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Tamarisk Financial, LLC
Doing Business As:
West Michigan Advisors
Tamarisk Family Office
Tamarisk Research
Form ADV Part 2A – Disclosure Brochure
Effective February 12, 2026
This Form ADV 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of
Tamarisk Financial, LLC (“Tamarisk” or the “Advisor”) dba West Michigan Advisors (“WMA”) Tamarisk Family
Office (“TFO”) and Tamarisk Research. If you have any questions about the contents of this Disclosure Brochure,
please contact Lonny Elfenbein, Chief Compliance Officer at 513-977-8330
Tamarisk Financial 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.
Additional information about Tamarisk Financial 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 with CRD# 312073.
Tamarisk Financial, LLC
301 Hoover Blvd. Suite 300 Holland MI 49423
Phone: (616) 820-1040 Fax: (616) 205-9250
https://tamariskfinancial.com
Tamarisk Financial, LLC
301 Hoover Blvd. Suite 300 Holland MI 49423
Phone: (616) 820-1040 Fax: (616) 205-9250
https://tamariskfinancial.com
Page 1
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 the Advisory
Persons of Tamarisk.
Tamarisk 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. Tamarisk encourages all
current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with
the Advisor.
Material Changes
Since our last annual update dated March 31, 2025 the following material changes have taken place:
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Item 1 - Cover Page has been updated to include the Tamarisk Research dba.
Item 4 - Advisory Services – Section A (Firm Information) has been updated to reflect Aaron Clark as
Managing Partner and Kevin Clark as Senior Partner.
Item 4 – Advisory Services – Section B (Advisory Services Offered) has been updated to reflect types of
clients and the addition of Services to Other Investment Advisers/Banks.
Item 5 – Fees and Compensation has been updated to reflect our affiliation with Tamarisk Capital
Management, an SEC-registered investment advisor.
Item 10 – Other Financial Industry Activities and Affiliations has been updated to reflect that Tamarisk is
under common ownership with Tamarisk Capital Management, an SEC-registered investment advisor.
Item 15 – Custody – This item has been updated to reflect that Tamarisk is deemed to have custody due
to its ability to pay bills or make other disbursements on behalf of its clients.
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in our 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 in the business practices of Tamarisk.
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 #312073. You
may also request a copy of this Disclosure Brochure at any time, by contacting the Advisor at (616) 820-1040.
Tamarisk Financial, LLC
301 Hoover Blvd. Suite 300 Holland MI 49423
Phone: (616) 820-1040 Fax: (616) 205-9250
https://tamariskfinancial.com
Page 2
Item 3 – Table of Contents
Item 2 – Material Changes ..................................................................................................................... 2
Item 3 – Table of Contents ..................................................................................................................... 3
Item 4 – Advisory Services ..................................................................................................................... 4
Item 5 – Fees and Compensation .......................................................................................................... 8
Item 6 – Performance-Based Fees and Side-By-Side Management ..................................................... 11
Item 7- Types of Clients A. Advisory Services Offered ........................................................................ 12
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis .......... 12
Item 9 – Disciplinary Information .......................................................................................................... 14
Item 10 – Other Financial Industry Activities and Affiliations ................................................................. 14
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .......... 15
Item 12 – Brokerage Practices ............................................................................................................. 15
Item 13 – Review of Accounts .............................................................................................................. 17
Item 14 – Client Referrals and Other Compensation ............................................................................ 17
Item 15 – Custody ................................................................................................................................ 18
Item 16 – Investment Discretion ........................................................................................................... 19
Item 17 – Voting Client Securities ........................................................................................................ 19
Item 18 – Financial Information ............................................................................................................ 19
Tamarisk Financial, LLC
301 Hoover Blvd. Suite 300 Holland MI 49423
Phone: (616) 820-1040 Fax: (616) 205-9250
https://tamariskfinancial.com
Page 3
Item 4 – Advisory Services
A. Firm Information
Tamarisk Financial, LLC (herein “Tamarisk” or the “Advisor”) is a registered investment advisor with the U.S.
Securities and Exchange Commission (“SEC”) doing business as West Michigan Advisors (herein “WMA”) and
Tamarisk Family Office (herein “TFO”). Tamarisk was organized as a limited liability company (“LLC”) under the
laws of the State of Michigan in December 2020. Tamarisk Financial is owned and operated by Kevin H. Clark
(Senior Partner), Aaron M. Clark (Managing Partner), Thomas S. Bosch (Partner) and Symphony Grove LLC
(Partner), a Michigan Limited Liability Company owned by the KDC Revocable Trust.
This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory
services provided by Tamarisk. For information regarding this Disclosure Brochure, please contact Lonny
Elfenbein, Chief Compliance Officer at (513) 977-8330.
B. Advisory Services Offered
Tamarisk offers investment advisory services through WMA and Tamarisk Family Office which are designed to
meet the needs of individuals, high net worth individuals, family offices, trusts, estates, charitable organizations,
investment advisors, banks and other businesses (each referred to as a “Client”). Unless noted by agreement the
Advisor serves as a fiduciary to Clients, as defined under 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. Tamarisk’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.
