Overview
Assets Under Management: $185 million
Headquarters: LOS ANGELES, CA
High-Net-Worth Clients: 38
Average Client Assets: $8 million
Services Offered
Services: Portfolio Management for Individuals
Fee Structure
Primary Fee Schedule (ADV PART 2A-WESTWOOD WEALTH MANAGEMENT, LLC - MARCH 2024)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $5,000,000 | 1.50% |
| $5,000,001 | $7,500,000 | 1.25% |
| $7,500,001 | $10,000,000 | 1.00% |
| $10,000,001 | and above | Negotiable |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $15,000 | 1.50% |
| $5 million | $75,000 | 1.50% |
| $10 million | $131,250 | 1.31% |
| $50 million | Negotiable | Negotiable |
| $100 million | Negotiable | Negotiable |
Clients
Number of High-Net-Worth Clients: 38
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 90.23
Average High-Net-Worth Client Assets: $8 million
Total Client Accounts: 192
Discretionary Accounts: 192
Regulatory Filings
CRD Number: 290658
Last Filing Date: 2024-03-29 00:00:00
Website: https://westwoodwealthmgmt.com
Form ADV Documents
Primary Brochure: ADV PART 2A-WESTWOOD WEALTH MANAGEMENT, LLC - MARCH 2024 (2025-10-03)
View Document Text
Westwood Wealth Management
11150 Santa Monica Blvd., Suite 740
Los Angeles, CA 90025
Telephone: (424) 255-3120
October 3, 2025
FORM ADV PART 2A
BROCHURE
This brochure provides information about the qualifications and business practices of Westwood
Wealth Management. If you have any questions about the contents of this brochure, contact us at
(424) 255-3120. The information in this brochure has not been approved or verified by the United
States Securities and Exchange Commission or by any state securities authority.
Additional information about Westwood Wealth Management is available on the SEC's website at
www.adviserinfo.sec.gov. Westwood Wealth Management's CRD number is: 290658.
Westwood Wealth Management is a registered investment adviser. Registration with the United States
Securities and Exchange Commission or any state securities authority does not imply a certain level of
skill or training.
1
Item 2 Summary of Material Changes
Form ADV Part 2 requires registered investment advisers to amend their brochure when information
becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure,
the adviser is required to notify you and provide you with a description of the material changes.
Since our last annual updating amendment, dated March 29, 2024, we have made the following
material changes to our Form ADV:
Cover Page
We have updated our principal office address. Please refer to the Cover Page of this brochure for the
specific address.
Advisory Services
Item 4
Portfolio Management Services
We offer discretionary portfolio management services. Our investment advice is tailored to meet our
clients' needs and investment objectives. Our investment advice is tailored to meet your needs and
investment objectives. You may limit our discretionary authority (for example, limiting the types of
securities that can be purchased or sold for your account) by providing our firm with your restrictions
and guidelines in writing.
If you retain us for portfolio management services, we will meet with you to determine your investment
objectives, risk tolerance, liquidity needs, and other relevant information (the "suitability information") at
the beginning of our advisory relationship. We will use the suitability information we gather to develop a
strategy that enables us to give you continuous and focused investment advice and/or to make
investments on your behalf.
Private Pooled Investment Vehicles
Westwood Wealth Management serves as the Manager and the Adviser to Westwood Alpha
Opportunity Fund, LP. ("Fund"). Westwood Wealth Management will manage the assets of the Fund on
a discretionary basis in accordance with the overall investment objective of the Fund. The detailed
terms, objectives, restrictions (if any), strategies and risks applicable to the Fund are described in the
Fund's organizational, offering documents, investment management agreement, and/or subscription
agreements, as the case may be (each and collectively, the "Governing Documents"). The Fund is
available for investment only by institutional investors and other sophisticated, high-net worth
investors, who meet the eligibility requirements of the Fund set forth in its Governing Documents.
Types of Investments
Westwood Wealth Management primarily offers advice on exchange traded funds ("ETFs"), mutual
funds, stocks, United States government securities, option contracts, pooled investment vehicles, and
money market funds. Additionally, we may advise you on various types of investments based on your
stated goals and objectives.
Wrap Fee Programs
We do not participate in any wrap fee programs.
IRA Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field
Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's
Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the
following acknowledgment to you. When we provide investment advice to you regarding your
retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I
2
of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable,
which are laws governing retirement accounts. We benefit financially from the rollover of your assets
from a retirement account to an account that we manage or provide investment advice, because the
assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only
recommend a rollover when we believe it is in your best interest.
Refer to Advisory Services for further information.
Item 5 Fees and Compensation
Portfolio Management Services
Westwood Wealth Management's annual fee for portfolio management services is based on a
percentage of the assets in your account and is set forth in the following annual fee schedule:
Assets Under Management
Annual Fee
Up to $5,000,000
1.50%
$5,000,001 - $7,500,000
1.25%
$7,500,001 - $10,000,000
1.00%
Over $10,000,000
Negotiable
Westwood Wealth Management's annual portfolio management fee is billed and payable quarterly
arrears based on the balance at end of billing period. Our advisory fee is negotiable, depending on
individual client circumstances. Assets in each of your account(s) are included in the fee assessment
unless specifically identified in writing for exclusion. If the portfolio management agreement is executed
at any time other than the first day of a calendar quarter, our fees will apply on a pro rata basis.
At our discretion, we may combine the account values of family members living in the same household
to determine the applicable advisory fee. We will deduct our fee directly from your account through the
qualified custodian holding your funds and securities. We will deduct our advisory fee only when you
have given our firm written authorization permitting the fees to be paid directly from your account.
