internal fee and expense structure than is available for the same mutual fund at other
custodians. In such instances, West End will select the lowest cost share class available at
the custodian that holds your account even though a lower cost share class is available at
another custodian. Instances in which the custodian that holds your account offers others
a share class with a lower internal fee and expense structure than what is available to West
End at the same custodian. In such instances, West End will select the lowest cost share
class that the custodian makes available. This situation sometimes occurs because the
custodian places conditions on the availability of the lower cost share class that West End
has determined are not appropriate to accept due to additional costs imposed by said
conditions. Instances in which a share class with a lower internal fee and expense structure
becomes available after the share class you hold was purchased. West End periodically
monitors this circumstance. However, a share class with a lower internal fee may become
available between the time of your purchase and West End’s next review. Instances in which
a share class with a lower internal fee and expense structure than the share class you
currently hold is available at your custodian, but where West End is prevented by either the
custodian or the fund sponsor from converting to the lower cost share class. Additionally,
West End does not convert to a share class with a lower internal fee and expense structure
if the conversion will cause a taxable event or other expense/cost to you that negates the
advantage of the lower cost share class.
Non-Transaction Fee (NTF) Mutual Funds: When selecting investments for our clients’
portfolios we might choose mutual funds on your account custodian’s Non-Transaction Fee
(NTF) list. This means that your account custodian will not charge a transaction fee or
commission associated with the purchase or sale of the mutual fund. The mutual fund
companies that choose to participate in your custodian’s NTF fund program pay a fee to be
included in the NTF program. The fee that a mutual fund company pays to participate in
the program is ultimately borne by the owners of the mutual fund including clients of our
Firm. When we decide whether to choose a fund from your custodian’s NTF list or not, we
consider our expected holding period of the fund, the position size and the expense ratio
of the fund versus alternative funds. Depending on our analysis and future events, NTF
funds might not always be in your best interest.
Unmanaged Assets From time to time, a Client may decide to hold certain securities or
other property for which our Firm does not provide investment advisory services
("Unmanaged Assets") in the account(s) held at the Custodian or outside the Custodian.
Unmanaged assets will be shown on West End reports as unmanaged assets. It is the
client’s sole responsibility to verify the accuracy of the Unmanaged status of any and all
investments in their accounts and to notify West End in writing of any corrections or
adjustments that need to be made. Our Firm will have no duty, responsibility or liability
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whatsoever with respect to these assets, and therefore, our Firm will not charge an
investment advisory fee. However, if you have an account that solely contains Unmanaged
Assets, the Custodian may charge an account maintenance fee as disclosed in the
Custodian account paperwork executed by the Client. In all cases, it is the clients sole
responsibility to monitor, manage, and transact all Unmanaged Assets (securities and/or
accounts).
Regulatory Fees To facilitate the execution of trades, regulatory Trading Activity Fees (TAF)
are added to applicable sales transactions. The Securities and Exchange Commission (SEC)
regulatory fee is assessed on client accounts for sell transactions, and a FINRA fee is
assessed on client accounts for sell transactions, for certain covered securities. This fee is
not charged by our Firm but is accessed and collected by the custodian. The Custodian
that our Firm uses, is a FINRA member firm. These fees recover the costs incurred by the
SEC and FINRA, for supervising and regulating the securities markets and securities
professionals. The fee rates vary depending on the type of transaction and the size of that
transaction. For more information on the SEC and FINRA fees, please visit their websites:
www.sec.gov/fast-answers/answerssec31htm.html or www.finra.org/industry/trading-
activity-fee.
ITEM 6 - PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT
We do not charge advisory fees on a share of the capital appreciation of the funds or
securities in a client account (so-called performance-based fees) nor engage in side by side
management.
ITEM 7 - TYPES OF CLIENTS
We require a minimum aggregated family balance of $1,000,000. This minimum family
balance requirement would be required throughout the course of the client’s relationship
with our firm and may be negotiable depending on the client’s financial circumstance.
We have the following types of clients:
•
Individuals and High Net-Worth Individuals;
• Trusts, Estates or Charitable Organizations;
• Corporations, Limited Liability Companies and/or Other Business Types.
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
We build customized investment portfolios to achieve your specific financial goals. We use
fundamental, cyclical, and technical analysis together along with charting to make
investment choices.
Fundamental analysis is a method of evaluation which looks at a company's earnings,
expenses, assets and liabilities, among other statistics, to determine the value of that
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company. The value is then compared to the current price to determine whether to
purchase, sell or hold the company.
Cyclical analysis is a type of fundamental analysis that considers the performance of a
company through various stages of an economic cycle. A company may be more attractive
to purchase/sell during different times of an economic cycle.
Technical analysis is a method of evaluation that uses statistical data such as trading
volume or price changes. This process does not attempt to measure intrinsic value, but
instead uses charts and other tools to identify patterns that may suggest future
performance.