Investment Management Services
Tamarisk provides customized investment management solutions for its Clients through its dba WMA. This is
achieved through continuous personal Client contact and interaction while providing discretionary investment
management and related advisory services. WMA works with each Client to identify their investment goals and
objectives as well as risk tolerance and financial situation in order to create an investment strategy. WMA will
construct Client portfolios utilizing exchange-traded funds (“ETFs”), mutual funds, individual equities, and/or
individual bonds. The Advisor also includes alternative investment vehicles and other types of investments, as
appropriate, to meet the needs of its Clients. WMA will may retain the Client’s legacy investments based on
portfolio fit, tax implications and/or other factors.
WMA’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate
investments that have been held for less than one year to meet the objectives of the Client or due to market
conditions. WMA 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.
WMA evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence
process. WMA may recommend, on occasion, redistributing investment allocations to diversify the portfolio. WMA
may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend
employing cash positions as a possible hedge against market movement. WMA may recommend selling positions
for reasons that 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 overweighting 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.
Tamarisk Financial, LLC
301 Hoover Blvd. Suite 300 Holland MI 49423
Phone: (616) 820-1040 Fax: (616) 205-9250
https://tamariskfinancial.com
Page 4
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over
the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account
to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or
increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a
retirement account to an account managed by the Advisor.
At no time will the Advisor accept or maintain custody of a Client’s funds or securities, except for the limited
authority as detailed in Item 15 – Custody. All Client assets will be managed within their designated brokerage
account or pension account, pursuant to the Client investment advisory agreement.
Use of Independent Managers - WMA may recommend that a Client utilize one or more unaffiliated investment
managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment
portfolio. In such instances, the Client may be required to authorize and enter into an advisory agreement with the
Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide investment
management and related services. The Advisor may also assist in the development of the initial policy
recommendations and managing the ongoing Client relationship. The Advisor will perform initial and ongoing
oversight and due diligence over the selected Independent Manager[s] to ensure the Independent Managers’
strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. The
Client, prior to entering into an agreement with unaffiliated investment manager[s] or investment platform[s], will be
provided with the Independent Manager's Form ADV 2A (or a brochure that makes the appropriate disclosures).
Financial Planning Services
WMA will typically provide a variety of financial planning services to Clients, pursuant to a separate agreement
between the Advisor and the Client, or alternatively included in the overall wealth management engagement. The
Advisor, at its sole discretion, may waive its financial planning fee. Services are offered in several areas of a
Client’s financial situation, depending on their goals and objectives.
Generally, such financial planning services will involve preparing a financial plan or rendering a 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, estate planning, personal savings,
education savings, insurance needs, and other areas of a Client’s financial situation. Services are defined as
mutually agreed in the Client engagement.
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.
Financial planning and consulting recommendations poses 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 Client 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.
Tamarisk Financial, LLC
301 Hoover Blvd. Suite 300 Holland MI 49423
Phone: (616) 820-1040 Fax: (616) 205-9250
https://tamariskfinancial.com
Page 5
WMA may also refer Clients to an accountant, attorney or other 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.
Retirement Plan Advisory Services
WMA provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company
(the “Plan Sponsors”) The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in
meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs
of the Plan and Plan Sponsor. Services generally include:
• Plan Participant Enrollment and Education Tracking
• Ongoing Investment Recommendation and Assistance
• Ongoing Investment Management (ERISA 3(38))
• Ongoing Investment Recommendations (ERISA 3(21))
These services are provided by WMA 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 WMA’s fiduciary status, the specific services to be rendered and all direct and
indirect compensation the Advisor reasonably expects under the agreement.
Family Office Services
Tamarisk offers the following family office services to high net worth individuals, investment limited partnerships,
trusts, estates, charitable organizations, corporations, family offices and business entities through its Tamarisk
Family Office DBA (“TFO”).
Financial Planning Services
TFO will typically provide a variety of financial planning services to Clients, pursuant to a separate agreement
between the Advisor and the Client, or included in the overall wealth management engagement. The Advisor, at its
sole discretion, may waive its financial planning fee. Services are offered in several areas of a Client’s financial
situation, depending on their goals and objectives.
Generally, such financial planning services will involve preparing a financial plan or rendering a 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, estate 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.
TFO works with each client to gather all relevant information from other professional advisers; accountants,
attorneys, insurers, etc. to assemble a client’s financial profile so TFO can make well-informed recommendations
that are suitable and in the client’s best interest. TFO acts as a project manager to coordinate the activities of the
other professional advisers developing the family financial plan and to maintain it into the future with regular reviews
and updates.
