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Item 1 - Cover Page
West Ridge Advisors, LLC
1528 W. Warm Springs Road #120
Henderson, NV 89014
(702) 547-9483
www.westridgeadvisors.com
Form ADV Part 2A
Firm Brochure
March 31, 2026
This Brochure provides information about the qualifications and business practices of West Ridge Advisors, LLC.
(“West Ridge Advisors,” “Firm,” “us,” “we,” or “our”). Please contact Michael Nestman at (702) 547-9483 if you
have any questions about the content of this Brochure.
The information in this Brochure has not been approved or verified by the United States Securities and Exchange
Commission (SEC) or any state securities administrator. Additional information about West Ridge Advisors is
available on the SEC’s website at www.adviserinfo.sec.gov. Click on the “Investment Adviser Search” link and
then search for “Investment Adviser Firm” using the Firm’s IARD (“CRD”) number, which is 282718.
While the Firm, and anyone associated with it, may be registered and/or licensed within a particular jurisdiction,
that registration and/or licensing does not imply an endorsement by any regulatory authority, nor does it imply
a certain level of skill or training on the part of the Firm or its associated personnel.
West Ridge Advisors, LLC
Form ADV Part 2 –20260331
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Item 2 - Material Changes
Please note that there were no “material changes” made to this Brochure since our last delivery or posting
of the Brochure on the SEC’s public disclosure website (“IARD”) www.adviserinfo.sec.gov. However, this
Brochure includes a number of minor editorial changes and updated information on our assets under
management.
The Firm may at any time update this document and either send a copy of its updated Brochure or provide a
summary of material changes to its Brochure, along with an offer to send an electronic or hard copy of the
updated Brochure. Clients may also download this Brochure from the SEC’s website at
www.adviserinfo.sec.gov or contact our Firm at (702) 547-9483 to request a copy at any time.
As with all Firm documents, clients and prospective clients are encouraged to review this Brochure in its
entirety and are encouraged to ask questions at any time prior to or throughout the engagement.
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Item 3 - Table of Contents
Item 1 - Cover Page ............................................................................................................................................. 1
Item 2 - Material Changes ................................................................................................................................... 2
Item 4 - Advisory Business ................................................................................................................................... 4
Item 5 - Fees and Compensation ......................................................................................................................... 9
Item 6 - Performance-Based Fees and Side-By-Side Management ................................................................... 12
Item 7 - Types of Clients .................................................................................................................................... 12
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ............................................................. 13
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 ........................................................................................................................... 19
Item 13 - Review of Accounts ............................................................................................................................ 22
Item 14 - Client Referrals and Other Compensation ......................................................................................... 23
Item 15 - Custody .............................................................................................................................................. 24
Item 16 - Investment Discretion ........................................................................................................................ 25
Item 17 - Voting Client Securities ...................................................................................................................... 25
Item 18 - Financial Information ......................................................................................................................... 26
Item 19 - Requirements for State-Registered Advisers ..................................................................................... 26
Important Information
Throughout this document the client or prospective client may be also referred to as “you,” “your,” etc., and
refers to a client engagement involving a single person as well as two or more persons and may refer to
natural persons and legal entities. The term “advisor” and “adviser” are used interchangeably where
accuracy in identification is necessary (i.e., internet address, etc.).
Our Firm maintains a business continuity and succession contingency plan integrated into the organization
to ensure it responds appropriately to events that pose a significant disruption to its operations. A
statement concerning the current plan is available under separate cover.
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Item 4 - Advisory Business
West Ridge Advisors is a Nevada-domiciled limited liability company formed in December 2015 and became
registered as an investment advisor in Nevada in February of 2016. Our Firm is also registered (licensed) as
an investment advisor in Arizona, California, and Utah, and we serve clients in other jurisdictions where we
are exempt from registration. We operate under the trade name West Ridge Advisors.
We are owned by the accounting firm of Udall CPA Group, PLLC. The managing members of Udall CPA
Group, PLLC are Thomas M. Udall, CPA, Todd S. Udall, CPA, Alan G. Erickson, CPA, Curtis Udall, CPA, and
Michael D. Nestman, CFP®. Michael Nestman serves as West Ridge Advisors' Chief Compliance Officer
(supervisor). Additional information on each partner’s professional experience may be found toward the end
of this Brochure, in their Brochure supplement.1 West Ridge Advisors is also under common control with an
insurance agency (see Items 5, 10, and 15 for further information).
Our Firm provides its clients with advice on key topics such as cash flow management and budgeting,
funding a college education, retirement planning, risk management, estate, and tax planning, among others.
Ongoing and continuous supervision of clients’ investment accounts is provided through our portfolio
management services offering. We provide educational seminars involving a broad range of financial
planning and investing topics. Our Firm assists plan sponsors with their retirement plan, which is described
in greater detail in a separate Firm Brochure available to interested parties upon request.
An initial interview is conducted with the client to discuss their current situation, long-term goals, and the
scope of services that may be provided. Prior to or during this first meeting, the client will be provided with
this Form ADV Part 2 Brochure that includes a statement involving our privacy policy (see Item 11), as well as
a Brochure supplement about the representative who will be assisting them. The Firm will disclose any
material conflicts of interest that could be reasonably expected to impair the rendering of unbiased and
objective advice, such as information found in Items 5, 10 through 12, and 14 of this Brochure.
If the client wishes to engage the Firm for its services, they must first execute our engagement agreement.
Thereafter, further discussion and analysis will be conducted to determine financial needs, goals, holdings,
etc. Depending on the scope of the engagement, the client may be asked to provide copies of the following
documents early in the process:
• Wills, codicils, and trusts
• Insurance policies
• Mortgage information
• Tax returns
• Student loans
• Divorce decree or separation agreement
• Current financial specifics, including W-2s or 1099s
• Information on current retirement plans and benefits provided by an employer
• Statements reflecting current investments in retirement and non-retirement accounts
• Employment or other business agreements
• Completed risk profile questionnaires or other forms provided by our Firm
1 Refer to the end of this Brochure for an explanation of designation prerequisites and continuing education requirements.
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It is important that we are provided with an adequate level of information and supporting documentation
throughout the term of the engagement, including but not limited to the source of funds, income levels, and
an account holder or attorney-in-fact’s authority to act on behalf of the account, among other information
that may be necessary for our services. The information and/or financial statements provided to us need to
be accurate. We may, but are not obligated to, verify the information provided to us, which will then be
used in the advisory process.
It is essential that the client inform the Firm of any significant issues that may require an update to their
financial plan or investment portfolio. Events such as changes in employment or marital status, or an
unplanned windfall, can affect a client’s circumstances and goals. We need to be aware of such events so
that adjustments may be made, as necessary.
Financial Planning Services
Financial planning services may be as broad-based or narrowly focused as you desire. The incorporation of
most or all of the listed components allows not only for thorough analysis but also for a refined focus of your
plans, enabling the Firm to assist you in reaching your goals and objectives.
Cash Flow Analysis and Debt Management
A review of your income and expenses will be conducted to determine your current surplus or deficit. Based
on the results, we will provide advice on prioritizing the use of any surplus or on reducing expenses if they
exceed your income. In addition, advice on prioritizing which debts to repay may be provided, based on
factors such as the debt’s interest rate and any income tax ramifications. Recommendations may also be
made regarding the appropriate level of cash reserves for emergencies and other financial goals. These
recommendations are based upon a review of cash accounts (such as money market funds) for such
reserves and may include strategies to save desired reserve amounts.
Risk Management
A risk management review includes an analysis of your exposure to major risks that could have a significant
adverse impact on your financial picture, such as premature death, disability, property and casualty losses,
or the need for long-term care planning. Advice may be provided on ways to minimize such risks, on
weighing the costs of purchasing insurance against the benefits of doing so, and, likewise, on the potential
cost of not purchasing insurance (“self-insuring”).