Charting involves identifying patterns in prices that may suggest future movements in the
security. These patterns are used to identify current trends and trend reversals to trigger
buy/sell signals.
At the center of portfolio construction is a well-studied theory called Modern Portfolio
Theory ("MPT"). MPT attempts to balance risk and return in your portfolio based on your
risk tolerance and financial goals.
Our Firm’s use of alternative assets is limited to publicly traded ETFs or ‘40 Act’ funds with
specific exposure in commodities, long/short strategies, real estate, and covered call
writing. Investments classified as "alternative investments" may include a broad range of
underlying assets including, but not limited to, hedge funds, private equity, venture capital,
and registered, publicly traded securities. Alternative investments are speculative, not
suitable for all clients and intended for only experienced and sophisticated investors who
are willing to bear the high risk of the investment, which can include: loss of all or a
substantial portion of the investment due to leveraging, short-selling, or other speculative
investment practices; lack of liquidity in that there may be no secondary market for the
fund and none expected to develop; volatility of returns; potential for restrictions on
transferring interest in the fund; potential lack of diversification and resulting higher risk
due to concentration of trading authority with a single advisor; absence of information
regarding valuations and pricing; potential for delays in tax reporting; less regulation and
typically higher fees than other investment options such as mutual funds. The SEC requires
investors be accredited to invest in these more speculative alternative investments.
Investing in a fund that concentrates its investments in a few holdings may involve
heightened risk and result in greater price volatility.
Our Firm also uses the following sources for our investment research and analysis: Spring
Tide Partners, LLC, financial newspapers and magazines, media outlets that report on
business, research materials prepared by others such as, Morningstar, Value Line, Schwab
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Research, Yahoo Finance, MarketWatch, various internet resources, and company press
releases and filings with the Securities and Exchange Commission.
At West End Wealth Management, we employ all these strategies along with our industry
experience to build customized portfolios to match your risk tolerance. However, there is
no guarantee that our efforts will be successful. General market conditions, prevailing
interest rates, performance of an industry, specific company or any number of other
factors can affect investment performance. You should be prepared to bear the risk of loss.
All investments may lose value including, among other things, loss of principal, loss of
earnings, which may include interest, dividends or other distributions, and possible loss of
future earnings.
Investors should be aware that accounts are subject to the following risks:
MARKET RISK - Even a long-term investment approach cannot guarantee a profit.
Economic, political, and issuer-specific events will cause the value of securities to
rise or fall. Because the value of investment portfolios will fluctuate, there is the
risk that you will lose money and your investment may be worth more or less upon
liquidation.
FOREIGN SECURITIES AND CURRENCY RISK - Investments in international and
emerging-market securities include exposure to risks such as currency fluctuations,
foreign taxes and regulations, and the potential for illiquid markets and political
instability.
CAPITALIZATION RISK - Small-cap and mid-cap companies may be hindered as a
result of limited resources or less diverse products or services Their stocks have
historically been more volatile than the stocks of larger, more established
companies.
INTEREST RATE RISK - In a rising rate environment, the value of fixed-income
securities generally declines, and the value of equity securities may be adversely
affected.
CREDIT RISK - Credit risk is the risk that the issuer of a security may be unable to make
interest payments and/or repay principal when due. A downgrade to an issuer’s
credit rating or a perceived change in an issuer’s financial strength may affect a
security’s value and thus, impact the fund’s performance.
LIQUIDITY RISK: Liquidity risk is the risk that there may be limited buyers for a
security when an investor wants to sell. Typically, this results in a discounted sale
price in order to attract a buyer.
West End Wealth Management, LLC – 8055 E. Tufts Ave., Suite 830, Denver, CO 80237
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DEFAULT RISK - A default occurs when an issuer fails to make payment on a principal
or interest payment.
EVENT RISK - Event risk is difficult to predict because it may involve natural disasters
such as earthquakes or hurricanes, as well as changes in circumstance from
regulators or political bodies.
POLITICAL RISK - Political risk is the risk associated with the laws of the country, or
to events that may occur there. Particular political events such as a government’s
change in policy could restrict the flow of capital.
DURATION RISK - Duration is a way to measure a bond's price sensitivity to changes
in interest rates. The duration of a bond is determined by its maturity date, coupon
rate, and call feature. Duration is a method to compare how different bonds will
react to interest rate changes. If a bond has a duration of five (5) years, it means
that the value of that security will decline by approximately five percent (5%) for
every one percent (1%) increase in interest rates.
REINVESTMENT RISK: Reinvestment risk is the risk that future interest and principal
payments may be reinvested at lower yields due to declining interest rates.
TAX RISK: For municipal bonds, depending on the client’s state of residence, the
interest earned on certain bonds may not be tax-exempt at the state level. Also,
changes in federal tax policy may impact the tax treatment of interest and capital
gains of an investment.