Tamarisk Financial, LLC
301 Hoover Blvd. Suite 300 Holland MI 49423
Phone: (616) 820-1040 Fax: (616) 205-9250
https://tamariskfinancial.com
Page 6
Financial planning and consulting recommendations poses a potential conflict between the interests of TFO and
the interests of the Client. For example, the Advisor has an incentive to recommend that Client engage WMA for
investment management services or to increase the level of investment assets with WMA, as it would increase the
amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by
TFO or maintain an ongoing relationship with the TFO. If the Client elects to act on any of the recommendations
made by the TFO, the Client is under no obligation to implement the transaction through the Advisor.
Family Office Services and Special Projects
TFO provides Family Office services such as consulting, expense management, bill pay, concierge services,
philanthropic management and property management These services do not involve any type of investment advisory
services or financial planning services.
Services to Other Investment Advisers/Banks
Tamarisk Financial provides model trade signals, research and other services to investment adviser clients through its
d.b.a Tamarisk Research. The Investment Committee is responsible for ensuring that the provision of such services
to investment adviser clients is suitable, pursuant to the agreement between Tamarisk Research and the specific
investment adviser client.
C. Client Account Management
Prior to engaging with the Advisor to provide investment advisory, financial planning, or family office services, each
Client is required to enter into one or more service agreements with the Advisor that define the terms, conditions,
authority and responsibilities of the Advisor and the Client. Engagements may be ongoing, or limited, as mutually
agreed between Client and Advisor. These services may include:
Establishing an Investment Strategy – WMA, in connection with the Client, will develop a strategy that
seeks to achieve the Client’s investment goals and objectives.
Asset Allocation – WMA 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 – WMA will develop a portfolio for the Client that is intended to meet the stated
goals and objectives of the Client.
Investment Management and Supervision – WMA will provide investment management and ongoing
oversight of the Client’s portfolio.
Financial Planning Services – WMA will provide a variety of financial planning services to its clients on
either a comprehensive or limited basis.
Family Office Financial Planning Services – TFO will provide individualized planning services for its
clients on a comprehensive or limited basis.
Family Office Services and Special Projects – TFO will provide a variety of family office services for its
clients.
D. Wrap Fee Programs
Tamarisk does not manage or place Client assets into a wrap fee program.
E. Assets Under Management
Tamarisk Financial, LLC
301 Hoover Blvd. Suite 300 Holland MI 49423
Phone: (616) 820-1040 Fax: (616) 205-9250
https://tamariskfinancial.com
Page 7
As of December 31, 2025, Tamarisk managed $781,324,025 in Client assets, all of which are managed on a
discretionary basis.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client shall sign one or more agreements that detail the responsibilities of Tamarisk and the Client.
A. Fees for Advisory Services
Investment Management Services
Investment advisory fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the
investment advisory agreement. Investment advisory fees are computed using the fee schedule in the Client
Agreement and the market value of assets under management on the last day of the previous quarter, including
cash, accrued interest, accrued dividends, and securities purchased on margin, using the following guidelines:
(a) cash and cash equivalents are valued at their dollar value; (b) marketable securities are valued at the current
market price provided by the custodian; and (c) private investment funds and securities for which there is no
active market are valued at the most recent valuation provided by the sponsor or the initial investment cost, as
applicable. Investment advisory fees range from 0.25% to 2.50% based on several factors, including, but not
limited to: the services offered to the Client, the complexity of the services to be provided, the level of Client
assets managed by the Advisor, and/or the overall relationship with the Advisor.
The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the
end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into
consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by
WMA will be independently valued by the Custodian.
Clients may make additions to and withdrawals from their account[s] at any time, subject to WMA’s right to
terminate an account. Additions may be in cash or securities provided that WMA reserves the right to liquidate any
transferred securities or decline to accept particular securities into a Client’s account[s]. Clients may withdraw
account assets on notice to WMA, subject to the usual and customary securities settlement procedures. However,
WMA designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of
a Client’s investment objectives. WMA may consult with its Clients about the options and ramifications of
transferring securities. However, Clients are advised that when transferred securities are liquidated, they may be
subject to transaction fees, fees assessed at the mutual fund level (i.e. contingent deferred sales charge) and/or
tax ramifications.
Use of Independent Managers
For Clients referred by the Advisor to an Independent Manager, the Client’s fee may be separately billed or deducted
from the Client’s account[s] by the Independent Manager, as mutually agreed.
Financial Planning Services
WMA typically includes financial planning services as part of a wealth management engagement and fee. WMA also
offers its services on a stand-alone basis at hourly rate beginning at $250/hour or a fixed engagement fee. Fees
may be negotiable based on the nature and complexity of the services to be provided and the overall relationship
with the Advisor. Fixed fee engagements are negotiated based on the expected number of hours to complete an
engagement at the Advisor’s hourly rate. An estimate for total hours and/or total costs will be provided to the Client
prior to engaging for these services.