Employee Benefits
A review is conducted, and an analysis is made as to whether you, as an employee, are taking maximum
advantage of your employee benefits. We will also offer advice on your employer-sponsored retirement
plan and/or stock options, along with other benefits that may be available to you.
Personal Retirement Planning
Retirement planning services typically include projections of your likelihood of achieving your financial goals,
with financial independence usually the primary objective. For situations where projections show less than
desired, a recommendation may include showing you the impact of changes to certain variables (e.g.,
working longer, saving more, spending less, taking more risk with investments). If you are near retirement or
already retired, you may receive advice on appropriate distribution strategies to minimize the risk of running
out of money or having to reduce spending during your retirement years.
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College Funding
Advice involving college funding may include projecting the amount that will be needed to achieve post-
secondary education funding goals, along with savings strategies and the “pros-and-cons” of various college
savings vehicles that are available. We are also available to review your financial picture as it relates to
eligibility for financial aid or the best way to contribute to family members, such as grandchildren, if
appropriate.
Tax Planning Strategies
General advice may include ways to minimize current and future income taxes as part of your overall
financial planning. For example, recommendations may be offered as to which type of account(s) or specific
investments should be owned based in part on their “tax efficiency,” with consideration that there is always
a possibility of future changes to federal, state, or local tax laws and rates that may impact your situation.
For specific accounting and taxation services, clients will be referred to their accountant and may choose to
be introduced to our affiliate.
Estate Planning
Our review typically includes an analysis of your exposure to estate taxes and your current estate plan,
including whether you have a will, powers of attorney, trusts, and other related documents. We may assess
ways to minimize or avoid future estate taxes by implementing appropriate estate planning strategies, such
as the use of applicable trusts. We generally recommend that you consult with a qualified attorney when
you initiate, update, or complete estate planning activities. We may provide you with contact information
for attorneys who specialize in estate planning when you wish to hire an attorney for such purposes. From
time to time, we will participate in meetings or phone calls between you and your attorney with your prior
approval.
Divorce Planning
Separation or divorce can have a major impact on your goals and plans. We will collaborate with you to help
you understand your unique situation and provide a realistic financial picture so you are better positioned to
communicate with legal counsel, a mediator, or your soon-to-be ex-spouse. We can assist in the completion
of cash flow and net worth projections, budgetary analysis, and help you to understand the financial
consequences of a settlement.
Investment Consultation
Investment consultation services often involve providing information on the types of investment vehicles
available, employee retirement plans and/or stock options, investment analysis and strategies, asset
selection, and portfolio design, as well as limited assistance if your investment account is maintained at
another broker/dealer or custodian. The strategies and types of investments that may be recommended are
further discussed in Item 8 of this Brochure.
Broad-Based v. Modular Financial Planning
A broad-based plan is an endeavor that requires detail. Certain variables can affect the cost involved in the
development of the plan, such as the quality of your own records, complexity and number of current
investments, diversity of insurance products and employee benefits you currently hold, size of the potential
estate, and special needs of the client or their dependents, among others. While certain broad-based plans
may require 10 or more hours to complete, complex plans may require more than 20 hours.
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At your request, we may concentrate on reviewing only a specific area (modular planning), such as employer
retirement plan allocation, funding an education, or estate planning issues, or evaluating the sufficiency of
your current retirement plan. Note that when these services focus only on certain areas of your interest or
need, your overall situation or needs may not be fully addressed due to limitations you may have
established.
Whether we have created a broad-based or modular plan, we will present you with a summary of our
recommendations, guide you in implementing some or all of them, as you decide, and offer you periodic
reviews thereafter. In all instances involving our financial planning engagements, our clients retain full
discretion over all implementation decisions and are free to accept or reject any recommendation we make.
Educational Workshops
We provide periodic complimentary educational seminars on personal finance and investing. Topics may
include general financial planning, educational funding, estate planning, retirement strategies, implications
of changes in marital status, and other current economic or investment topics. Our workshops are
educational in nature and do not involve soliciting insurance or investment products.
Portfolio Management Services
You may also engage us to implement investment strategies that we have recommended to you. Depending
on your risk profile, goals, and needs, among other considerations, your portfolio will employ one of our
investment strategies and either a broad range or a more narrowly focused selection of investment vehicles,
which are further discussed in Item 8 of this Brochure.
We typically prepare investment guidelines that reflect your objectives, time horizon, risk tolerance, and any
reasonable account constraints you may have for the portfolio. For example, you have the right to exclude
certain securities (e.g., options, stocks, etc.) at your discretion. These guidelines will be designed to be
sufficiently specific to provide future guidance while allowing flexibility to adapt to changing market
conditions. Since this effort is based on the information and data you have provided, you may be asked to
review it and provide your final approval. We will then develop a customized portfolio for you based on your
unique situation, investment goals, and risk tolerance. We manage your portfolio on a discretionary or
nondiscretionary basis (defined in Item 16). We want to note that it will remain your responsibility to
promptly notify us of any changes in your financial situation and/or investment objectives so that we can
review, evaluate, or revise any previous account restrictions or Firm investment recommendations.
Personalized Indexing
West Ridge’s Personalized Indexing service partners with Vanguard Personalized Indexing (“Vanguard”) to
serve as an investment sub-adviser in managing client accounts. West Ridge is responsible for selecting the
personalized indexing strategy, index exposure, and client-specific investment guidelines. Customization
parameters may include, among other things, tracking tolerance relative to the target index, tax-management
preferences, restrictions on specific securities or industries, and other client-approved constraints. Prior to
implementation, West Ridge establishes investment parameters based on each client’s investment objectives,
risk tolerance, tax considerations, and other relevant factors. Vanguard, as sub-adviser, is responsible for
discretionary trading, portfolio construction, rebalancing, and tax-loss harvesting in accordance with the
investment guidelines established by West Ridge. West Ridge retains fiduciary responsibility for client
accounts, including strategy selection, suitability determinations, and ongoing oversight of Vanguard. Client
accounts that implement these strategies are custodied at Fidelity Brokerage Services, LLC.
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Third-Party Investment Advisors Referral Services- Solicitor Arrangements
West Ridge offers advisory services by referring Clients to unaffiliated third-party advisors offering asset
management and other investment advisory services. The third-party advisors are responsible for
monitoring Client Accounts and making trades in Client Accounts when necessary. The third-party advisor
has discretionary authority to determine which securities to purchase and sell for your Account. We do not
have any trading authority over the designated Accounts managed by the third-party advisor. You must
enter into an agreement directly with the third-party advisor who provides your designated Account with
asset management services. Clients who are referred to third-party advisors will receive full disclosure,
including services rendered and fee schedules, at the time of the referral by delivery of a copy of the
relevant third-party advisor’s or equivalent disclosure document, prior to placing the assets with the third-
party advisors.
As a result of the referral, West Ridge and your Advisor are paid a portion of the fee charged and collected
by the third-party advisor in the form of solicitor fees. Each solicitation arrangement is conducted pursuant
to a written solicitation agreement and complies with SEC Rule 206(4)-1 and applicable state securities rules
and regulations. Clients are advised that there may be other third-party managed programs not
recommended by us, which are suitable for the Client, and that may be more or less costly than
arrangements recommended by us. No guarantees can be made that a Client’s financial goals or objectives
will be achieved by a third-party advisor recommended by West Ridge.
Retirement Accounts – DOL Disclosure
We are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act of 1974
(“ERISA”) and/or the Internal Revenue Code (“Code”), as applicable, when we provide investment advice
regarding portfolio assets held in an IRA, Roth IRA, Archer Medical Savings Account, a Plan covered by ERISA,
or a plan described in Section 4975(e)(1)(A) of the Code (collectively referred to collectively sometimes
herein as (“Retirement Accounts”). To ensure that West Ridge adheres to fiduciary norms and basic
standards of fair dealing, we are required to provide advice in the "best interest" of the retirement client.