REGULATORY RISK: Market participants are subject to rules and regulations imposed
by one or more regulators. Changes to these rules and regulations could have an
adverse effect on the value of an investment.
CONCENTRATION RISK: The risk of amplified losses that may occur from having a
large portion of your holdings in a particular investment, asset class or market
segment relative to your overall portfolio.
SECURITIES LENDING RISK - Securities lending involves the risk that the fund loses
money because the borrower fails to return the securities in a timely manner or at
all. The fund could also lose money if the value of the collateral provided for loaned
securities, or the value of the investments made with the cash collateral, falls.
These events could also trigger adverse tax consequences for the fund.
EXCHANGE-TRADED FUNDS - ETFs face market-trading risks, including the potential
lack of an active market for shares, losses from trading in the secondary markets,
and disruption in the creation/redemption process of the ETF. Any of these factors
may lead to the fund’s shares trading at either a premium or a discount to its “net
asset value.”
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CYBERSECURITY RISK - In addition to the Material Investment Risks listed above,
investing involves various operational and “cybersecurity” risks. These risks include
both intentional and unintentional events at our firm or one of its third-party
counterparties or service providers, that may result in a loss or corruption of data,
result in the unauthorized release or other misuse of confidential information, and
generally compromise our Firm’s ability to conduct its business. A cybersecurity
breach may also result in a third-party obtaining unauthorized access to our clients’
information, including social security numbers, home addresses, account numbers,
account balances, and account holdings. Our Firm has established business
continuity plans and risk management systems designed to reduce the risks
associated with cybersecurity breaches. However, there are inherent limitations in
these plans and systems, including that certain risks may not have been identified,
in large part because different or unknown threats may emerge in the future. As
such, there is no guarantee that such efforts will succeed, especially because our
Firm does not directly control the cybersecurity systems of our third-party service
providers. There is also a risk that cybersecurity breaches may not be detected.
COMMODITIES RISK - Exposure to commodities in Adviser Clients accounts is in non-
physical form, such as ETFs or mutual funds, there are risks associated with the
movement in gold prices and the ability of the fund or trust manager to respond or
deal with those price movements. There also may be initial charges as well as
annual management fees associated with the fund or trust.
DIGITAL CURRENCY - Our Firm’s use of digital currency in a model portfolio is limited
only to publicly traded securities that passively or actively invest in digital currency
assets. The shares of certain Products are also publicly quoted on OTC Markets and
shares that have become unrestricted in accordance with the rules and regulations
of the SEC may be bought and sold throughout the day through any brokerage
account. Cryptocurrency (notably, bitcoin), often referred to as “virtual currency”,
“digital currency,” or “digital assets,” operates as a decentralized, peer-to-peer
financial exchange and value storage that is used like money. If deemed
appropriate, Clients may have exposure
to bitcoin, a cryptocurrency.
Cryptocurrency operates without central authority or banks and is not backed by
any government. Cryptocurrencies (i.e., bitcoin) may experience very high
volatility. Cryptocurrency is also not legal tender. Federal, state, or foreign
governments may restrict the use and exchange of cryptocurrency, and regulation
in the U.S. is still developing. The SEC has issued a public report stating U.S. federal
securities laws require treating some digital assets as securities. Cryptocurrency
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exchanges may stop operating or permanently shut down due to fraud, technical
glitches, hackers, or malware. Due to its relatively recent launch, bitcoin has a
limited trading history, making it difficult for investors to evaluate investments in
this cryptocurrency. It is possible that another entity could manipulate the
blockchain in a manner that is detrimental to the bitcoin network. Bitcoin
transactions are irreversible such that an improper transfer can only be undone by
the receiver of the bitcoin agreeing to return the bitcoin to the original sender.
Digital assets are highly dependent on their developers and there is no guarantee
that development will continue or that developers will not abandon a project with
little or no notice. Third parties may assert intellectual property claims relating to
the holding and transfer of digital assets, including cryptocurrencies, and their
source code. Any threatened action that reduces confidence in a network’s long-
term ability to hold and transfer cryptocurrency may affect investments in
cryptocurrencies. Investments in the Products are speculative investments that
involve high degrees of risk, including a partial or total loss of invested funds. The
shares of each Product are intended to reflect the price of the digital asset(s) held
by such Product (based on digital asset(s) per share), less such Product’s expenses
and other liabilities. Because each Product does not currently operate a
redemption program, there can be no assurance that the value of such Product’s
shares will reflect the value of the assets held by such Product, less such Product’s
expenses and other liabilities, and the shares of such Product, if traded on any
secondary market, may trade at a substantial premium over, or a substantial
discount to, the value of the assets held by such Product, less such Product’s
expenses and other liabilities, and such Product may be unable to meet its
investment objective.