Retirement Plan Advisory Services Fees
Fees for retirement plan advisory services are charged an annual asset-based fee of up to 2.50%, in advance of
each calendar quarter, pursuant to the terms of the agreement. Retirement plan fees are based on the market value
Tamarisk Financial, LLC
301 Hoover Blvd. Suite 300 Holland MI 49423
Phone: (616) 820-1040 Fax: (616) 205-9250
https://tamariskfinancial.com
Page 8
of assets under management at the end of the prior calendar quarter. Fees may be negotiable depending on the
size and complexity of the Plan.
Tamarisk Family Office Fees
The specific manner in which fees are charged by TFO are established in each respective Agreement. Depending
on the terms of the Agreement, TFO may agree to provide its Financial Planning or Family Office/Special Project
services on either an hourly and/or fixed fee basis, or on the basis of assets under management. Generally TFO
requires a retainer for its family office services (estimated hourly or fixed). TFO’s family office fees are negotiable
but generally range from $10,000 to $500,000 on an annual fixed fee basis, $250 to $800 on an hourly rate basis
and/or .25% to 1.5% of assets under advisement depending upon the level and scope of the services and the
professional rendering the services. Calculations for the initial fee/retainer may be estimates based on the
projected assets under management or on projected time and materials required for certain non-investment related
family office services, such as tax return preparation.
Tamarisk Capital Management
When the Advisor recommends the use of pooled investment vehicles managed by Tamarisk Capital Management,
an SEC registered investment adviser under common ownership with Tamarisk, a conflict of interest exists because
Tamarisk receives a financial benefit for investments in these pooled investment vehicles. The conflict is mitigated,
however, because you are under no obligation, contractually or otherwise, to engage with Tamarisk Capital
Management.
B. Fee Billing
Investment Management Services
Investment advisory fees will be calculated by the Advisor or its delegate and deducted from the Client’s account[s] at
the Custodian. The Advisor 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. The amount due is calculated by applying the
quarterly rate (annual rate divided by 4) to the total assets under management with WMA at the end of the prior
quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the
investment advisory fee. It is the responsibility of the Client to verify the accuracy of these fees as listed on the
Custodian’s brokerage statement as the Custodian does not assume this responsibility. Clients will be provided with
a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. Clients
provide written authorization permitting advisory fees to be deducted by WMA to be paid directly from their accounts
held by the Custodian as part of the investment advisory agreement and separate account forms provided by the
Custodian.
Use of Independent Managers
For Clients referred by the Advisor to an Independent Manager, the Client’s fee may be separately billed or deducted
from the Client’s account[s] with the respective manager and a portion of the investment advisory fee may be
provided to WMA, as mutually agreed.
Financial Planning Services
One-time financial planning engagements require an advance payment of fees up to 50% of the expected total
cost of the engagement. Upon completion of the engagement deliverable[s], the remaining balance of the
engagement fees shall be invoiced by the Advisor and are due upon receipt of the invoice. Fees are typically
paid via check however clients with assets managed by WMA may elect to have these fees deducted from their
custodial accounts.
Retirement Plan Advisory Services Fees
Tamarisk Financial, LLC
301 Hoover Blvd. Suite 300 Holland MI 49423
Phone: (616) 820-1040 Fax: (616) 205-9250
https://tamariskfinancial.com
Page 9
WMA is compensated for its services at the beginning of the quarter before advisory services are rendered. 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.
Tamarisk Family Office Fees
Clients engaging with TFO on a fixed annual fee or percentage of assets under management basis will be billed for
its services at the beginning of each month based on the annual fee and terms of the Agreement. Fixed annual fees
are invoiced by the Advisor and are due upon receipt of the invoice or as otherwise agreed upon between the Client
and TFO. Clients engaging with TFO on a percentage of assets under advisement basis will be billed for its
services per the terms of the Investment Advisory agreement with WMA.
Clients engaging with TFO on an hourly basis generally require an advance payment of fees of up to 50% of the
expected cost of the engagement. Upon completion of the engagement the remaining balance of the engagement
fees shall be invoiced by the Advisor and are due upon receipt of the invoice.
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], such as securities transaction fees, wire transfer fees, fees for trades executed away from
the Custodian (if applicable) and other fees.
In addition, all fees paid to WMA for investment advisory services 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 WMA, but would not
receive the services provided by WMA which are designed, among other things, to assist the Client in determining
which products or 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 WMA to fully understand the total
fees to be paid.
D. Advance Payment of Fees and Termination
Investment Management Services
WMA is compensated for its services in advance of the quarter in which investment advisory services are rendered.
Either party may request to terminate the investment advisory agreement with WMA, at any time, by providing
advance written notice to the other party. The Client may also terminate the investment advisory agreement within
five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the
Client will incur charges for bona fide advisory services rendered to the point of termination the Advisor will promptly
refund any unearned, prepaid advisory fees.
Use of Independent Managers
In the event that a Client should wish to terminate their relationship with the Independent Manager, the terms for
termination will be set forth in the respective agreements between the Client and that Independent Manager. WMA
will assist the Client with the termination and transition as appropriate.