The best interest standard has two chief components: prudence and loyalty. Under the prudence standard,
our advice must meet a professional standard of care, and under the standard of loyalty, our advice must be
based on the interests of our retirement clients rather than the potentially competing financial interests of
West Ridge.
To address the conflicts of interest with respect to our compensation, we are required to act in your best
interest and not put our interests ahead of yours. To this end, we must:
• Meet a professional standard of care when making investment recommendations (give prudent
advice).
• Never put our financial interests ahead of yours when making recommendations (give loyal advice).
• Avoid misleading statements about conflicts of interest, fees, and investments.
• Follow policies and procedures designed to ensure that we give advice that is in your best interest.
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
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Wrap Fee Program
The Firm does not sponsor or serve as a portfolio manager in an investment program involving wrapped
(bundled) fees.
Assets Under Management
As of December 31, 2025, we had approximately $396,019,216 million of reportable assets under its
management;2 $238,274,266 million on a discretionary basis, and $157,744,950 million on a non-
discretionary basis.
Item 5 - Fees and Compensation
Forms of payment are based on the types of services provided, terms of service, and other factors, and will
be stated in the engagement agreement. Our fees are negotiable, and we may reduce or waive our fee for
associates of the Firm, family members, or pre-existing relationships. We strive to offer fees that are fair and
reasonable, given our experience and the services we provide. We are obliged under California statute to
inform clients and prospective clients that similar services may be made available from others, potentially at
a lower fee.
Fees may be paid by check or draft from US-based financial institutions. With the client’s prior written
authorization, payment may also be made through the investment account held at the client’s custodian of
record. We do not accept cash, money orders, or similar forms of payment for our engagements.
Financial Planning Services
Project-based engagements are assessed at fixed fees ranging from $500 to $3,000. Our fee will take into
consideration factors such as the complexity of your financial profile, the depth of services to be provided
through the engagement, assets that comprise your overall portfolio, number of accounts comprising the
portfolio, whether you or our Firm will implement the transactions for your account(s), time involved in the
engagement, among others. A deposit equaling one half of the quoted fee will be due upon execution of the
engagement agreement, and the remaining portion is due upon plan delivery.
Clients interested in a limited planning component engagement are assessed an hourly fee. Our rate is $200
per hour, billed in 15-minute increments; a partial increment (e.g., 7 minutes) will be treated as a whole
increment.3 Prior to entering into an agreement with our Firm, you will receive an estimate of the overall
cost based on your requirements and the time involved. We do not require a deposit to initiate the
engagement; the fee is due in full upon delivery of our invoice, which is issued at the time your plan/advice
is presented. An hourly engagement lasting more than one month may be billed at the end of each month
for time incurred during that period.
Educational Workshops
Workshop sessions are complimentary; no session fees are assessed by our Firm.
2 The term “assets under management” and rounding per the SEC’s General Instructions for Part 2 of Form ADV.
3 The Firm’s hourly rate will not exceed $150 per hour for Utah-domiciled clients.
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Third-Party Referral Service Fees
Third-party advisors generally have account minimum requirements that will vary among third-party
advisors. A complete description of the third-party advisor’s services, fee schedules, and account minimums
will be disclosed in the third-party advisor’s disclosure brochure, which will be provided to you prior to or at
the time an agreement for services is executed and the account is established.
The actual fee charged to you will vary depending on the third-party advisor. All fees are calculated and
collected by the third-party advisor. We are paid a portion of the fee charged and collected by the third-
party advisor in the form of solicitor fees. Our portion of the fee is negotiated with each third-party advisor.
The exact fee and the timing of withdrawal will vary by third-party advisor. These details will be disclosed in
the third-party advisor’s ADV Part 2A and the Solicitor Disclosure, which will be provided to the Client upon
solicitation. Clients may terminate the third-party advisor Agreement in accordance with the terms set forth
in the third-party management agreement executed between the Client and the third-party advisor.
Portfolio Management Services
We bill our portfolio management fees in advance, or in arrears, quarterly, as determined by the client’s
specific advisory arrangement with us. At the end of each calendar quarter, portfolio management clients
will pay West Ridge Advisors an asset-based fee based on an annual rate as indicated in the following fee
table.
Fees paid in arrears are determined by the value of account assets and calculated on the average daily
balance throughout the quarter, multiplying that quotient by the applicable number of basis points set forth
in the following fee table (one basis point equals 1/100 of one percent). The result is then divided by 4 to
determine the quarterly fee. Certain account fees will be calculated based on a most recent month-end
average balance or other quarter-end calculations depending on custodial platform capabilities, which will
be disclosed and discussed with the client.
Fees paid in advance are calculated by multiplying the market value of assets under management by
annualized fee set forth below, time’s the number of days in the quarter, divided by the number of days in
the year. Fees for the initial quarter will be adjusted pro rata based on the number of days in the fiscal
quarter that the Agreement goes into effect.
Amount of Assets Under Management
$0 - $499,999
$500,000 - $999,999
$1,000,000 - $9,999,999
$10,000,000 - $19,999,999
$20,000,000 and above
Annual Fee
1.50% (150 basis points)
1.25% (125 basis points)
1.00% (100 basis points)
0.75% (75 basis points)
Custom Pricing
Portfolio Management Billing Processes
The first billing cycle will begin once the engagement agreement is executed with our Firm and assets have
settled into the client’s account held by the custodian of record. Fee payments will generally be assessed
within the first 15 days of each billing cycle.
Our Firm will concurrently send the client and custodian of record a written invoice each billing period that
describes the advisory fees to be deducted from the account at our Firm’s request. The invoice will include
the total fee assessed, covered time period, calculation formula utilized, and reference to the assets under
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management in which the fee has been based. We encourage clients to verify the accuracy of fee
calculations as custodians do not verify the accuracy of advisory fee assessments for each account.
The client’s written authorization is required for the custodian of record to deduct advisory fees from the
account. By signing our Firm’s engagement agreement and the custodian account opening documents, the
client will authorize the withdrawal of both advisory and transactional fees (see the following section) from
an account. The custodian will withdraw these fees upon our request and remit them directly to our Firm.
All fees deducted will be reflected on the client's account statements, which the client will receive directly
from the custodian of record. We do not typically accept requests to pay our advisory fee directly, rather
than have the fee withdrawn from the account.
Personalized Indexing Sub-Management Fees
For clients utilizing West Ridge’s personalized indexing strategies, the Firm has engaged Vanguard
Personalized Indexing as an investment sub-manager. Vanguard charges a sub-advisory fee ranging from
0.15% to 0.20% of assets under management, depending on the size of the client account. This fee is
deducted directly from the client’s account and is in addition to West Ridge’s advisory fee. As a result,
clients participating in the personalized indexing program will pay higher aggregate advisory costs than
clients who do not utilize this service. The Firm generally requires a minimum account balance of $250,000
to participate in the personalized indexing strategies implemented through Vanguard. Vanguard may, in its
discretion, waive the account minimum for certain accounts. Any such waiver is determined by Vanguard
and is not guaranteed. West Ridge does not control whether an account minimum is waived.
Additional Client Fees
Any transactional or service fees (sometimes termed brokerage fees), individual retirement account fees,
qualified retirement plan fees, account termination fees, or wire transfer fees will be borne by the account
holder and per the separate fee schedule of your custodian of record. We will ensure that our clients receive
a copy of our preferred custodian’s fee schedule at the beginning of the engagement, and the client will be
notified of any future changes to these fees by the custodian of record and/or third-party administrator for
tax-qualified plans. Fees paid by our clients to our Firm for our advisory services are separate from any of
these fees or other similar charges. In addition, our advisory fees are separate from any internal fees or
charges a client may pay involving mutual funds, exchange-traded funds (ETFs), exchange-traded notes
(ETNs), or other similar investments. Additional information about our fees related to our brokerage and
operational practices is provided in Items 12 and 14 of this document.