OPTIONS AND OTHER DERIVATIVES RISK - Client portfolios may purchase or sell
options, warrants, equity-related swaps, or other derivatives that trade on an
exchange. Both the purchasing and selling of call and put options entail risks. An
investment in an option may be subject to greater fluctuation than an investment
in the underlying securities. The effectiveness of purchasing or selling stock index
options as a hedging technique depends upon the extent to which price
movements in the hedged portfolios correlate with price movements of the stock
index selected. Because the value of an index option depends upon movements in
the level of the index rather than the price of a particular security, whether a
portfolio realizes a gain or loss will depend upon movements in the level of security
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prices in securities markets generally rather than movements in the price of a
particular security.
ITEM 9 - DISCIPLINARY INFORMATION
Our firm does not have any legal, financial, or other “disciplinary” item to report.
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Other Affiliations
Management personnel of West End may engage in outside business activities. As such,
these individuals can receive separate, yet customary commission compensation resulting
from implementing product transactions on behalf of investment advisory Clients. Clients
are not under any obligation to engage these individuals when considering implementation
of these outside recommendations. The implementation of any or all recommendations is
solely at the discretion of the Client.
Our Firm does not have an application pending to register, as a futures commission
merchant, commodity pool operator, a commodity trading adviser, or an associated
person of the foregoing entities.
Neither our firm nor any of its management persons are registered or have an application
pending to register as a broker-dealer.
Clients should be aware that the ability to receive additional compensation by our Firm
and its management persons or employees creates conflicts of interest that impair the
objectivity of the Firm and these individuals when making advisory recommendations. Our
Firm endeavors at all times to put the interest of its clients first as part of our fiduciary duty
as a registered investment adviser; we take the following steps, among others to address
this conflict:
• we disclose to clients the existence of all material conflicts of interest, including the
potential for the Firm and our employees to earn compensation from advisory
clients in addition to the Firm's advisory fees.
• we disclose to clients that they have the right to decide to purchase recommended
investment products from our employees.
• we collect, maintain and document accurate, complete, and relevant client
background information, including the client’s financial goals, objectives, and
liquidity needs.
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•
the Firm conducts regular reviews of each client advisory account to verify that all
recommendations made to a client are in the best interest of the client’s needs and
circumstances.
• we require that our employees seek prior approval of any outside employment
activity so that we may ensure that any conflicts of interests in such activities are
properly addressed.
• we periodically monitor these outside employment activities to verify that any
conflicts of interest continue to be properly addressed by the Firm; and
• we educate our employees regarding the responsibilities of a fiduciary, including
the need for having a reasonable and independent basis for the investment advice
provided to clients.
ITEM 11 - CODE OF ETHICS PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS
AND PERSONAL TRADING
West End and persons associated with us are allowed to invest for their own accounts or
to invest in the same securities or other investments that we recommend or acquire for
your account and may engage in transactions that are the same as or different than
transactions recommended to or made for your account. This creates a conflict of interest.
We recognize the fiduciary responsibility to act in your best interest and have established
policies in this regard to mitigate any conflicts of interest.
We have developed and implemented a Code of Ethics that sets forth standards of conduct
expected of our advisory personnel to mitigate this conflict of interest. The Code of Ethics
addresses, among other things, personal trading, gifts, the prohibition against the use of
inside information and other situations where there is a possibility for conflicts of interest.
The Code of Ethics is designed to protect our clients to detect and deter misconduct,
educate personnel regarding the firm’s expectations and laws governing their conduct,
remind personnel that they are in a position of trust and must act with complete propriety
at all times, protect the reputation of West End, guard against violation of the securities
laws, and establish procedures for personnel to follow so that we may determine whether
their personnel are complying with the firm’s ethical principles.
We have established the following restrictions to ensure our firm’s fiduciary
responsibilities:
1. A director, officer or employee of West End shall not buy or sell any securities for
their personal portfolio(s) where their decision is substantially derived, in whole or
in part, by reason of his or her employment unless the information is also available
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to the investing public on reasonable inquiry. No director, officer or employee of
West End shall prefer his or her own interest to that of the advisory client.
2. We maintain a list of all securities holdings of anyone associated with this advisory
practice with access to advisory recommendations. These holdings are reviewed
on a regular basis by an appropriate officer/individual of .
3. We emphasize the unrestricted right of the client to decline to implement any
advice rendered, except in situations where we are granted discretionary authority
of the client’s account.
4. We emphasize the unrestricted right of the client to select and choose any
custodian he or she wishes.
5. We require that all affiliated individuals of our Firm must act in accordance with all
applicable Federal and State regulations governing registered investment advisory
practices.
6. Any affiliated individual of our Firm not in observance of the above may be subject
to termination.