Financial Planning Services
WMA requires an advance deposit as described above. Either party may terminate the financial planning
agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the
financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the
Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of
termination and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any
Tamarisk Financial, LLC
301 Hoover Blvd. Suite 300 Holland MI 49423
Phone: (616) 820-1040 Fax: (616) 205-9250
https://tamariskfinancial.com
Page 10
unearned, prepaid fees based on the number of hours worked by the Advisor or the percentage of the engagement
completed, as applicable.
Retirement Plan Advisory Services Fees
WMA is compensated for its services in advance of the quarter in which retirement plan advisory services are
rendered. Either party may request to terminate their services with WMA in whole or in part, by providing advance
written notice to the other party. The Advisor will refund any unearned, prepaid investment advisory fees from the
effective date of termination to the end of the quarter. The Client’s retirement plan services agreement with the
Advisor is non-transferable without the Client’s written approval.
Tamarisk Family Office Services
TFO is compensated for its fixed fee services in advance of the quarter in which Family Office services are
rendered. Either party may request to terminate the investment advisory agreement with TFO, at any time, by
providing advance written notice to the other party. The Client may also terminate the investment advisory
agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-
day period, the Advisor will promptly refund any unearned, prepaid advisory fees.
Clients engaging with TFO on an hourly basis generally require an advance payment of fees of up to 50% of the
expected cost of the engagement. Either party may request to terminate the investment advisory agreement with
TFO, at any time, by providing advance written notice to the other party. The Client may also terminate the
investment advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the
Client. After the five-day period, the Client will incur charges for bona fide Family Office services rendered to the
point of termination and such fees will be due and payable by the Client. Upon termination, the Advisor will promptly
refund any unearned, prepaid advisory fees.
E. Compensation for Sales of Securities
Tamarisk does not buy or sell securities to earn securities transaction fees and does not receive any compensation
for securities transactions in any Client account, other than the investment advisory fees noted above.
Certain Advisory Persons are also Registered Representatives of Level Four Financial, LLC. (“Level Four”). Level
Four is a registered broker-dealer (CRD No. 13905), member FINRA, SIPC. In one’s separate capacity as a
Registered Representative of Level Four, an Advisory Person will implement securities transactions through Level
Four and not through Tamarisk. In such instances, the 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 the Advisory Person in one’s capacity as a Registered
Representative is separate and in addition to the Advisor’s fees. This practice presents a conflict of interest
because the Advisory Person who is a Registered Representative has an incentive to effect securities
transactions for the purpose of generating commissions rather than solely based on the Client. Clients are not
obligated to implement any recommendation provided by the Advisor nor its Advisory Persons. Neither the
Advisor nor Advisory Persons will earn ongoing investment advisory fees in connection with any products or
services implemented in the Advisory Person’s separate capacity as a Registered Representative. Please see
Item 10 below.
Item 6 – Performance-Based Fees and Side-By-Side Management
WMA does not charge performance-based fees for its investment advisory services. The fees charged by WMA
are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by
any Client. WMA 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.
Tamarisk Financial, LLC
301 Hoover Blvd. Suite 300 Holland MI 49423
Phone: (616) 820-1040 Fax: (616) 205-9250
https://tamariskfinancial.com
Page 11
Item 7- Types of Clients
A. Advisory Services Offered
WMA offers investment advisory services designed to meet the needs of individuals, high net worth individuals,
family offices, trusts, estates, charitable organizations and businesses. WMA does not impose a minimum account
or relationship size.
TFO offers investment advisory services designed to meet the needs of high net worth individuals, trusts, estates,
charitable organizations, family offices and businesses.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
WMA primarily employs fundamental and technical analysis methods in developing investment strategies for its
Clients. Research and analysis from WMA are derived from numerous sources, including financial media
companies, third-party research materials, Internet sources, and review of company activities, including annual
reports, prospectuses, press releases and research prepared by others.
Fundamental analysis utilizes economic and business indicators as investment selection criteria. These criteria are
generally ratios and trends 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 value
discounted by the market. While this type of analysis helps the Advisor 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”.
Technical analysis involves the analysis of past market data rather than specific company data in determining the
recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and
trends, which may be based on investor sentiment rather than the fundamentals of the company. 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 WMA will be able to accurately predict such a reoccurrence.
As noted above, WMA generally employs a long-term investment strategy for its Clients, as consistent with their
financial goals. WMA 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, WMA may also
buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the
fundamentals of the security, sector or asset class.
B. 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. WMA 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.
While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the
investment will increase in value. Assets meeting the investment criteria utilized in these methods of 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.
Tamarisk Financial, LLC
301 Hoover Blvd. Suite 300 Holland MI 49423
Phone: (616) 820-1040 Fax: (616) 205-9250
https://tamariskfinancial.com
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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. 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.
The risks associated with a particular strategy are provided to each Client in advance of investing a Client’s
account[s]. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio
construction process. Following are some of the risks associated with the Advisor’s investment approach:
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 an ETF is traded actively and a liquidity risk if the ETF has 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.