Per annum interest at the current statutory rate based on the state in which the client resides may be
assessed on fee balances due more than 30 days, and we may refer past due accounts to collections or legal
counsel for processing. We reserve the right to suspend some or all services once an account is deemed past
due.
External Compensation Involving the Sale of Securities to Clients
Our Firm does not charge or receive a commission or markup on securities transactions, nor will the Firm or
any associate be paid a commission on the purchase of a securities holding recommended to a client. We do
not receive “trailer” or SEC Rule 12b-1 fees from an investment company that may be recommended to a
client. Fees charged by such issuers are detailed in prospectuses or product descriptions, and interested
investors are always encouraged to read these documents before investing.
When a client purchases an insurance policy (i.e., fixed annuity, life insurance policy, disability insurance
policy, etc.), a commission or override (or similar compensation) is normally paid to the insurance agent and
the insurance agency. West Ridge Insurance, LLC is an insurance agency affiliate of West Ridge Advisors, and
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some associates of our Firm are licensed as insurance agents. This creates an incentive to make such a
recommendation based on the compensation they may receive rather than a client’s needs. Our advisory
Firm and its associates take their responsibilities seriously and intend only to recommend investments,
insurance, or advisory services that we believe are appropriate for each client. Please refer to Items 10 and
11 of this Brochure, in addition to Item 4 of an associate’s brochure supplement, for details.
The client retains the right to purchase recommended or similar investments through their own selected
service provider.
Termination of Services
Either party has the right to terminate the engagement agreement at any time by providing written notice
of intent to terminate to the other party. The effective date of the termination shall be the date the other
party receives the termination, unless the termination states a later date, in which case the later date
specified by the terminating party shall be the effective date. Our Firm will not be responsible for
investment allocation, advice, or transactional services, except for limited closing transactions, after the
effective date of termination. Upon termination, our Firm will be required to inform the custodian of record
that the relationship between the Firm and the client has been terminated.
If a client does not receive our Form ADV Part 2 Brochure at least 48 hours prior to entering into the Firm’s
agreement, then that client will have the right to terminate the engagement without fee or penalty within
five business days after entering into the agreement. Should a client terminate a financial planning service
after this five-day time period, the client will be assessed fees at the Firm’s current hourly rate for any time
incurred in the preparation of the client’s analysis or plan. If a portfolio management services client
terminates their agreement after the five-day period, the client will be assessed fees on a prorated basis for
services incurred from either (i) as a new client, the date of the engagement to the date of the Firm’s receipt
of the written notice of termination, or (ii) all other accounts, the last billing period to the date of the Firm’s
physical or constructive receipt of written termination notice.
The Firm will return any prepaid, unearned fees within 30 days of the Firm’s receipt of a termination notice.
Earned fees in excess of any prepaid deposit will be billed at termination and due upon receipt of our
invoice. Our return of payment to a client for our financial planning services will be made only by check from
our Firm’s US-based financial institution. We will only coordinate remuneration of prepaid asset-based fees
to an investment account via the account custodian. The return of prepaid fees will never involve a personal
check, cash, or money order from our Firm or an associate of our Firm.
Item 6 - Performance-Based Fees and Side-By-Side Management
Our advisory fees will not be based on a share of capital gains or capital appreciation (growth) of any portion
of the managed funds, which are known as performance-based fees. Our fees will also not be based on side-
by-side management, which refers to a firm simultaneously managing accounts that do pay performance-
based fees (such as a hedge fund) and those that do not.
Item 7 - Types of Clients
While West Ridge Advisors’ current client-base consists of individuals, high net worth individuals, and
pension and profit-sharing plans, we are available to serve businesses of all scales. We do not require
minimum income, minimum asset levels, or other similar preconditions. We reserve the right to waive or
reduce certain fees based on unique individual circumstances, special arrangements, or preexisting
relationships. Our Firm reserves the right to decline services to any prospective client for any
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nondiscriminatory reason. For clients participating in the personalized indexing strategies implemented
through Vanguard, a minimum account size of $250,000 is generally required. Vanguard may waive this
requirement in its sole discretion.
Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss
Methods of Analysis
Our Firm employs fundamental analyses; we evaluate various economic factors, including interest rates, the
current state of the economy, and the future growth of an industry sector. Our research is typically drawn
from economists and other industry professionals, as well as financial periodicals and reference materials.
Investment Strategy
Client portfolios are constructed based on Modern Portfolio Theory, which states that by employing
securities whose price movements have historically low correlations, it is possible to create an efficient
portfolio that can offer the highest expected return for a given level of risk, or one with the lowest level of
risk for a given expected return. The practice of Modern Portfolio Theory does not employ market timing or
stock selection methods of investing, but rather a long-term, buy-and-hold strategy with periodic
rebalancing to maintain desired risk levels.
Our portfolios contain investment vehicles that are globally diversified, tax-efficient, and low-cost whenever
practical. It is common to find a broad range of mutual funds or ETFs within a portfolio, as well as individual
stocks, bonds, and money markets or certificates of deposit (CDs)4 to aid in non-correlation.
Personalized Indexing Strategy
The indexing strategies are designed to provide index-based exposure through the ownership of individual
equity securities rather than pooled investment vehicles. The portfolio is designed to approximate the
index’s overall market exposure while allowing for customization and tax-management features.
Risk of Loss
Our Firm believes its strategies and investment recommendations are designed to produce the appropriate
potential return for the given level of risk; however, there is no guarantee that a planning goal or investment
objective will be achieved. Past performance is not necessarily indicative of future results. Investing in
securities involves risk of loss that clients should be prepared to bear. While the following list is not
exhaustive, we provide examples of such risks in the paragraphs below, and we believe it is important that
our clients review and consider each one prior to investing.
Company Risk
When investing in securities, such as stocks, there is always a certain level of company- or industry-specific
risk inherent in each company or issuer. There is a risk that the company will perform poorly or see its value
reduced due to factors specific to the company or its industry. This is also referred to as unsystematic risk
and can be reduced or mitigated through diversification.
4 The Firm may recommend but does not distribute certificates of deposits, money market accounts, or similar savings vehicles for
client accounts. We are not a financial institution, is not a member of the Federal Deposit Insurance Corporation (FDIC) or National
Credit Union Association (NCUA), nor is required to be an FDIC or NCUA member. You may learn more about the FDIC or NCUA and
how they serve financial institution depositors/members by going to their website at www.fdic.gov or www.ncua.gov. Securities
recommended by us are not FDIC or NCUA/NCUSIF-insured.
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Direct Indexing Risks and Limitations
Direct Indexing strategies involve holding securities rather than investing in a pooled investment vehicle,
which may result in increased tracking error relative to the referenced index. Tax-loss harvesting may
increase trading activity and transaction costs and does not guarantee tax benefits. Results depend on
individual circumstances, tax laws, and future regulatory changes. The Firm's reliance on third-party trading
and portfolio management technology presents operational and execution risks outside the Firm's direct
control.
Failure to Implement
Each client has the right to accept or reject any or all the recommendations made by our Firm involving their
financial plan or portfolios managed on a non-discretionary basis. While no advisory firm can guarantee
future performance, no plan can succeed if it is not implemented. Clients who choose not to take the steps
recommended in their financial plan may face an increased risk that their stated goals and objectives will not
be achieved.
Financial Risk
Excessive borrowing to finance business operations increases profitability risk because the company must
meet its obligations under the terms of its debt in good times and bad. During periods of financial stress, the
inability to meet loan obligations may result in bankruptcy and/or a declining market value.
Fundamental Analysis
The challenge with fundamental analysis is that the information obtained may be incorrect; the analysis may
not provide an accurate estimate of earnings, which may be the basis for a security’s value. If a security’s
price adjusts rapidly to new information, fundamental analysis may lead to unfavorable performance.
Inflation Risk
Also called purchasing power risk, is the chance that the cash flows from an investment will not be worth as
much in the future because of changes in purchasing power due to inflation.