Further, the qualified custodian will deliver an account statement to you at least quarterly. You may
terminate the portfolio management agreement upon 30 days written notice. You will incur a pro rata
charge for services rendered prior to the termination of the portfolio management agreement.
Private Pooled Investment Vehicle Fees
Westwood Wealth Management serves as the Manager and the Adviser to Westwood Alpha
Opportunity Fund, LP. ("Fund"). Westwood Wealth Management will manage the assets of the Fund on
a discretionary basis in accordance with the overall investment objective of the Fund. All fees paid for
investment advisory services are separate and distinct from the fees and expenses charged by the
Fund. These fees and expenses are described in the Fund's offering documents.
Additional Fees and Expenses
As part of our investment advisory services to you, we may invest, or recommend that you invest, in
mutual funds and exchange traded funds. The fees that you pay to our firm for investment advisory
services are separate and distinct from the fees and expenses charged by mutual funds or exchange
traded funds (described in each fund's prospectus) to their shareholders.
3
Refer to Fees and Compensation for further information.
Item 6 Performance-Based Fees and Side-By-Side Management
We do not accept performance-based fees or participate in side-by-side management. Performance-
based fees are fees that are based on a share of a capital gains or capital appreciation of a client's
account. Side-by-side management refers to the practice of managing accounts that are charged
performance-based fees while at the same time managing accounts that are not charged performance-
based fees. Refer to Performance-Based Fees and Side-By-Side Management for further information.
Item 7 Types of Clients
Westwood Wealth Management offers investment advisory services to individuals, high net worth
individuals, pension and profit-sharing plans, business entities, and pooled investment vehicles. In
general, WWM does not require a minimum dollar amount to open and maintain an advisory
account. The minimum investment amount in Westwood Alpha Opportunity Fund LP is
$100,000. WWM can accept lesser amounts in its sole discretion. Refer to Types of Clients for further
information.
Methods of Analysis, Investment Strategies and Risk of Loss
Item 8
A description of the types of securities/investments we may recommend to you and some of their
inherent risks associated with these securities/investments were added to Item 8 - Methods of
Analysis, Investment Strategies, and Risk of Loss. Refer to Methods of Analysis, Investment Strategies
and Risk of Loss for further information.
Item 9 Disciplinary Information
We are required to disclose the facts of any legal or disciplinary events that are material to a client's
evaluation of our advisory business or the integrity of our management. There are no legal, regulatory,
or disciplinary events involving Westwood Wealth Management or its owner. Refer to Disciplinary
Information for further information.
Item 10 Other Financial Industry Activities and Affiliations
Westwood Wealth Management serves as the Manager and the Adviser to Westwood Alpha
Opportunity Fund (the "Fund"), a private pooled investment vehicle in which you may be solicited to
invest. The Fund is offered to certain sophisticated investors, who meet certain requirements under
applicable state and/or federal securities laws. Investors to whom the Fund is offered will receive a
private placement memorandum and other offering documents. The fees charged by the Fund are
separate and apart from our advisory fees. You should refer to the offering documents for a complete
description of the fees, investment objectives, risks and other relevant information associated with
investing in the Fund. Persons affiliated with our firm have made an investment in the Fund and have
an incentive to recommend the Fund over other investments. Private investment funds generally
involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity
constraints and lack of transparency, a complete discussion of which is set forth in each fund's offering
documents, which will be provided to each client for review and consideration. Refer to Other Financial
Industry Activities and Affiliations for further information.
Item 11 Code of Ethics, Participation in Client Transactions and Personal Trading
Description of Our Code of Ethics
We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code
of Ethics includes guidelines for professional standards of conduct for persons associated with our
firm. Our goal is to protect your interests at all times and to demonstrate our commitment to our
fiduciary duties of honesty, good faith, and fair dealing with you. All persons associated with our firm
are expected to adhere strictly to these guidelines. Persons associated with our firm are also required
4
to report any violations of our Code of Ethics. Additionally, we maintain and enforce written policies
reasonably designed to prevent the misuse or dissemination of material, nonpublic information about
you or your account holdings by persons associated with our firm.
Participation or Interest in Client Transactions
Westwood Wealth Management serves as the Manager and the Adviser to Westwood Alpha
Opportunity Fund, LP ("Fund") in which Clients may be solicited to invest. Westwood Wealth
Management and certain members of its management may acquire, directly or indirectly, investment
interests in the Fund or have other financial interests (e.g., General Partner) in the Fund. This presents
a conflict of interest because Westwood Wealth Management has investments and/or is compensated
by the Fund.
Personal Trading Practices
Our firm or persons associated with our firm buy or sell the same securities that we recommend to you
or securities in which you are already invested. A conflict of interest exists in such cases because we
have the ability to trade ahead of you and potentially receive more favorable prices than you will
receive.
Aggregated Trading
Our firm or persons associated with our firm may buy or sell securities for you at the same time we or
persons associated with our firm buy or sell such securities for our own account. We do not combine
multiple orders for shares of the same securities purchased for advisory accounts we manage (the
practice of combining multiple orders for shares of the same securities is commonly referred to as
"aggregated trading").Refer to the Brokerage Practices section in this brochure for information on our
aggregated trading practices. A conflict of interest exists in such cases because we have the ability to
trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate
this conflict of interest, it is our policy that neither our firm nor persons associated with our firm shall
have priority over your account in the purchase or sale of securities.