Bond ETFs – Bond ETFs are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk
that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to
maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be
reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and
inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4)
credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the
company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating
agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to
repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as desired if there is no
readily available market for the bond.
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.
Private Fund Risks - A private fund is an investment vehicle that pools capital from a number of investors and
invests in securities and other instruments. In almost all cases, a private fund is a private investment vehicle that
is typically not registered under federal or state securities laws. So that private funds do not have to register
under these laws, issuers make the funds available only to certain sophisticated or accredited investors and
cannot be offered or sold to the general public. Private funds are generally smaller than mutual funds because
they are often limited to a small number of investors and have a more limited number of eligible investors. Many
but not all private funds use leverage as part of their investment strategies. Private funds management fees
typically include a base management fee along with a performance component. In many cases, the fund’s
managers may become “partners” with their clients by making personal investments of their own assets in the
fund. Most private funds offer their securities by providing an offering memorandum or private placement
memorandum, known as “PPM” for short.
Tamarisk Financial, LLC
301 Hoover Blvd. Suite 300 Holland MI 49423
Phone: (616) 820-1040 Fax: (616) 205-9250
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The PPM covers important information for investors and investors should review this document carefully and
should consider conducting additional due diligence before investing in the private fund. The primary risks of
private funds include the following: (a) Private funds do not sell publicly and are therefore illiquid. An investor
may not be able to exit a private fund or sell its interests in the fund before the fund closes. And (b) Private funds
are subject to various other risks, including risks associated with the types of securities that the private fund
invests in or the type of business issuing the private placement.
The risks associated with a particular strategy are provided to each Client in advance of investing Client
accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio
construction process. 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.
Item 9 – Disciplinary Information
There are no legal, regulatory or disciplinary events involving Tamarisk or its management persons.
Tamarisk values the trust Clients place in the Advisor. The Advisor encourages Client to perform the requisite
due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor and its
Advisors Persons are on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by
searching with the Advisor’s firm name or CRD# 312073.
Item 10 – Other Financial Industry Activities and Affiliations
Broker-Dealer Affiliation
As noted in Item 5, certain Advisory Persons are also Registered Representatives of Level Four. In one’s separate
capacity as a Registered Representative, an Advisory Person will receive commissions for the implementation of
recommendations for commissionable transactions. Clients are not obligated to implement any recommendation
provided by an Advisory Person. Neither the Advisor nor its 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.
Insurance Recommendations
The Advisor also serves as a licensed insurance agency, and as such, may offer insurance products on a
commissionable basis. The Advisor shall generally introduce the Client to an unaffiliated insurance agency to
manage the insurance process. The Advisor shall receive a portion of the insurance commission earned by the
unaffiliated insurance agency. No Client shall be under any obligation to purchase any insurance products from the
Advisor or such introduced insurance agency. The recommendation by an Advisory Person that a Client purchase
an insurance product presents a conflict of interest, as the receipt of commissions may provide an incentive to
recommend insurance products based on commissions to be received, rather than based on a particular Client’s
need. Clients are reminded that they remain free to purchase insurance products through other insurance agencies.
Use of Independent Managers
As noted in Item 4, the Advisor may select Independent Managers to assist with the implementation of a Client’s
investment strategy. In such arrangements, the Advisor will receive a portion of the investment advisory fees
collected by the Independent Manager from the Client.
Arrangements with Affiliated Entities
The Advisor is affiliated with Tamarisk Capital Management through common control and ownership. Tamarisk
Capital Management is the Investment Advisor managing the Defender Risk Adaptive 500 ETF (Exchange
Traded Fund), a pooled investment vehicle in which you may be solicited to invest. The Advisor may recommend
Tamarisk Financial, LLC
301 Hoover Blvd. Suite 300 Holland MI 49423
Phone: (616) 820-1040 Fax: (616) 205-9250
https://tamariskfinancial.com
Page 14
the use of the Defender Risk Adaptive 500 ETF if appropriate and suitable for your needs. The Advisor’s
advisory services are separate and distinct from the fees paid to our affiliate for their services.
The use of the Defender Risk Adaptive 500 ETF does present a conflict of interest because the Advisor may have
a financial incentive to recommend the fund being managed by our affiliate. While we believe that compensation
charged by our affiliate is competitive, such compensation may be higher than fees charged by other firms
providing the same or similar services. You are under no obligation to use our affiliates’ services and may obtain
comparable services and/or lower fees through other firms.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
Tamarisk has implemented a Code of Ethics that defines the Advisor’s fiduciary commitment to each Client. This
Code of Ethics applies to all persons associated with Tamarisk (“Supervised Persons”). The Code of Ethics was
developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to the
Client. Tamarisk and its personnel owe a duty of loyalty, fairness and good faith towards each Client. It is the
obligation of Tamarisk 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 of Ethics covers a range of topics that address employee
ethics and conflicts of interest. To request a copy of the Code of Ethics, please contact the Advisor at (616) 820-
1040.