Market Risk
When the stock market or an industry as a whole declines, it can cause the prices of individual stocks to fall
indiscriminately. This is also called systemic or systematic risk.
Passive Investing
A portfolio that employs a passive, efficient markets approach (representative of Modern Portfolio Theory)
has the potential risk at times to generate lower-than-expected returns for the broader allocation than
might be the case for a more narrowly focused asset class, and the return on each type of asset may be a
deviation from the average return for the asset class.
Political Risk
The risk of financial or market losses due to political decisions or disruptions in a particular country or region
is also known as "geopolitical risk."
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Research Data
When research and analyses are based on commercially available software, rating services, general market
and financial information, or due diligence reviews, a firm is relying on the accuracy and validity of the
information or capabilities provided by selected vendors, rating services, market data, and the issuers
themselves. While our Firm makes every effort to determine the accuracy of the information received, we
cannot predict the outcome of events or actions taken or not taken, or the validity of all information
researched or provided, which may or may not affect the advice on or investment management of an
account.
Security-Specific Risks
ETF and Mutual Fund Risks - The risk of owning ETFs and mutual funds reflects the risks of their underlying
securities (e.g., stocks, bonds). These forms of securities typically incur additional expenses based on their
share of operating expenses and certain brokerage fees, which may result in duplicate fees. We do not
recommend leveraged or inverse ETFs due to their inherent heightened risk.
Equity (Stock) Risk - Common stocks are susceptible to general stock market fluctuations and to volatile
increases or decreases in value as market confidence in and perceptions of their issuers change. If an
investor held common stock or common stock equivalents of any given issuer, they may be exposed to
greater risk than if they held preferred stocks and debt obligations of the issuer.
Fixed Income Risks - Various forms of fixed income instruments, such as bonds, money market, or bond
funds, may be affected by various forms of risk, including:
• Credit Risk - The potential risk that an issuer would be unable to pay scheduled interest or repay
principal at maturity, sometimes referred to as “default risk.” Credit risk may also arise when an issuer’s
ability to make principal and interest payments when due is interrupted. This may negatively impact all
forms of debt instruments, as well as the funds or ETF share values that hold these issues. Bondholders
are creditors of an issuer and have priority to assets before equity holders (i.e., stockholders) when
receiving a payout from liquidation or restructuring. When defaults occur due to bankruptcy, the type of
bond held will determine the seniority of payment.
• Duration Risk - Duration is a measure of a bond’s volatility, expressed in years to be repaid by its internal
cash flow (interest payments). Bonds with longer durations carry more risk and have higher price
volatility than bonds with shorter durations.
• Interest Rate Risk - The risk that the value of the fixed income holding will decrease because of an
increase in interest rates.
• Liquidity Risk - The inability to readily buy or sell an investment for a price close to the true underlying
value of the asset due to a lack of buyers or sellers. While certain types of fixed income are generally
liquid (e.g., bonds), risks can arise, such as when an issue, in any given period, does not readily support
buy and sell orders at an efficient price. Conversely, when trading volume is high, there is also a risk of
not being able to purchase a particular issue at the desired price.
• Reinvestment Risk - With declining interest rates, investors may have to reinvest interest income or
principal at a lower rate.
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Index Investing - Certain ETFs and index funds may be affected by “active risk” or “tracking error risk,” which
is a deviation from a stated benchmark (e.g., an index).
QDI Ratios - While many ETFs and index mutual funds are known for their potential tax-efficiency and higher
“qualified dividend income” (QDI) percentages, there are asset classes within these investment vehicles or
holding periods within that may not benefit. Shorter holding periods, as well as commodities and currencies
(that may be holdings within an ETF or mutual fund portfolio), may be considered “non-qualified” under
certain tax code provisions. A holding’s QDI will be considered when tax-efficiency is an important aspect of
the client’s portfolio.
Use of Data Aggregation Services- West Ridge Advisors may use third-party data aggregation services for
financial planning, account monitoring, performance reporting, or client portal access. These services enable
clients to link accounts across unrelated financial institutions, allowing them to view balances, holdings, and
transactions in a single view. Usually, the Firm’s access to these accounts is “read-only,” meaning it can see
information but cannot place trades, transfer assets, or exercise discretionary control over the accounts
through the aggregation platform.
Account data is obtained from third-party data providers and connectivity services, which may not have a
direct relationship with the client’s custodian or financial institution. Clients should understand that
aggregated data comes from third-party sources and may not always be complete, accurate, or current. West
Ridge Advisors does not independently verify all aggregated information. Clients should rely on statements
provided directly by their custodians or financial institutions as the official records of their accounts.
Using data aggregation services involves certain risks, including cybersecurity threats and possible service
disruptions. Although the Firm conducts due diligence on vendors and reviews their security practices, no
system is completely secure, and the Firm cannot guarantee the security of information transmitted through
third-party platforms. West Ridge Advisors’ use of aggregation services does not establish custody of client
assets, and such accounts stay under the control of the respective financial institutions.
Item 9 - Disciplinary Information
Neither the Firm nor its management has been involved in any material criminal or civil action in a domestic,
foreign, or military jurisdiction, an administrative enforcement action, or a self-regulatory organization
proceeding that would reflect poorly upon our offering advisory business or its integrity.
Item 10 - Other Financial Industry Activities and Affiliations
Firm policies require associated persons to conduct business activities in a manner that avoids conflicts of
interest between the Firm and its clients, or that may be contrary to law. West Ridge Advisors will provide
clients with disclosure prior to and throughout the term of an engagement regarding any conflicts of interest
arising from its business relationships that might reasonably compromise its impartiality or independence.
Our advisory Firm and its management are not registered, nor do they have an application pending, to
register as a Financial Industry Regulatory Authority (FINRA) or National Futures Association (NFA) member
firm or as an associated person of such a firm. We are not required to be registered with such entities, nor
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do they supervise our Firm, its activities, or our associates. Neither our Firm nor its management is or has a
material relationship with any of the following types of entities:
• another investment advisor, including financial planning firms, municipal advisors, or third-party
investment managers.
• bank, credit union or thrift institution, or their separately identifiable department or division.
• lawyer or law firm.
• pension consultant (other than our own services).
• real estate broker, dealer, or advisor.
• sponsor or syndicator of limited partnerships.
• trust company.
• issuer of a security, to include investment company or other pooled investment vehicle (including a
mutual fund, closed-end investment company, unit investment trust, private investment company or
“hedge fund,” and offshore fund).
Associates of our advisory Firm may also be licensed insurance agents appointed to various unaffiliated
insurance carriers through our insurance agency affiliate, West Ridge Insurance, LLC. The majority of our
Firm partners are also accountants and partners of our accounting firm affiliate (parent) and shareholder
Udall CPA Group, PLLC. Udall CPA Group, PLLC, has entered into a referral agreement with ADP Retirement
Services (“ADP”) to refer clients to the ADP Retirement Service program and receive a referral fee. West
Ridge advisory clients are referred to ADP and fees are paid to Udall CPA Group, PLLC. No fees are shared or
received by West Ridge Advisors for the clients referred by Udall CPA Group, PLLC, to ADP Retirement
Service program.
Firm clients may have one or more business relationships with an associate, depending on the service and
advice being provided. Further information regarding these activities may be found in each associate’s
accompanying Form ADV Part 2B Brochure supplement. Whether they are serving a client in one or more
capacities, they will disclose in advance how they are being compensated and if there is a conflict of interest
involving any advice or service to be provided. At no time will there be tying between business practices
and/or services; a condition where a client or prospective client would be required to accept one product or
service which is conditional upon the selection of a second, distinctive tied product or service.