Refer to Code of Ethics, Participation in Client Transactions and Personal Trading for further
information.
Item 12 Brokerage Practices and Item 14 Client Referrals and Other Compensation
We recommend the brokerage and custodial services of LPL Financial. Additional disclosure language
was added regarding our relationship with LPL Financial. Refer to Brokerage Practices and Client
Referrals and Other Compensation for further information.
Item 13 Review of Accounts
Michael A. Puryear, President and Chief Compliance Office of Westwood Wealth Management
will monitor your accounts on an ongoing basis and will conduct account reviews at least
annually to ensure the advisory services provided to you are consistent with your investment needs
and objectives. Upon request, we will provide you with additional or regular written reports in
conjunction with the annual account reviews. You will receive trade confirmations and monthly or
quarterly statements from your account custodian(s). Refer to Review of Accounts for further
information.
Item 15 Custody
Direct Debiting of Fees
Your independent custodian will directly debit your account(s) for the payment of our advisory fees.
This ability to deduct our advisory fees from your accounts causes our firm to exercise limited custody
over your funds or securities. We do not have physical custody of any of your funds and/or securities.
Your funds and securities will be held with a bank, broker-dealer, or other qualified custodian. You will
5
receive account statements from the qualified custodian(s) holding your funds and securities at least
quarterly. The account statements from your custodian(s) will indicate the amount of our advisory fees
deducted from your account(s) each billing period. You should carefully review account statements for
accuracy.
Private Pooled Investment Vehicle
Westwood Wealth Management serves as the investment adviser to Westwood Alpha Opportunity
Fund LP ("Fund,"), a private pooled investment vehicle in which our clients are not solicited to invest.
The Fund is offered to certain sophisticated investors, who meet certain requirements under applicable
state and/or federal securities laws. Investors to whom the Fund is offered will receive a private
placement memorandum and other offering documents. The fees charged by the Fund are separate
and apart from our advisory fees. You should refer to the offering documents for a complete
description of the fees, investment objectives, risks and other relevant information associated with
investing in the Fund. Persons affiliated with our firm may have made an investment in the Fund and
may have an incentive to recommend the Fund over other investments. In our capacity as investment
adviser to the Fund, we will have access to the Fund's funds and securities, and therefore have
custody over such funds and securities. We provide each investor in the Fund with audited annual
financial statements. If you are a Fund investor and have questions regarding the financial statements
or if you did not receive a copy, contact us directly at the telephone number on the cover page of this
brochure.
Refer to Custody for further information.
Investment Discretion
Before we can buy or sell securities on your behalf, you must first sign our discretionary management
agreement and the appropriate trading authorization forms. You may grant our firm discretion over the
selection and amount of securities to be purchased or sold for your account(s) without obtaining your
consent or approval prior to each transaction. You may specify investment objectives, guidelines,
and/or impose certain conditions or investment parameters for your account(s). Refer to Investment
Discretion for further information.
Financial Information
Item 18
Our firm does not have any financial condition or impairment that would prevent us from meeting our
contractual commitments to you. We do not take physical custody of client funds or securities, or serve
as trustee or signatory for client accounts. WWM is not required to deliver a balance sheet along with
this Disclosure Brochure, as we do not collect advance fees of $1,200 or more for services to be
performed six months or more in the future. We have not been subject to a bankruptcy petition at any
time in the past ten years. Refer to Financial Information for further information.
Item 19 Requirements for State Registered Advisers
We are a federally registered investment adviser; therefore, we are not required to respond to this
item.
Additional Information
Item 20
Trade Errors
In the event a trading error occurs in your account, our policy is to restore your account to the position
it should have been in had the trading error not occurred. Depending on the circumstances, corrective
actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account.
6
Class Action Lawsuits
We do not determine if securities held by you are the subject of a class action lawsuit or whether you
are eligible to participate in class action settlements or litigation nor do we initiate or participate in
litigation to recover damages on your behalf for injuries as a result of actions, misconduct, or
negligence by issuers of securities held by you.
IRA Rollover Considerations
As part of our investment advisory services to you, we may recommend that you withdraw the assets
from your employer's retirement plan and roll the assets over to an individual retirement account
("IRA") that we will manage on your behalf. If you elect to roll the assets to an IRA that is subject to our
management, we will charge you an asset based fee as set forth in the agreement you executed with
our firm. This practice presents a conflict of interest because persons providing investment advice on
our behalf have an incentive to recommend a rollover to you for the purpose of generating fee based
compensation rather than solely based on your needs. You are under no obligation, contractually or
otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no
obligation to have the assets in an IRA managed by our firm.
Refer to Additional Information for further information.
7
Item 3 Table of Contents
Item 1 Cover Page
Item 2 Summary of Material Changes
Item 3 Table of Contents
Item 4 Advisory Business
Item 5 Fees and Compensation
Item 6 Performance-Based Fees and Side-By-Side Management
Item 7 Types of Clients
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Item 9 Disciplinary Information
Item 10 Other Financial Industry Activities and Affiliations
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Item 12 Brokerage Practices
Item 13 Review of Accounts
Item 14 Client Referrals and Other Compensation
Item 15 Custody
Item 16 Investment Discretion
Item 17 Voting Client Securities
Item 18 Financial Information
Item 19 Requirements for State-Registered Advisers
Item 20 Additional Information
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Page 8
Page 9
Page 10
Page 12
Page 12
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Item 4 Advisory Business
Description of Firm
Westwood Wealth Management ("WWM") is a registered investment adviser based in Los Angeles,
California. We are organized as a corporation under the laws of the State of United States. We have
been providing investment advisory services since October 2017. Michael A. Puryear is the principal
owner.