You may request a complete copy of our Code by contacting us at the address, telephone
or email on the cover page of this Part 2; Attn: Chief Compliance Officer.
ITEM 12 - BROKERAGE PRACTICES
The Custodian and Brokers We Use
Investment Management Services
Clients must maintain assets in an account at a “qualified custodian,” generally a broker-
dealer or bank. We recommend that our clients use Charles Schwab & Co., Inc. Advisor
Services (“CS&Co”), a registered broker-dealer, member SIPC, as the qualified custodian.
We are independently owned and operated, and unaffiliated with CS&Co. CS&Co will hold
client assets in a brokerage account and buy and sell securities when we instruct them to.
While we recommend that clients use CS&Co as Custodian, client must decide whether to
do so and open accounts with CS&Co by entering into account agreements directly with
them. The Client opens the accounts with CS&Co. The accounts will always be held in the
name of the client and never in West End’s name.
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How We Select Custodians
We seek to recommend a custodian who will hold client assets and execute transactions
on terms that are, overall, most advantageous when compared to other available providers
and their services. We consider a wide range of factors, including, among others:
1. Combination of transaction execution services and asset custody services (generally
without a separate fee for custody)
2. Capability to execute, clear, and settle trades (buy and sell securities for client
accounts)
3. Capability to facilitate transfers and payments to and from accounts (wire transfers,
check requests, bill payment, etc.)
4. Breadth of available investment products (stocks, bonds, mutual funds, exchange-
traded funds [ETFs], etc.)
5. Availability of investment research and tools that assist us in making investment
decisions
6. Quality of services
7. Competitiveness of the price of those services (commission rates, other fees, etc.)
and willingness to negotiate the prices
8. Reputation, financial strength, and stability
9. Prior service to West End and our other clients
10. Availability of other products and services that benefit us, as discussed below (see
Products and Services Available to Us from CS&Co)
Client Brokerage and Custody Costs
For our clients’ accounts that CS&Co maintains, CS&Co generally does not charge
separately for custody services. However, CS&Co receives compensation by charging ticket
charges or other fees on trades that it executes or that settle into clients’ CS&Co accounts.
We have determined that having CS&Co execute most trades is consistent with our duty to
seek “best execution” of client trades. Best execution means the most favorable terms for
a transaction based on all relevant factors, including those listed above (see How We Select
Custodians).
Products and Services Available to Us from CS&Co
Schwab Advisor Services™ (formerly called Schwab Institutional®) is CS&Co’s business
serving independent investment advisory firms like us. They provide West End and our
clients with access to its institutional brokerage, trading, custody, reporting, and related
services, many of which are not typically available to CS&Co retail customers. CS&Co also
makes available various support services. Some of those services help us manage or
administer our clients’ accounts; others help us manage and grow our business. CS&Co’s
support services generally are available on an unsolicited basis (we do not have to request
them) and at no charge to us. These are considered soft dollar benefits because there is an
incentive to do business with CS&Co. This creates a conflict of interest. We recognize the
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fiduciary responsibility to always act in best interest of our clients and have established
policies in this regard to mitigate any conflicts of interest.
Following is a more detailed description of CS&Co’s support services:
Services That Benefit Our Clients
CS&Co’s institutional brokerage services include access to a broad range of investment
products, execution of securities transactions, and custody of client assets. The investment
products available through CS&Co include some to which we might not otherwise have
access or that would require a significantly higher minimum initial investment by our
clients. CS&Co’s services described in this paragraph generally benefit our clients and their
accounts.
Services That May Not Directly Benefit Our Clients
CS&Co also makes available to us other products and services that benefit us but may not
directly benefit our clients or their accounts. These products and services assist us in
managing and administering our clients’ accounts. They include investment research, both
CS&Co’s own and that of third parties. We may use this research to service all or a
substantial number of our clients’ accounts, including accounts not maintained at CS&Co.
In addition to investment research, CS&Co also makes available software and other
technology that:
1. Provide access to client account data (such as duplicate trade confirmations and
account statements)
2. Facilitate trade execution and allocate aggregated trade orders for multiple
client accounts
3. Provide pricing and other market data
4. Facilitate payment of our fees from our clients’ accounts
5. Assist with back-office functions, recordkeeping, and client reporting
Services That Generally Benefit Only Us
CS&Co also offers other services intended to help us manage and further develop our
business enterprise.
These services include:
1. Educational conferences and events
2. Consulting on technology, compliance, legal, and business needs
3. Publications and conferences on practice management and business succession
4. Access to employee benefits providers, human capital consultants, and
insurance providers
CS&Co may provide some of these services itself. In other cases, it will arrange for third-
party vendors to provide the services to us. CS&Co may also discount or waive its fees for
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some of these services or pay all or a part of a third party’s fees. CS&Co may also provide
us with other benefits, such as occasional business entertainment of our personnel.