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
West Ridge Advisors holds itself to a fiduciary standard, which means the Firm and its associates will act in
the utmost good faith and perform in a manner believed to be in the best interests of its clients. Our Firm
believes that business methodologies, ethical rules, and adopted policies are designed to eliminate or at
least minimize material conflicts of interest and to appropriately manage any that may remain. We will
disclose to our clients any material conflict of interest involving the Firm, its representatives, or any of its
employees that could reasonably be expected to impair the rendering of unbiased and objective advice.
Code of Ethics
We have adopted a Code of Ethics that establishes policies for ethical conduct for our personnel. Our Firm
accepts the obligation to comply with applicable laws and regulations and to act in an ethical and
professionally responsible manner in all professional services and activities. Firm policies include
prohibitions against insider trading, circulation of industry rumors, and certain political contributions, among
others. West Ridge Advisors periodically reviews and amends its Code of Ethics to ensure that it remains
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current and requires Firm personnel to annually attest to their understanding of and adherence to the Firm’s
Code of Ethics. A copy of the Firm’s Code of Ethics is made available to any client or prospective client upon
request.
Statement Regarding our Privacy Policy
We respect the privacy of all clients and prospective clients (collectively, “customers” under privacy
regulations), both past and present. It is recognized that our clients have entrusted our Firm with non-public
personal information, and it is important that both access persons and customers are aware of the Firm's
policy concerning what may be done with that information. The Firm collects personal information about
customers from the following sources:
• Information customers provide to us to complete their financial plan or investment recommendation.
• Information customers provide in engagement agreements and other documents completed in
connection with the opening and maintenance of an account.
• Information customers provide verbally; and
• Information received from service providers, such as custodians, about customer transactions.
The Firm does not disclose non-public personal information about our customers to anyone, except in the
following circumstances:
• When required to provide services our customers have requested.
• When our customers have specifically authorized us to do so.
• When required during a firm assessment (i.e., independent audit); or
• When permitted or required by law (i.e., periodic regulatory examination).
Within the Firm, access to customer information is restricted to personnel who need to know that
information. All access persons and service providers understand that everything handled in Firm offices is
confidential, and they are instructed not to discuss customer information with anyone else that may request
information about an account unless they are specifically authorized in writing by the customer to do so.
This includes providing information about a family member’s account.
To ensure security and confidentiality, the Firm maintains physical, electronic, and procedural safeguards to
protect the privacy of customer information.
The Firm will provide clients with our updated privacy policy whenever the Firm's privacy policies are
materially changed.
Firm Recommendations and Conflicts of Interest
An associate is prohibited from borrowing from or lending to a client unless the client is an approved
financial lending institution.
Neither the Firm nor an associate is authorized to recommend to a client, or effect a transaction for a client,
involving any security in which the Firm or a “related person” (e.g., associate, an immediate family member,
etc.) has a material financial interest, such as in the capacity as a board member, underwriter or advisor to
an issuer of securities, etc.
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West Ridge Advisors does not trade for its own account (e.g., proprietary trading). The Firm’s related
persons may buy or sell securities that are the same as, similar to, or different from those recommended to
clients for their accounts, and this poses a conflict of interest. We mitigate this conflict by implementing
policies and procedures to ensure that the Firm or any related person does not receive preferential
treatment over a client. To reduce or eliminate certain conflicts of interest involving personal trading (e.g.,
trading ahead of client recommendations), Firm policy may require that we periodically restrict or prohibit
related parties’ transactions. Any exceptions must be approved in writing by our Chief Compliance Officer,
and personal trading accounts are reviewed quarterly or more frequently. Please refer to Item 6 of the
accompanying Form ADV Part 2B for further details.
Our Firm can provide a range of advisory services to you and all our clients. Because our Firm can offer two
or more services and receive compensation for each engagement, a conflict of interest arises from the
extended services or revenue earned. We therefore note that you are under no obligation to act on our
recommendations and, if you choose to do so, you have the right to complete them through a provider of
your own choice.
Item 12 - Brokerage Practices
Factors Used to Select Broker/Dealers for Client Transactions
Accounts must be maintained by a qualified custodian (generally a broker/dealer, bank, or trust company) that is
frequently reviewed for its capabilities to serve in that capacity by their respective industry regulatory authority.
Our Firm is not a custodian, there is no affiliate that is a custodian, nor does a custodian supervise our Firm, its
activities, or our associates. We do not receive referrals from a custodian, nor are client referrals a factor in our
recommendation of a custodian.
When we are engaged to provide investment consultation as part of a financial planning service, we may
recommend that a client retain the provider with whom the client's assets are currently held. Should the
client prefer a new service provider, our Firm's recommendation would be based on the client's needs, as
well as the provider's overall costs and ease of use.
We prefer that our portfolio management services clients use Schwab Institutional, a division of Charles
Schwab & Co., Inc. Member FINRA/SIPC.5 Our Firm is independently owned and operated; we are not legally
affiliated with Schwab Institutional. While we recommend Schwab Institutional as the custodian of record,
the client will decide whether to do so and will open their account in their name with the custodian by
entering into an agreement directly with the custodian. We do not technically open an account for a client,
but we will assist the client in doing so. If a client does not wish to place their assets with Schwab
Institutional as the custodian of record, we may be able to serve as investment advisor to another custodian
of the client’s choice, provided the other custodian’s policies allow us to do so.
Charles Schwab & Co. Inc. (“Charles Schwab”) offers independent investment advisors’ various services
which include custody of client assets, trade execution, clearance, and settlement, etc. Our Firm may receive
certain benefits from Charles Schwab through participation in its independent advisor support program
(please refer to Item 14 for further details), however, there is no direct link between our Firm’s participation
in their program and the investment advice we may provide to our clients. Our Firm periodically assesses
any recommended service provider (including Charles Schwab), which generally involves a review of the
range and quality of services, reasonableness of fees, among other items, in comparison to industry peers.
5 West Ridge Advisors is not, nor required to be, a Securities Investor Protection Corporation (SIPC) member. You may learn more
about SIPC and how it serves member firms and the investing public by going to their website at http://www.sipc.org.
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We do not receive referrals from our custodian, nor are client referrals a factor in our selection of our
custodian.
Client accounts implementing West Ridge’s personalized indexing strategies are custodied at Fidelity
Brokerage Services, LLC (“Fidelity”), a qualified custodian. Fidelity executes and clears trades as directed by
Vanguard Personalized Indexing Management (“Vanguard”), the Firm’s discretionary sub-advisor. While
Vanguard has trading discretion to implement the strategy within the parameters established by the Firm,
the Firm retains fiduciary responsibility for selecting the strategy, establishing client-specific investment
guidelines, and overseeing trading activity. West Ridge does not receive any compensation, revenue sharing
or other economic benefits from Fidelity or Vanguard in connection with the implementation of
personalized indexing strategy.
Best Execution
“Best execution” means the most favorable terms for a transaction based on all relevant factors, including
those listed in the earlier paragraphs and in Item 14. We recognize our obligation to seek best execution for
our clients; however, we believe the determinative factor is not always the lowest possible cost, but
whether the selected custodian’s transactions represent the best “qualitative execution,” taking into
account the full range of services provided. Our Firm will seek services at competitive rates, but this does
not necessarily mean the lowest possible rate for each transaction. We have determined that having our
portfolio management clients’ accounts trades completed through our recommended custodian is
consistent with our obligation to seek the best execution of client trades. A review is regularly conducted to
recommend a custodian to our clients, in light of our duty to seek the best execution.
In our Firm’s discretion, and following our custodian’s authorization, we may accept the client’s transfer of
preexisting retail mutual funds into their account. A transfer-in-kind of retail share-class mutual funds may
benefit the client by enabling them to invest in their portfolio more quickly, mitigate tax and/or short-term
trading liabilities, and/or avoid contingent deferred sales charges (CDSC). Our Firm regularly reviews
accounts that have transferred between different share classes of mutual funds and will convert to a lower-
expense share class when we believe doing so would be beneficial to the client. In addition, if account assets
remain in a retail share class and within a CDSC period, we may exclude those assets from our advisory fee
until they have been converted to what we believe is a more appropriate share class.