The following paragraphs describe our services and fees. Refer to the description of each investment
advisory service listed below for information on how we tailor our advisory services to your individual
needs. As used in this brochure, the words "we," "our," and "us" refer to Westwood Wealth
Management and the words "you," "your," and "client" refer to you as either a client or prospective
client of our firm.
Portfolio Management Services
We offer discretionary portfolio management services. Our investment advice is tailored to meet our
clients' needs and investment objectives. Our investment advice is tailored to meet your needs and
investment objectives. If you retain us for our discretionary portfolio management services, we require
you to grant our firm discretionary authority to manage your account. Discretionary authorization will
allow us to determine the specific securities, and the amount of securities, to be purchased or sold for
your account without your approval prior to each transaction. Discretionary authority is typically granted
by the investment advisory agreement you sign with our firm, and the appropriate trading authorization
forms. You may limit our discretionary authority (for example, limiting the types of securities that can be
purchased or sold for your account) by providing our firm with your restrictions and guidelines in
writing.
If you retain us for portfolio management services, we will meet with you to determine your investment
objectives, risk tolerance, liquidity needs, and other relevant information (the "suitability information") at
the beginning of our advisory relationship. We will use the suitability information we gather to develop a
strategy that enables us to give you continuous and focused investment advice and/or to make
investments on your behalf. As part of our portfolio management services, we will customize an
investment portfolio for you in accordance with your risk tolerance and investing objectives. Once we
construct an investment portfolio for you, we will monitor your portfolio's performance on an ongoing
basis, and will rebalance the portfolio as required by changes in market conditions and in your financial
circumstances.
Private Pooled Investment Vehicle
Westwood Wealth Management serves as the Manager and the Adviser to Westwood Alpha
Opportunity Fund, LP. ("Fund"). Westwood Wealth Management will manage the assets of the Fund on
a discretionary basis in accordance with the overall investment objective of the Fund. The detailed
terms, objectives, restrictions (if any), strategies and risks applicable to the Fund are described in the
Fund's organizational, offering documents, investment management agreement, and/or subscription
agreements, as the case may be (each and collectively, the "Governing Documents"). The Fund is
available for investment only by institutional investors and other sophisticated, high-net worth
investors, who meet the eligibility requirements of the Fund set forth in its Governing Documents. The
Fund is exempt from registration as an investment company under the U.S. Investment Company Act,
as amended (the "Investment Company Act"), under Section 3(c)(1). Investors and prospective
investors should refer to the offering documents for the Funds for a complete description of the risks,
investment objectives and strategies, fees and other relevant information pertaining to investments
in the Fund.
9
Types of Investments
Westwood Wealth Management primarily offers advice on exchange traded funds ("ETFs"), mutual
funds, stocks, United States government securities, option contracts, pooled investment vehicles, and
money market funds. Refer to the Methods of Analysis, Investment Strategies and Risk of Loss below
for additional disclosures on this topic.
Additionally, we may advise you on various types of investments based on your stated goals and
objectives. We may also provide advice on any type of investment held in your portfolio at the inception
of our advisory relationship. Since our investment strategies and advice are based on each client's
specific financial situation, the investment advice we provide to you may be different or conflicting with
the advice we give to other clients regarding the same security or investment.
Wrap Fee Programs
We do not participate in any wrap fee programs.
IRA Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field
Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's
Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the
following acknowledgment to you. When we provide investment advice to you regarding your
retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I
of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable,
which are laws governing retirement accounts. The way we make money creates some conflicts with
your interests, so we operate under a special rule that requires us to act in your best interest and not
put our interest ahead of yours. Under this special rule's provisions, 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.
We benefit financially from the rollover of your assets from a retirement account to an account that we
manage or provide investment advice, because the assets increase our assets under management
and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in
your best interest.
Assets Under Management
As of December 2024, we provide continuous management services for $338,806,901 in client assets
on a discretionary basis. All assets are managed on a discretionary basis. We do not manage client
assets on a non-discretionary basis.
Item 5 Fees and Compensation
Portfolio Management Services
Westwood Wealth Management's annual fee for portfolio management services is based on a
percentage of the assets in your account and is set forth in the following annual fee schedule:
10
Annual Fee Schedule
Assets Under Management
Annual Fee
Up to $5,000,000
1.50%
$5,000,001 - $7,500,000
1.25%
$7,500,001 - $10,000,000
1.00%
Over $10,000,000
Negotiable
Westwood Wealth Management's annual portfolio management fee is billed and payable quarterly
arrears based on the balance at end of billing period. Our advisory fee is negotiable, depending on
individual client circumstances. Assets in each of your account(s) are included in the fee assessment
unless specifically identified in writing for exclusion. If the portfolio management agreement is executed
at any time other than the first day of a calendar quarter, our fees will apply on a pro rata basis, which
means that the advisory fee is payable in proportion to the number of days in the quarter for which you
are a client.
At our discretion, we may combine the account values of family members living in the same household
to determine the applicable advisory fee. For example, we may combine account values for you and
your minor children, joint accounts with your spouse, and other types of related accounts. Combining
account values may increase the asset total, which may result in your paying a reduced advisory fee
based on the available breakpoints in our fee schedule stated above.