B. Personal Trading with Material Interest
Tamarisk allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Tamarisk 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. Tamarisk does not have a
material interest in any securities traded in Client accounts.
C. Personal Trading in Same Securities as Clients
Tamarisk allows Supervised Persons to purchase or sale of the same securities that may be recommended to and
purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients
presents a potential conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through
policies and procedures. As noted above, the Advisor has adopted a Code of Ethics, which addresses insider
trading (material non-public information controls) and personal securities reporting procedures. When trading for
personal accounts, Supervised Persons of Tamarisk have a conflict of interest if trading in the same securities. The
fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more
advantageous terms than Client trades, or by trading based on material non-public information. This risk is
mitigated by Tamarisk requiring reporting of personal securities trades by its employees for review by the Chief
Compliance Officer (“CCO”). The Advisor has also adopted written policies and procedures to detect the misuse of
material, non-public information.
D. Personal Trading at Same Time as Client
While Tamarisk allows Supervised Persons to purchase or sale of the same securities that may be recommended
to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterward. At
no time will Tamarisk, or any Supervised Person of Tamarisk, transact in any security to the detriment of
any Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
Tamarisk Financial, LLC
301 Hoover Blvd. Suite 300 Holland MI 49423
Phone: (616) 820-1040 Fax: (616) 205-9250
https://tamariskfinancial.com
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WMA typically 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 WMA to direct trades to this Custodian as agreed in the investment advisory agreement.
Further, WMA does not have the discretionary authority to negotiate commissions on behalf of our Clients on a
trade-by-trade basis. For certain Clients, the Advisor may be granted the discretion to select the broker-dealer for
the purchase or sale of fixed income instruments traded away from the Advisor’s Custodian.
Where WMA does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to
Clients for custody and executing services. Clients are not obligated to use the Custodian recommended by the
Advisor and will not incur any extra fee or cost associated with using a custodian not recommended by WMA.
However, if the recommended Custodian is not engaged, WMA may be limited in the services it can provide
comparable to other clients. WMA may recommend the Custodian based on criteria such as, but not limited to,
reasonableness of commissions charged to the Client, services made available to the Client, and its overall
reputation. WMA will generally recommend that Clients establish their account[s] at Raymond James & Associates,
Inc. (“Raymond James”) or Charles Schwab & Co., Inc. (“Schwab”). Raymond James and Schwab (collectively the
“Custodians”) serve as the Client’s “qualified custodian.” WMA maintains an institutional relationship with Raymond
James and Schwab, whereby the Advisor receives economic benefits from Raymond James and Schwab. Please
see Item 14 below.
Factors which the Advisor considers in recommending Raymond James or Schwab to Clients include their
respective financial strength, reputation, execution, pricing, and research service. The commissions and/or
transaction fees charged by Raymond James and Schwab may be higher or lower than those charged by other
financial institutions. The Advisor maintains an institutional relationship with Raymond James and Schwab,
whereby the Advisor receives certain Benefits. Please see Item 14 below.
Following are additional details regarding the brokerage practices of the Advisor:
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. Tamarisk does not participate in soft dollar programs sponsored or offered by any broker-
dealer. However, the Advisor does receive certain economic benefits from Raymond James. Please see
Item 14 below.
2. Brokerage Referrals - Tamarisk does not receive any compensation from any third party in connection with
the recommendation for establishing a brokerage account.
3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Tamarisk will place trades
within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded
within their respective account[s]. 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]). In selecting the Custodian, Tamarisk 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 designated Custodian.
B. Trade Errors
WMA’s goal is to execute trades seamlessly and in the best interests of the client. In the event a trade error occurs,
WMA endeavors to identify the error in a timely manner, correct the error so that the client’s account is in the position
it would have been had the error not occurred, and, after evaluating the error, assess what action(s) might be necessary
to prevent a recurrence of similar errors in the future.
Tamarisk Financial, LLC
301 Hoover Blvd. Suite 300 Holland MI 49423
Phone: (616) 820-1040 Fax: (616) 205-9250
https://tamariskfinancial.com
Page 16
Trade errors generally are corrected through the use of a “trade error” account or similar account at Raymond James,
Schwab, or another BD, as the case may be. In the event an error is made in a client account custodied elsewhere,
WMA works directly with the broker in question to take corrective action. In all cases, WMA will take the appropriate
measures to return the client’s account to its intended position.
C. Aggregating and Allocating Trades
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the
most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution,
4) confidentiality and 5) skill required of the broker. Tamarisk will execute its transactions through an unaffiliated
broker-dealer selected by the Client. Tamarisk may aggregate orders in a block trade or trades when securities are
purchased or sold through the Custodian for multiple (discretionary) accounts. If a block trade cannot be executed
in full at the same price or time, the securities actually purchased or sold by the close of each business day must
be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This will be done
in a way that does not consistently advantage or disadvantage particular Client accounts.