Our Interest in CS&Co’s Services
The availability of these services from CS&Co benefits us because we do not have to
produce or purchase them. These services are not contingent upon us committing any
specific amount of business to CS&Co in trading commissions. We believe that our
recommendation of CS&Co as custodian is in the best interests of our clients.
Some of the products, services and other benefits provided by CS&Co benefit West End
and may not benefit our client accounts. Our recommendation or requirement that you
place assets in CS&Co's custody may be based in part on benefits CS&Co provides to us, or
our agreement to maintain certain Assets Under Management at CS&Co, and not solely on
the nature, cost or quality of custody and execution services provided by CS&Co.
We place trades for our clients' accounts subject to its duty to seek best execution and its
other fiduciary duties. CS&Co's execution quality may be different than other custodians.
Brokerage for Client Referrals
West End does not receive client referrals from any custodian or third party in exchange
for using that custodian or third party.
Aggregation and Allocation of Transactions
West End may aggregate transactions if we believe that aggregation is consistent with the
duty to seek best execution for our clients and is consistent with the disclosures made to
clients and terms defined in the client investment advisory agreement. No advisory client
will be favored over any other client, and each account that participates in an aggregated
order will participate at the average share price (per custodian) for all transactions in that
security on a given business day.
If we do not receive a complete fill for an aggregated order, we will allocate the order on
a pro-rata basis. If we determine that a pro-rata allocation is not appropriate under the
particular circumstances, we will base the allocation on other relevant factors, which may
include:
1. When only a small percentage of the order is executed, with respect to purchase
allocations, allocations may be given to accounts high in cash;
2. With respect to sale allocations, allocations may be given to accounts low in cash;
3. We may allocate shares to the account with the smallest order, or to the smallest
position, or to an account that is out of line with respect to security or sector
weightings, relative to other portfolios with similar mandates;
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4. We may allocate to one account when that account has limitations in its investment
guidelines prohibiting it from purchasing other securities that we expect to produce
similar investment results and that can be purchased by other accounts in the
block;
5. If an account reaches an investment guideline limit and cannot participate in an
allocation, we may reallocate shares to other accounts. For example, this may be
due to unforeseen changes in an account’s assets after an order is placed;
6. If a pro-rata allocation of a potential execution would result in a de minimis
allocation in one or more accounts, we may exclude the account(s) from the
allocation and disgorge any profits. Generally, de minimis allocations do not exceed
5% of the total allocation. Additionally, we may execute the transactions on a pro-
rata basis.
7. We will document the reasons for any deviation from a pro-rata allocation.
Trade Errors
We have implemented procedures designed to prevent trade errors; however, trade errors
in client accounts cannot always be avoided. Consistent with our fiduciary duty, it is our
policy to correct trade errors in a manner that is in the best interest of the client. In cases
where the client causes the trade error, the client will be responsible for any loss resulting
from the correction. Depending on the specific circumstances of the trade error, the client
may not be able to receive any gains generated as a result of the error correction. In all
situations where the client does not cause the trade error, the client will be made whole
and we will absorb any loss resulting from the trade error if the error was caused by the
firm. If the error is caused by the custodian, the custodian will be responsible for covering
all trade error costs. If an investment gain results from the correcting trade, the gain will
be donated to charity. We will never benefit or profit from trade errors.
We do not direct or permit you to direct to execute transaction through a specified
custodian. Additionally, we typically do not permit you to direct brokerage. We place
trades for your account subject to our duty to seek best execution and other fiduciary
duties.
ITEM 13 - REVIEW OF ACCOUNTS
Account Reviews and Reviewers – Investment Management Services
The underlying securities within the investment supervisory services are monitored on at
least a monthly basis. These reviews will be made by the firm’s investment advisor
representatives. An annual review with the client is usually conducted in person or by
telephone.
The purpose of all these reviews is to ensure that the investment plan continues to be
implemented in a manner which matches your objectives and risk tolerances. More-
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frequent reviews may be triggered by material changes in variables such as your individual
circumstances, or the market, political or economic environment. You are urged to notify
us of any changes in your personal circumstances.
Statements and Reports
Through an agreement with ORION, West End will have the ability to provide clients with
Performance/Position summary reports upon request. Reports may also be provided at
every client meeting. Communication to clients will be done on an as needed basis with a
minimum of 1 contact per calendar quarter.
The custodian for the individual client’s account will also provide clients with an account
statement at least monthly. You are urged to compare the reports provided by West End
against the account statements you receive directly from your account custodian.
ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION
We utilize the services of Charles Schwab & Co., Inc. (“Schwab”) a FINRA-registered broker-
dealer, member SIPC, as the qualified custodian. We are independently owned and operated
and not affiliated with Schwab. Schwab offers to independent investment advisers non-soft
dollar services which include custody of securities, trade execution, clearance and settlement
of transactions. There is no commitment made by us to Schwab or any other institution as
result of this arrangement.