While our Firm has access to a broad range of securities through our custodian, that range remains finite. In
addition, not all investment managers, share classes, etc., are represented at each custodian. Due to these
normal and customary limitations, not all portfolio holdings will be readily available, least expensive, best
performing, etc. It is an unrealistic expectation for an investor to maintain a premise otherwise.
Directed Brokerage
Our internal policy and operational relationship with our custodian require client accounts custodied with
them to have trades executed per their order routing requirements. We do not direct which executing
broker should be selected for client account trades, whether that is an affiliate of our preferred custodian or
another executing broker of our custodian’s choice. As a result, the client may pay higher commissions or
other transaction costs, experience greater spreads, or receive less favorable net prices on transactions than
might otherwise be the case. In addition, since we routinely recommend a custodian to our advisory clients,
and that custodian may choose to use the execution services of its broker affiliate for some or all of our
client account transactions, there is an inherent conflict of interest involving our recommendation since the
Firm receives various products or services described in Item 14 from that custodian. Note that we are not
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compensated for trade routing/order flow, nor are we paid commissions on such trades. We do not receive
interest on an account’s cash balance.
Client accounts maintained at our custodian cannot be used for direct brokerage. As a result, they may pay
higher commissions or other transaction costs, potentially experience greater spreads, or receive less
favorable net prices on transactions for their account than would otherwise be the case if they had the
opportunity to direct brokerage.
For accounts maintained at a custodian of the client’s choice (e.g., held-away accounts), the client may
choose to request that a particular broker is used to execute some or all account transactions. Under these
circumstances, the client will be responsible for negotiating, in advance of each trade, the terms and/or
arrangements for their account with that broker, including whether the selected broker is affiliated with
their custodian of record. We will not be obligated to seek better execution services or prices from these
other brokers, and we will be unable to aggregate transactions for execution via our custodian with other
orders for accounts managed by our Firm. As a result, the client may pay higher commissions or other
transaction costs, potentially experience greater spreads, or receive less favorable net prices on transactions
for their account than would otherwise be the case.
Aggregating Securities Transactions for Client Accounts
Trade aggregation involves the purchase or sale of the same security for several clients/accounts at
approximately the same time. This may also be termed “blocked” or “batched” orders. Aggregated orders
are effected to obtain better execution, negotiate favorable transaction rates, or to allocate equitably
among multiple client accounts should there be differences in prices, brokerage commissions or other
transactional costs that might otherwise be unobtainable through separately placed orders. Our Firm may,
but is not obligated to, aggregate orders, and our Firm does not receive additional compensation or
remuneration for aggregated transactions.
Transaction charges and/or prices may vary due to account size and/or method of receipt. To the extent that
the Firm determines to aggregate client orders for the purchase or sale of securities, including securities in
which a related person may invest, the Firm will generally do so in accordance with the parameters set forth
in SEC No Action Letter, SMC Capital, Inc., or similar guidance if the jurisdiction in which the client resides
provides such direction. We will provide a copy of the referenced No Action Letter upon request.
Please note that when trade aggregation is not allowed or infeasible and necessitates individual transactions
(e.g., withdrawal or liquidation requests, odd-lot trades, non-discretionary accounts, etc.), an account may
potentially be assessed higher costs or less favorable prices than those where aggregation has occurred.
We review the Firm's trading processes periodically to ensure they remain in compliance with stated policies
and regulations. Our clients will be informed in advance should trading practices change at any point in the
future.
Trade Errors
The Firm corrects its trade errors through an account maintained by our custodian, and the Firm may be
responsible for certain trading error losses that occur within a client account. Clients should be aware that
trading gains in accounts maintained at Charles Schwab are swept to a designated account and donated to a
501(c)(3) charity of Charles Schwab’s choice, and Charles Schwab will be obligated to disclose in their own
literature to account holders whether such recipients’ receipt of such donations presents a material conflict
of interest.
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Item 13 - Review of Accounts
Periodic Reviews of Client Accounts
Client financial check-ups or reviews are recommended annually for clients who receive our financial
planning services. Reviews will be conducted by your assigned investment advisor representative and
typically involve analysis and possible revision of your previous financial plan or investment allocation. A
copy of the revised plans or asset allocation reports, in print or digital format, will be provided to the client
upon request. Unless provided for in the engagement agreement, reviews are generally conducted under a
new or amended agreement and will be assessed at our current fee rate.
Portfolios are reviewed on a quarterly or more frequent basis by your assigned investment advisor
representative and/or Mr. Nestman. Client-level reviews are also completed by your assigned investment
advisor representative, and we recommend they occur at least annually. A copy of a revised investment
guideline or an asset allocation report, in print or digital format, will be provided to the client upon request.
Client Reviews on a Non-Periodic Basis
The client should contact our Firm for additional reviews when it is anticipated, or they have experienced
changes in their financial situation (i.e., changes in employment, an inheritance, the birth of a new child,
etc.), or if the client prefers to change requirements involving an investment account. Non-periodic reviews
are conducted by your assigned investment advisor representative under a new or amended agreement,
and fees may be assessed at our published rate. A copy of revised plans or asset allocation reports in printed
or digital format will be provided to the client upon request.
Additional portfolio reviews by your assigned investment advisor representative and/or Mr. Nestman may
be triggered by news or research related to a specific holding, a change in our view of the investment merits
of a holding, or news related to the macroeconomic climate affecting a sector or holding within that sector.
A portfolio may be reviewed for an additional holding or when an increase in a current position is under
consideration. Account cash levels that are above or below what we deem appropriate for the investment
environment, given the client's stated risk tolerance and investment objectives, may also trigger a review.
Client Reports
Whether the client has opened and maintained an investment account on their own or with our assistance,
they will receive account statements from the mutual fund companies, transfer agents, custodians, or
brokerage firms where their investments are held. We urge each client to carefully review these account
statements for accuracy and clarity and to ask questions if anything is unclear.
Our Firm may produce its own performance reports, in printed or digital format, calculated using a time-
weighted methodology and reviewed for accuracy by Mr. Nestman prior to delivery. The reports are
intended to inform clients about their investment performance over the current period and over the long
term since the account’s inception, both on an absolute basis and relative to a known benchmark. These
reports are periodically back-tested by Mr. Nestman. Clients are urged to carefully review and compare
account statements that they have received directly from their custodian of record with any report they may
receive from our Firm or any other source that contains account performance information.
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Item 14 - Client Referrals and Other Compensation
Referral Arrangements
We have a referral arrangement with Wells Fargo Advisors Financial Network, LLC (“Adviser”) to introduce
or refer prospective investors to the Adviser. We will receive compensation for such referrals as agreed
upon in writing and disclosed to the respective clients. The compensation paid to us is contingent upon a
prospective client engaging Adviser for investment advisory services. Therefore, we have a financial
incentive to recommend Adviser. This creates a conflict of interest; however, we address it by disclosing the
referral relationship and acknowledging that a prospective client is not obligated to engage the Adviser for
advisory services.
Soft dollars
As disclosed in Item 12, our Firm may receive economic benefit from Charles Schwab in the form of various
products and services they make available to the Firm and other independent investment advisors that may
not be made available to a “retail investor.” There is no direct link between our Firm’s participation in their
program and the investment advice we may provide to our clients. These benefits may include the following
products and services (provided either without cost or at a discount):
• receipt of duplicate client statements and confirmations.
• research related products and tools.
• access to trading desks serving our clients.
• access to block trading services.
• the ability to have advisory fees deducted directly from a client’s accounts (per written agreement)
• resource information related to capital markets and various investments.
• access to an electronic communications network for client order entry and account information.
• access to mutual funds with no transaction fees and/or select investment managers.
• discounts on marketing, research, technology, and practice management products or services provided
to our Firm by third-party providers.