We will deduct our fee directly from your account through the qualified custodian holding your funds
and securities. We will deduct our advisory fee only when you have given our firm written authorization
permitting the fees to be paid directly from your account. Further, the qualified custodian will deliver an
account statement to you at least quarterly. These account statements will show all disbursements
from your account. We encourage you to review the statement(s) you receive from the qualified
custodian. If you find any inconsistent information, please call our main office number located on the
cover page of this brochure.
You may terminate the portfolio management agreement upon 30 days written notice. You will incur a
pro rata charge for services rendered prior to the termination of the portfolio management agreement,
which means you will incur advisory fees only in proportion to the number of days in the quarter for
which you are a client. If you have pre-paid advisory fees that we have not yet earned, you will receive
a prorated refund of those fees.
Private Pooled Investment Vehicle Fees
Westwood Wealth Management serves as the Manager and the Adviser to Westwood Alpha
Opportunity Fund, LP. ("Fund"). Westwood Wealth Management will manage the assets of the Fund on
a discretionary basis in accordance with the overall investment objective of the Fund. All fees paid for
investment advisory services are separate and distinct from the fees and expenses charged by the
Fund. These fees and expenses are described in the Fund's offering documents. Such fees will
generally include a management fee, other fund expenses, and a performance based fee. A client
could possibly invest in the Fund directly, without our services. In that case, the client would not
11
receive the services provided by Westwood Wealth Management which are designed, among other
things, to assist the client in determining if the Fund is are appropriate to the client's financial condition
and objectives. Accordingly, the client should review both the fees charged by the Fund and Westwood
Wealth Management to fully understand the total amount of fees to be paid by the client and thereby
evaluate the advisory services being provided.
Additional Fees and Expenses
As part of our investment advisory services to you, we may invest, or recommend that you invest, in
mutual funds and exchange traded funds. The fees that you pay to our firm for investment advisory
services are separate and distinct from the fees and expenses charged by mutual funds or exchange
traded funds (described in each fund's prospectus) to their shareholders. These fees will generally
include a management fee and other fund expenses. You will also incur transaction charges and/or
brokerage fees when purchasing or selling securities. These charges and fees are typically imposed by
the broker-dealer or custodian through whom your account transactions are executed. We do not
share in any portion of the brokerage fees/transaction charges imposed by the broker-dealer or
custodian. To fully understand the total cost you will incur, you should review all the fees charged by
mutual funds, exchange traded funds, our firm, and others. For information on our brokerage practices,
refer to the Brokerage Practices section of this brochure.
Item 6 Performance-Based Fees and Side-By-Side Management
We do not accept performance-based fees or participate in side-by-side management. Performance-
based fees are fees that are based on a share of a capital gains or capital appreciation of a client's
account. Side-by-side management refers to the practice of managing accounts that are charged
performance-based fees while at the same time managing accounts that are not charged performance-
based fees. Our fees are calculated as described in the Fees and Compensation section above, and
are not charged on the basis of a share of capital gains upon, or capital appreciation of, the funds in
your advisory account.
Item 7 Types of Clients
Westwood Wealth Management offers investment advisory services to individuals, high net worth
individuals, pension and profit sharing plans, business entities, and pooled investment vehicles. In
general, WWM does not require a minimum dollar amount to open and maintain an advisory account.
The minimum investment amount in Westwood Alpha Opportunity Fund LP is $100,000. WWM can
accept lesser amounts in its sole discretion.
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Our Methods of Analysis and Investment Strategies
We use one or more of the following methods of analysis or investment strategies when providing
investment advice to you:
Technical Analysis - involves studying past price patterns, trends and interrelationships in the
financial markets to assess risk-adjusted performance and predict the direction of both the overall
market and specific securities.
12
Risk: The risk of market timing based on technical analysis is that our analysis may not accurately
detect anomalies or predict future price movements. Current prices of securities may reflect all
information known about the security and day-to-day changes in market prices of securities may
follow random patterns and may not be predictable with any reliable degree of accuracy.
Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a
company's financial statements, details regarding the company's product line, the experience and
expertise of the company's management, and the outlook for the company and its industry. The
resulting data is used to measure the true value of the company's stock compared to the current
market value.
Risk: The risk of fundamental analysis is that information obtained may be incorrect and the
analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's
value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not
result in favorable performance.
Long-Term Purchases - securities purchased with the expectation that the value of those securities
will grow over a relatively long period of time, generally greater than one year.
Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in
the long-term which may not be the case. There is also the risk that the segment of the market
that you are invested in or perhaps just your particular investment will go down over time even if
the overall financial markets advance. Purchasing investments long-term may create an
opportunity cost - "locking-up" assets that may be better utilized in the short-term in other
investments.
Short-Term Purchases - securities purchased with the expectation that they will be sold within a
relatively short period of time, generally less than one year, to take advantage of the securities' short-
term price fluctuations.
Risk: Using a short-term purchase strategy generally assumes that we can predict how financial
markets will perform in the short-term which may be very difficult and will incur a disproportionately
higher amount of transaction costs compared to long-term trading. There are many factors that
can affect financial market performance in the short-term (such as short-term interest rate
changes, cyclical earnings announcements, etc.) but may have a smaller impact over longer
periods of times.
Short Sales - Unlike a straightforward investment in stocks where you buy shares with the expectation
that their price will increase so you can sell at a profit, in a "short sale" you borrow stocks from your
brokerage firm and sell them immediately, hoping to buy them later at a lower price. Thus, a short
seller hopes that the price of a stock will go down in the near future. A short seller thus uses declines in
the market to his advantage. The short seller makes money when the stock prices fall and losses when
prices go up. The SEC has strict regulations in place regarding short selling.