Products and Services Available to Us from Schwab
Schwab Advisor Services (formerly called Schwab Institutional) is Schwab’s business serving
independent investment advisory firms like us. They provide us and our clients with access to
its institutional brokerage – trading, custody, reporting and related services – many of which
are not typically available to Schwab retail customers. Schwab also makes available various
support services. Some of those services help us manage or administer our clients’ accounts
while others help us manage and grow our business. Here is a more detailed description of
Schwab’s support services:
Services that Benefit You.
Schwab’s institutional brokerage services include access to a broad range of investment
products, execution of securities transactions, and custody of client assets. The investment
products available through Schwab include some to which we might not otherwise have
access or that would require a significantly higher minimum initial investment by our clients.
Schwab’s services described in this paragraph generally benefit you and your account.
Services that May Indirectly Benefit You.
Schwab also makes available to us other products and services that benefit us but may not
directly benefit you or your account. These products and services assist us in managing and
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administering our clients’ accounts. They include investment research, both Schwab’s own
and that of third parties. We may use this research to service all or some substantial number
of our clients’ accounts, including accounts not maintained at Schwab. In addition to
investment research, Schwab also makes available software and other technology that:
• provide access to client account data (such as duplicate trade confirmations and
•
account statements);
facilitate trade execution and allocate aggregated trade orders for multiple client
accounts;
facilitate payment of our fees from our clients’ accounts; and
• provide pricing and other market data;
•
• assist with back-office functions, recordkeeping and client reporting.
technology, compliance, legal, and business consulting;
Services that Generally Benefit Our Firm.
Schwab also offers other services intended to help us manage and further develop our
business enterprise. These services include:
• educational conferences and events
•
• publications and conferences on practice management and business succession; and
• access to employee benefits providers, human capital consultants and insurance
providers. Schwab may provide some of these services itself. In other cases, it will
arrange for third-party vendors to provide the services to us. Schwab may also
discount or waive its fees for some of these services or pay all or a part of a third
party’s fees. Schwab may also provide us with other benefits such as occasional
business entertainment of our personnel.
We do not use client brokerage commissions to obtain research or other products or
services. The aforementioned research and brokerage services are used by our firm to
manage accounts for which we have investment discretion. Without this arrangement, our
firm might be compelled to purchase the same or similar services at our own expense.
As a result of receiving these services, we have an incentive to continue to use or expand the
use of Schwab services. Our firm examined this conflict of interest when we chose to enter
into the relationship with Schwab and we have determined that the relationship is in the best
interest of our firm’s clients and satisfies our fiduciary obligations, including our duty to seek
best execution.
In seeking best execution, the determinative factor is not the lowest possible cost, but
into
whether the transaction represents the best qualitative execution, taking
consideration the full range of a broker-dealer’s services, including the value of research
provided, execution capability, commission rates, and responsiveness. Accordingly,
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although we will seek competitive rates, to the benefit of all clients, we may not necessarily
obtain the lowest possible commission rates for specific client account transactions.
Our Firm may be asked to recommend a financial professional, such as an attorney,
accountant, or mortgage broker. In such cases, our Firm does not receive any direct
compensation in return for any referrals made to individuals or firms in our professional
network. Clients must independently evaluate these firms or individuals before engaging
in business with them and clients have the right to choose any financial professional to
conduct business. Individuals and firms in our financial professional network may refer
clients to our Firm. Again, our Firm does not pay any direct compensation in return for any
referrals made to our Firm. Our Firm does recognize the fiduciary responsibility to place
your interests first and have established policies in this regard to mitigate any conflicts of
interest.
ITEM 15 - CUSTODY
Custody, as it applies to investment advisors, has been defined by regulators as having
access or control over client funds and/or securities. In other words, custody is not limited
to physically holding client funds and securities. If an investment advisor has the ability to
access or control client funds or securities, the investment advisor is deemed to have
custody and must ensure proper procedures are implemented.
West End is deemed to have custody of client funds and securities whenever West End is
given the authority to have fees deducted directly from client accounts. However, this is
the only form of custody West End will ever maintain. It should be noted that authorization
to trade in client accounts is not deemed by regulators to be custody.
For accounts in which West End has the authority to have fees deducted directly from
client accounts, the firm has established procedures to ensure all client funds and
securities are held at a qualified custodian in a separate account for each client under that
client’s name. Clients or an independent representative of the client will direct, in writing,
the establishment of all accounts and therefore are aware of the qualified custodian’s
name, address and the manner in which the funds or securities are maintained. Finally,
account statements are delivered directly from the qualified custodian to each client, or
the client’s independent representative, monthly. You should carefully review those
statements and are urged to compare the statements against reports received from West
End. When you have questions about your account statements, you should contact West
End or the qualified custodian preparing the statement.