Some of the products and services offered by Charles Schwab may benefit our advisory Firm but may not
directly benefit a client account. While our Firm does not consider these services to be "brokerage or
research services" under Section 28(e) of the Securities Exchange Act of 1934, certain jurisdictions in which
we serve client accounts believe they fall under this definition. The availability of these services from Charles
Schwab benefits our Firm because it does not have to produce or purchase them, provided Firm clients
maintain assets in accounts at Charles Schwab. There is a conflict of interest because our Firm has an
incentive to select or recommend a custodian based on our Firm’s interest in receiving these benefits, rather
than your interest in obtaining favorable trade execution. It is important to mention that the benefit
received by our Firm through participation in any custodian’s program does not depend on the amount of
brokerage transactions directed to that custodian, and our selection of a custodian is primarily supported by
the scope, quality, and cost of services provided as a whole -- not just those services that benefit only our
advisory Firm. Further, we will act in the best interest of our clients regardless of the custodian we may
select.
Professional Relationships.
An associate of the Firm may hold individual membership or serve on boards or committees of professional
industry associations. Generally, participation in any of these entities requires membership fees to be paid,
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adherence to ethical guidelines, as well as in meeting experiential and educational requirements. A benefit
these entities may provide to the investing public is the availability of online search tools that allow
interested parties (prospective clients) to search for individual participants within a selected state or region.
These passive websites may provide means for interested persons to contact a participant via electronic
mail, telephone number, or other contact information, to interview the participating member.
The public may also choose to telephone the association staff to inquire about an individual within their
area and would receive the same or similar information. A portion of these participant’s membership fees
may be used so that their name will be listed on some or all these entities’ websites (or other listings).
Prospective clients locating our advisory Firm or an associate via these methods are not actively marketed
by the noted associations. Clients who find our Firm in this way do not pay more for their services than
clients referred in any other fashion. The Firm does not pay these entities for prospective client referrals,
nor is there a fee-sharing arrangement reflective of a solicitor engagement.
Item 15 - Custody
Our clients’ assets will be maintained by an unaffiliated, qualified custodian, such as a bank, broker/dealer,
trust company, mutual fund company, or transfer agent. Assets are not held by our Firm or any associate of
our Firm. In keeping with this policy involving our client funds or securities, our Firm:
• Restricts the Firm or an associate from serving as trustee or having general power of attorney over a
client account.
• Prohibits any associate from having authority to directly withdraw securities or cash assets from a client
account. Although we may be deemed to have “constructive custody” of client assets since we may
request the withdrawal of advisory fees from your account, we will only do so through the engagement
of a qualified custodian maintaining client assets, via the client’s prior written approval, and following
the delivery of our written invoice (see Item 5 for details).
• Does not accept or forward client securities (i.e., stock certificates) erroneously delivered to our Firm.
• Will not collect advance fees of $500 or more for services that are to be performed six months or more
into the future; and
• Will not authorize an associate to have knowledge of a client’s account access information (i.e., online
401(k), brokerage or bank accounts) if such access would allow physical control over account assets.
While most advisory firm associates at Udall CPA Group, PLLC are Certified Public Accountants (CPAs), they
do not serve clients in a capacity that would be considered to have physical custody (control) of an account.
The client’s custodian of record will provide the client with investment account transaction confirmations
and account statements, including all debits and credits, as well as our Firm’s advisory fee for that period.
Statements are provided on at least a quarterly basis or as transactions occur within the client’s account.
West Ridge Advisors will not create an account statement for a client or serve as the sole recipient of an
account statement.
Standing Letters of Authority
West Ridge Advisors has been deemed to have inadvertent custody because of your providing us with
Standing Letters of Authorization (“SLOA(s)”) to withdraw funds from your portfolio account to pay third
parties. Notwithstanding that, a surprise examination is not required as we are relying on the conditions set
forth in the No-Action letter issued by the Securities and Exchange Commission on February 21, 2017.
Pursuant to the conditions set forth in the No-Action Letter, West Ridge Advisors confirms that (1) you provide
an instruction to the qualified custodian, in writing, that includes the your signature, the third party’s name,
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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) you authorize us, 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) Schwab performs
appropriate verification of the instruction, such as a signature review or other method to verify the your
authorization, and Schwab provides a transfer of funds notice to you promptly after each transfer; (4) you
have the ability to terminate or change the instruction to Schwab; (5) we have 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 your instruction; (6) we maintain records showing that the third party is not a related party
of West Ridge Advisors or located at the same address as West Ridge Advisors; and (7) Schwab sends you, in
writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction.
Clients are reminded that if they receive a report from any source that includes investment performance
information, they are urged to carefully review and compare the report with their account statements that
they have received directly from their custodian of record.
Item 16 - Investment Discretion
We typically serve accounts on a discretionary basis. Under a limited power of attorney, discretionary
authority allows our Firm to implement investment decisions, such as the purchase or sale of a security on
behalf of an account, without requiring the client’s prior authorization for each transaction, provided the
transaction meets stated investment objectives. This authority will be granted by the client upon execution
of both our engagement agreement and the selected custodian’s account-opening documents.
Note that the custodian will specifically limit our Firm’s authority within an account to the placement of
trade orders and our request for the deduction of our advisory fees.
Our Firm prefers not to manage client accounts on a nondiscretionary basis, but we may accommodate such
requests on a case-by-case basis. Such account authority requires the client’s ongoing prior approval for the
investment and reinvestment of account assets, portfolio rebalancing, or for our Firm to give instructions to
the custodian maintaining the account (e.g., wire instructions). The client will be required to execute our
Firm’s client services agreement, which describes our limited account authority, as well as the custodian of
record’s account opening document, which includes their limited power of attorney form or clause. Please
note that, considering the requirement for pre-approval, the client must make themselves available and
keep our Firm updated on their contact information so that instructions can be efficiently effected on their
behalf. In addition, nondiscretionary accounts are generally unable to be aggregated (see Item 12) and may
therefore be assessed higher trading fees or receive less favorable prices than those accounts where trade
aggregation has occurred.
As noted in Item 4, we will allow for reasonable restrictions that we will note in your written investment
guidelines involving the management of an account. It remains the client’s responsibility to notify us if there
is any change in their situation and/or investment objective so that we may reevaluate previous investment
recommendations or portfolio holdings.
Item 17 - Voting Client Securities
Account holders may periodically receive proxies or other similar solicitations sent directly from their
custodian or transfer agent. Should we receive a duplicate copy, note that we do not forward these or any
correspondence relating to the voting of your securities, class action litigation, or other corporate actions.
Our Firm does not vote proxies on behalf of an account holder, including accounts for which we have
discretionary authority. We do not offer guidance on how to vote proxies, nor will we offer guidance
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involving any claim or potential claim in any bankruptcy proceeding, class action securities litigation or other
litigation or proceeding relating to securities held at any time in a client account, including, without
limitation, to file proofs of claim or other documents related to such proceeding, or to investigate, initiate,
supervise or monitor class action or other litigation involving client assets. We will answer limited questions
with respect to what a proxy voting request or other corporate matter may be and how to reach the issuer
or its legal representative.
Each account holder will maintain exclusive responsibility for directing the manner in which proxies solicited
by issuers of securities that are beneficially owned by you shall be voted, as well as making all other
elections relative to mergers, acquisitions, tender offers or other legal matters or events pertaining to your
holdings.
Clients should consider contacting the issuer or their legal counsel regarding specific questions they may
have regarding a particular proxy solicitation or corporate action.
Item 18 - Financial Information
We are required to provide you with certain financial information or disclosures about any financial
condition that would impede our ability to provide the advisory services described herein. West Ridge
Advisors has no financial obligations that impair its ability to meet contractual and fiduciary obligations to
clients and has not been the subject of bankruptcy proceedings.
Item 19 - Requirements for State-Registered Advisers
This Item 19 is not applicable to investment advisers registered with the SEC.
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