Risk: Short selling is very risky. Investors should exercise extreme caution before short selling is
implemented. A short seller will profit if the stock goes down in price, but if the price of the shares
increase, the potential losses are unlimited because the stock can keep rising forever. There is no
ceiling on how much a short seller can lose in a trade. The share price may keep going up and the
short seller will have to pay whatever the prevailing stock price is to buy back the shares.
However, gains have a ceiling level because the stock price cannot fall below zero.
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Risk: A short seller has to undertake to pay the earnings on the borrowed securities as long as the
short seller chooses to keep the short position open. If the company declares huge dividends or
issues bonus shares, the short seller will have to pay that amount to the lender. Any such
occurrence can skew the entire short investment and make it unprofitable. The broker can use the
funds in the short seller's margin account to buy back the loaned shares or issue a "call away" to
get the short seller to return the borrowed securities. If the broker makes this call when the stock
price is much higher than the price at the time of the short sale, then the investor can end up
taking huge losses.
Risk: Margin interest can be a significant expense. Since short sales can only be undertaken in
margin accounts, the interest payable on short trades can be substantial, especially if short
positions are kept open over an extended period.
Risk: Shares that are difficult to borrow – because of high short interest, limited float, or any other
reason – have "hard-to-borrow" fees. These fees are based on an annualized rate that can range
from a small fraction of a percent to more than 100% of the value of the short trade. The hard-to-
borrow rate can fluctuate substantially on a daily basis; therefore, the exact dollar amount of the
fee may not be known in advance, and may be substantial.
Margin Transactions - a securities transaction in which an investor borrows money to purchase a
security, in which case the security serves as collateral on the loan.
Risk: If the value of the shares drops sufficiently, the investor will be required to either deposit
more cash into the account or sell a portion of the stock in order to maintain the margin
requirements of the account. This is known as a "margin call." An investor's overall risk includes
the amount of money invested plus the amount that was loaned to them.
Option Writing - a securities transaction that involves selling an option. An option is a contract that
gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price
on or before the expiration date of the option. When an investor sells a call option, he or she must
deliver to the buyer a specified number of shares if the buyer exercises the option. When an investor
sells a put option, he or she must pay the strike price per share if the buyer exercises the option, and
will receive the specified number of shares. The option writer/seller receives a premium (the market
price of the option at a particular time) in exchange for writing the option.
Risk: Options are complex investments and can be very risky, especially if the investor does not
own the underlying stock. In certain situations, an investor's risk can be unlimited.
Trading - We may use frequent trading (in general, selling securities within 30 days of purchasing the
same securities) as an investment strategy when managing your account(s). Frequent trading is not a
fundamental part of our overall investment strategy, but we may use this strategy occasionally when
we determine that it is suitable given your stated investment objectives and tolerance for risk. This may
include buying and selling securities frequently in an effort to capture significant market gains and
avoid significant losses.
Risk: When a frequent trading policy is in effect, there is a risk that investment performance within
your account may be negatively affected, particularly through increased brokerage and other
transactional costs and taxes.
Our investment strategies and advice may vary depending upon each client's specific financial
situation. As such, we determine investments and allocations based upon your predefined objectives,
risk tolerance, time horizon, financial information, liquidity needs and other various suitability factors.
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Your restrictions and guidelines may affect the composition of your portfolio. It is important that you
notify us immediately with respect to any material changes to your financial circumstances, including
for example, a change in your current or expected income level, tax circumstances, or employment
status.
Cash Management
In managing the cash maintained in your account, we utilize the sole exclusive cash vehicle (money
market) made available by the custodian. There may be other cash management options away from
the custodian available to you with higher yields or safer underlying investments. We manage cash
balances in your account based on the yield, and the financial soundness of the money markets and
other short term instruments.
Tax Considerations
Our strategies and investments may have unique and significant tax implications. However, unless we
specifically agree otherwise, and in writing, tax efficiency is not our primary consideration in the
management of your assets. Regardless of your account size or any other factors, we strongly
recommend that you consult with a tax professional regarding the investing of your assets.
Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Your
custodian will default to the First-In First-Out ("FIFO") accounting method for calculating the cost basis
of your investments. You are responsible for contacting your tax advisor to determine if this accounting
method is the right choice for you. If your tax advisor believes another accounting method is more
advantageous, provide written notice to our firm immediately and we will alert your account custodian
of your individually selected accounting method. Decisions about cost basis accounting methods will
need to be made before trades settle, as the cost basis method cannot be changed after settlement.
Risk of Loss
Investing in securities involves risk of loss that you should be prepared to bear. We do not represent or
guarantee that our services or methods of analysis can or will predict future results, successfully
identify market tops or bottoms, or insulate clients from losses due to market corrections or declines.
We cannot offer any guarantees or promises that your financial goals and objectives will be met. Past
performance is in no way an indication of future performance.
Other Risk Considerations
When evaluating risk, financial loss may be viewed differently by each client and may depend on many
different risks, each of which may affect the probability and magnitude of any potential losses. The
following risks may not be all-inclusive, but should be considered carefully by a prospective client
before retaining our services.
Liquidity Risk: The risk of being unable to sell your investment at a fair price at a given time due to high
volatility or lack of active liquid markets. You may receive a lower price or it may not be possible to sell
the investment at all.
Credit Risk: Credit risk typically applies to debt investments such as corporate, municipal, and
sovereign fixed income or bonds. A bond issuing entity can experience a credit event that could impair
or erase the value of an issuer's securities held by a client.