Item 13 – Review of Accounts
Each Client account shall be reviewed at least annually. Reviews may be conducted more or less frequently at the
Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in
the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is
encouraged to notify WMA if changes occur in the Client’s personal financial situation that might adversely affect the
Client’s investment plan. Additional reviews may be triggered by material market, economic or political events.
The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage
statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to
the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage
statements will include all positions, transactions and fees relating to the Client’s account[s]. Additional reporting
is provided to clients during review meetings, as needed on an ad hoc basis and on-demand through our client
portal.
The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance.
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by Tamarisk
Participation in Institutional Advisor Platform (Raymond James)
Tamarisk has established an institutional relationship with Raymond James to assist the Advisor in managing Client
account[s]. Access to the Raymond James 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 Raymond James. 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.
Participation in Institutional Advisor Platform (Schwab)
Tamarisk has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a
division of Schwab dedicated to serving independent advisory firms like Tamarisk. As a registered investment
Tamarisk Financial, LLC
301 Hoover Blvd. Suite 300 Holland MI 49423
Phone: (616) 820-1040 Fax: (616) 205-9250
https://tamariskfinancial.com
Page 17
advisor participating on the Schwab Advisor Services platform, Tamarisk 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 potential 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.
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 and financial support to Tamarisk
that may not benefit the Client, including: educational conferences and events, financial start-up support,
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 potential conflict of interest. Tamarisk
believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients.
Insurance Agency
As noted in Item 10, Tamarisk also serves as an insurance agency, where the Advisor may recommend to Clients
the purchase of certain insurance products. Tamarisk will benefit from any revenue generated from the sale of a
recommended insurance product.
Use of Independent Managers
The Advisor may be indirectly compensated by an Independent Manager as described in Item 5 above and does
not receive any other forms of compensation with such arrangements.
B. Client Referrals from Promoters
The Advisor does not compensate, either directly or indirectly, any affiliated or unaffiliated parties (“Promoters”) for
Client referrals.
Item 15 – Custody
Advisor does not maintain physical custody of client funds and/or securities, however Advisor is deemed to have
custody pursuant to the authority granted by Client to directly deduct the advisor’s fee. All Clients must place their
assets with a “qualified custodian”. Clients are required to select their own Custodian to retain their funds and
securities and direct Tamarisk to utilize that Custodian for the Client’s security transactions. As described in Item
12, Brokerage Practices, client assets are held at qualified custodians that provide account statements at least
quarterly directly to clients at their address of record. Tamarisk encourages Clients to review statements provided
by the account Custodian.
Tamarisk Financial, LLC
301 Hoover Blvd. Suite 300 Holland MI 49423
Phone: (616) 820-1040 Fax: (616) 205-9250
https://tamariskfinancial.com
Page 18
the SEC has exempted advisers from the custody audit requirement by rule or
Additionally, Advisor is also deemed to have custody of client assets to the extent Clients gives the Advisor authority
to move money from one account to another account pursuant to the authority granted through a Standing Letter of
Authorization “SLOA.” In order to avoid additional regulatory requirements, the Custodian and the Advisor have
adopted safeguards to ensure that the money movements are completed in accordance with the Client’s instructions.
For these types of deemed custody,
no-action relief.
However, Advisor is deemed to have custody under SEC rules because certain clients authorize the Firm to pay bills
or make other disbursements on their behalf. Although the Firm does not take physical possession of client funds,
the authority to direct payments from client accounts constitutes custody.
registered public accounting firm. The examination is performed on an unannounced
‑
To meet the requirements of the SEC Custody Rule, the Firm undergoes an annual surprise examination conducted
by an independent, PCAOB
basis each year, and the accountant files a report with the SEC upon completion. Clients may request a copy of this
report at any time.
pay services are provided only with written client authorization and are limited to payment of legitimate,
approved expenses. The Firm does not have authority to change account ownership, modify client addresses
‑
Bill
client
‑
or banking credentials, or withdraw funds for its own benefit. Supporting documentation is maintained for all
disbursements, and clients are encouraged to review all statements and reports carefully.
Item 16 – Investment Discretion
WMA generally has discretion over the selection and amount of securities to be bought or sold in Client accounts
without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to
specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by WMA.
Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will
be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to
such authority. All discretionary trades made by WMA will be in accordance with each Client's investment objectives
and goals.
Item 17 – Voting Client Securities
Tamarisk 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
Neither Tamarisk, nor its management, have any adverse financial situations that would reasonably impair the
ability of Tamarisk to meet all obligations to its Clients. Neither Tamarisk, nor any of its Advisory Persons, has been
subject to a bankruptcy or financial compromise. Tamarisk is not required to deliver a balance sheet along with this
Disclosure Brochure as the Advisor does not collect fees of $1,200 or more for services to be performed six months
or more in advance.
Tamarisk Financial, LLC
301 Hoover Blvd. Suite 300 Holland MI 49423
Phone: (616) 820-1040 Fax: (616) 205-9250
https://tamariskfinancial.com
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