Standing Letters of Authorization (“SLOA”)
Our Firm is deemed to have custody of clients’ funds or securities when you have standing
authorizations with their custodian to move money from your account to a third-party
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(“SLOA”) and, under that SLOA, it authorizes us to designate the amount or timing of
transfers with the custodian. The SEC has set forth a set of standards intended to protect
your assets in such situations, which we follow. We do not have a beneficial interest on
any of the accounts we are deemed to have Custody where SLOAs are on file. In addition,
account statements reflecting all activity on the account(s), are delivered directly from the
qualified custodian to each client or the client’s independent representative, at least
monthly. You should carefully review those statements and are urged to compare the
statements against reports received from us. When you have questions about your
account statements, you should contact us, your Adviser or the qualified custodian
preparing the statement.
However, the SEC would not recommend enforcement action under the Custody Rule against an
investment adviser if that adviser does not obtain a surprise examination where it acts pursuant to
such an arrangement under the following circumstances:
1. The client provides an instruction to the qualified custodian, in writing, that includes the client’s
signature, the third party’s name, and either the third party’s address or the third party’s
account number at a custodian to which the transfer should be directed.
2. The client authorizes the investment advisor, in writing, either on the qualified custodian’s
form or separately, to direct transfers to the third party either on a specified schedule or from
time to time.
3. The client’s qualified custodian performs appropriate verification of the instruction, such as a
signature review or other method to verify the client’s authorization and provides a transfer of
funds notice to the client promptly after each transfer.
4. The client has the ability to terminate or change the instruction to the client’s qualified
custodian.
5. The investment adviser has no authority or ability to designate or change the identity of the
third party, the address, or any other information about the third party contained in the client’s
instruction.
6. The investment adviser maintains records showing that the third-party is not a related party of
the investment adviser or located at the same address as the investment adviser.
7. The client’s qualified custodian sends the client, in writing, an initial notice confirming the
instruction and an annual notice reconfirming the instruction.
Clients will provide written authorization permitting the fees to be paid directly from their
account held by the qualified custodian. When fees are deducted from an account, West
End is responsible for calculating the fee and delivering instructions to the custodian.
ITEM 16 - INVESTMENT DISCRETION
For discretionary accounts, prior to engaging West End to provide investment advisory
services, you will enter a written Agreement with us granting the firm the authority to
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supervise and direct, on an on-going basis, investments in accordance with the client’s
investment objective and guidelines. In addition, you will need to execute additional
documents required by the Custodian to authorize and enable West End, in its sole
discretion, without prior consultation with or ratification by you, to purchase, sell or
exchange securities in and for your accounts. We are authorized, in our discretion and
without prior consultation with you to: (1) buy, sell, exchange and trade any stocks, bonds
or other securities or assets and (2) determine the amount of securities to be bought or
sold and (3) place orders with the custodian. Any limitations to such authority will be
communicated by you to us in writing.
The limitations on investment and brokerage discretion held by for you are:
1. For discretionary clients, we require that we be provided with authority to
determine which securities and the amounts of securities to be bought or sold.
2. Any limitations on this discretionary authority shall be included in this written
authority statement. You may change/amend these limitations as required. Such
amendments shall be submitted in writing.
ITEM 17 - VOTING CLIENT SECURITIES
West End will not vote proxies on your behalf. You are welcome to vote proxies or
designate an independent third-party at your own discretion. You designate proxy voting
authority in the custodial account documents. You must ensure that proxy materials are
sent directly to you or your assigned third party. We do not take action with respect to any
securities or other investments that become the subject of any legal proceedings, including
bankruptcies. Clients can contact our office with questions about a particular proxy
solicitation by phone at 720-576-6068.
ITEM 18 - FINANCIAL INFORMATION
We do not require or solicit prepayment of more than $1,200 in fees per client, six months
or more in advance. Therefore, we are not required to include a balance sheet for our
most recent fiscal year. We are not subject to a financial condition that is reasonably likely
to impair our ability to meet contractual commitments to clients. Finally, we have not been
the subject of a bankruptcy petition at any time.
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PRIVACY POLICY
Our Firm collects nonpublic personal information about Clients from information provided
on applications or other forms, as well as from information regarding Client transactions
with our Firm, our affiliates, or others. In accordance with Regulation S-P, our Firm does
not disclose any nonpublic personal information about current or former Clients to third
parties, except as permitted or required by law, or as necessary to service Client accounts.
Access to Client information is restricted to Firm personnel who require such information
to provide investment advisory services. Our Firm maintains physical, electronic, and
procedural safeguards designed to protect Client information in compliance with federal
standards and Regulation S-P. Our Firm provides a copy of its Privacy Policy to Clients at
the time of account opening, upon request, and annually if the Policy is amended.
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