Inflation and Interest Rate Risk: Security prices and portfolio returns will likely vary in response to
changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and
may reduce the purchasing power of a client's future interest payments and principal. Inflation also
generally leads to higher interest rates which may cause the value of many types of fixed income
investments to decline.
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Horizon and Longevity Risk: The risk that your investment horizon is shortened because of an
unforeseen event, for example, the loss of your job. This may force you to sell investments that you
were expecting to hold for the long term. If you must sell at a time that the markets are down, you may
lose money. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for
people who are retired, or are nearing retirement.
Recommendation of Particular Types of Securities
We recommend various types of securities and we do not primarily recommend one particular type of
security over another since each client has different needs and different tolerance for risk. Each type of
security has its own unique set of risks associated with it and it would not be possible to list here all of
the specific risks of every type of investment. Even within the same type of investment, risks can vary
widely. However, in very general terms, the higher the anticipated return of an investment, the higher
the risk of loss associated with the investment. A description of the types of securities we may
recommend to you and some of their inherent risks are provided below.
Stocks: There are numerous ways of measuring the risk of equity securities (also known simply as
"equities" or "stock"). In very broad terms, the value of a stock depends on the financial health of the
company issuing it. However, stock prices can be affected by many other factors including, but not
limited to the class of stock (for example, preferred or common); the health of the market sector of the
issuing company; and, the overall health of the economy. In general, larger, better established
companies ("large cap") tend to be safer than smaller start-up companies ("small cap") are but the
mere size of an issuer is not, by itself, an indicator of the safety of the investment.
Municipal Securities: Municipal securities, while generally thought of as safe, can have significant
risks associated with them including, but not limited to: the credit worthiness of the governmental entity
that issues the bond; the stability of the revenue stream that is used to pay the interest to the
bondholders; when the bond is due to mature; and, whether or not the bond can be "called" prior to
maturity. When a bond is called, it may not be possible to replace it with a bond of equal character
paying the same amount of interest or yield to maturity.
Bonds: Corporate debt securities (or "bonds") are typically safer investments than equity securities,
but their risk can also vary widely based on: the financial health of the issuer; the risk that the issuer
might default; when the bond is set to mature; and, whether or not the bond can be "called" prior to
maturity. When a bond is called, it may not be possible to replace it with a bond of equal character
paying the same rate of return.
Mutual Funds and Exchange Traded Funds: Mutual funds and exchange traded funds ("ETF") are
professionally managed collective investment systems that pool money from many investors and invest
in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any
combination thereof. The fund will have a manager that trades the fund's investments in accordance
with the fund's investment objective. While mutual funds and ETFs generally provide diversification,
risks can be significantly increased if the fund is concentrated in a particular sector of the market,
primarily invests in small cap or speculative companies, uses leverage (i.e., borrows money) to a
significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing
the fund with different types of securities. ETFs differ from mutual funds since they can be bought and
sold throughout the day like stock and their price can fluctuate throughout the day. The returns on
mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual
funds are "no load" and charge no fee to buy into, or sell out of, the fund, other types of mutual funds
do charge such fees which can also reduce returns. Mutual funds can also be "closed end" or "open
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end". So-called "open end" mutual funds continue to allow in new investors indefinitely whereas
"closed end" funds have a fixed number of shares to sell which can limit their availability to new
investors.
ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to
cause the ETF's performance to match that of its Underlying Index or other benchmark, which may
negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track
the performance of their Underlying Indices or benchmarks on a daily basis, mathematical
compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an
ETF may not have investment exposure to all of the securities included in its Underlying Index, or its
weighting of investment exposure to such securities may vary from that of the Underlying Index. Some
ETFs may invest in securities or financial instruments that are not included in the Underlying Index, but
which are expected to yield similar performance.
Money Market Funds: A money market fund is technically a security. The fund managers attempt to
keep the share price constant at $1 per share. However, there is no guarantee that the share price will
stay at $1 per share. If the share price goes down, you can lose some or all of your principal. The U.S.
Securities and Exchange Commission ("SEC") notes that "While investor losses in money market
funds have been rare, they are possible." In return for this risk, you should earn a greater return on
your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured
savings account (money market funds are not FDIC insured). Next, money market fund rates are
variable. In other words, you do not know how much you will earn on your investment next month. The
rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes
down and you earn less than you expected to earn, you may end up needing more cash. A final risk
you are taking with money market funds has to do with inflation. Because money market funds are
considered to be safer than other investments like stocks, long-term average returns on money market
funds tends to be less than long term average returns on riskier investments. Over long periods of
time, inflation can eat away at your returns.
Limited Partnerships: A limited partnership is a financial affiliation that includes at least one general
partner and a number of limited partners. The partnership invests in a venture, such as real estate
development or oil exploration, for financial gain. The general partner has management authority and
unlimited liability. The general partner runs the business and, in the event of bankruptcy, is responsible
for all debts not paid or discharged. The limited partners have no management authority and their
liability is limited to the amount of their capital commitment. Profits are divided between general and
limited partners according to an arrangement formed at the creation of the partnership. The range of
risks are dependent on the nature of the partnership and disclosed in the offering documents if
privately placed. Publicly traded limited partnership have similar risk attributes to equities. However,
like privately placed limited partnerships their tax treatment is under a different tax regime from
equities. You should speak to your tax adviser in regard to their tax treatment.
Private Placements: A private placement (non-public offering) is the non-public sale of illiquid
securities to individuals or entities that offer for sale equity shares, common or preferred stocks, or
debt instruments that are not publicly traded. Securities offered through a private placement are not
registered with the Securities and Exchange Commission. Private Placements are offered through
exemptions from registration specified in Regulation D and if certain conditions are met. Regulation D
offers a "safe harbor" for exemption from registration with the SEC. Companies that comply with the
requirements do not have to register their offering with the SEC, but they must file a Form D. However,
issuers must comply with state securities laws and regulations in the states in which the securities are
offered or sold. Each state's securities laws have their own registration requirements and exemptions
from registration. These securities are generally made available to accredited investors. Private
placements generally carry a higher degree of risk due to illiquidity. Most securities that are acquired in
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a private placement will be restricted securities and must be held for an extended amount of time and
therefore cannot be sold easily. Unlike registered offerings in which certain information is required to
be disclosed, it may be more difficult to obtain information about the company as the Private
Placement Memorandum generally provides limited information concerning a company and its
financials.
Options Contracts: Options are complex securities that involve risks and are not suitable for
everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally
recommended that you only invest in options with risk capital. An option is a contract that gives the
buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before
a certain date (the "expiration date"). The two types of options are calls and puts:
A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls
are similar to having a long position on a stock. Buyers of calls hope that the stock will increase
substantially before the option expires.
A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts
are very similar to having a short position on a stock. Buyers of puts hope that the price of the stock
will fall before the option expires.
Selling options is more complicated and can be even riskier.
The option trading risks pertaining to options buyers are:
• Risk of losing your entire investment in a relatively short period of time.
• The risk of losing your entire investment increases if, as expiration nears, the stock is below the
strike price of the call (for a call option) or if the stock is higher than the strike price of the put
(for a put option).
• European style options which do not have secondary markets on which to sell the options prior
to expiration can only realize its value upon expiration.
• Specific exercise provisions of a specific option contract may create risks.
• Regulatory agencies may impose exercise restrictions, which stops you from realizing value.
The option trading risks pertaining to options sellers are:
• Options sold may be exercised at any time before expiration.
• Covered Call traders forgo the right to profit when the underlying stock rises above the strike
price of the call options sold and continues to risk a loss due to a decline in the underlying
stock.
• Writers of Naked Calls risk unlimited losses if the underlying stock rises.
• Writers of Naked Puts risk substantial losses if the underlying stock drops.
• Writers of naked positions run margin risks if the position goes into significant losses. Such
risks may include liquidation by the broker.
• Writers of call options could lose more money than a short seller of that stock could on the
same rise on that underlying stock. This is an example of how the leverage in options can work
against the option trader.
• Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call
options are exercised.
• Call options can be exercised outside of market hours such that effective remedy actions
cannot be performed by the writer of those options.
• Writers of stock options are obligated under the options that they sold even if a trading market
is not available or that they are unable to perform a closing transaction.
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• The value of the underlying stock may surge or decline unexpectedly, leading to automatic
exercises.
Other option trading risks are:
• The complexity of some option strategies is a significant risk on its own.
• Option trading exchanges or markets and option contracts themselves are open to changes at
all times.
• Options markets have the right to halt the trading of any options, thus preventing investors from
realizing value.
If an options brokerage firm goes insolvent, investors trading through that firm may be affected.
Internationally traded options have special risks due to timing across borders.
• Risk of erroneous reporting of exercise value.
•
•
Risks that are not specific to options trading include market risk, sector risk and individual stock risk.
Option trading risks are closely related to stock risks, as stock options are a derivative of stocks.
Derivatives: Derivatives are types of investments where the investor does not own the underlying
asset. There are many different types of derivative instruments, including, but not limited to, options,
swaps, futures, and forward contracts. Derivatives have numerous uses as well as various risks
associated with them, but they are generally considered an alternative way to participate in the market.
Investors typically use derivatives for three reasons: to hedge a position, to increase leverage, or to
speculate on an asset's movement. The key to making a sound investment is to fully understand the
characteristics and risks associated with the derivative, including, but not limited to counter-party,
underlying asset, price, and expiration risks. The use of a derivative only makes sense if the investor is
fully aware of the risks and understands the impact of the investment within a portfolio strategy. Due to
the variety of available derivatives and the range of potential risks, a detailed explanation of derivatives
is beyond the scope of this disclosure.
Item 9 Disciplinary Information
We are required to disclose the facts of any legal or disciplinary events that are material to a client's
evaluation of our advisory business or the integrity of our management. There are no legal, regulatory,
or disciplinary events involving Westwood Wealth Management or its owner. Westwood Wealth
Management encourages you to perform due diligence on Westwood Wealth Management and our
Advisory Persons. Information can be found on the Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching our firm name or CRD# 290658.
Item 10 Other Financial Industry Activities and Affiliations
Westwood Wealth Management serves as the Manager and the Adviser to Westwood Alpha
Opportunity Fund (the "Fund"), a private pooled investment vehicle in which you may be solicited to
invest. The Fund is offered to certain sophisticated investors, who meet certain requirements under
applicable state and/or federal securities laws. Investors to whom the Fund is offered will receive a
private placement memorandum and other offering documents. The fees charged by the Fund are
separate and apart from our advisory fees. You should refer to the offering documents for a complete
description of the fees, investment objectives, risks and other relevant information associated with
investing in the Fund. Persons affiliated with our firm have made an investment in the Fund and have
an incentive to recommend the Fund over other investments. The relationship and potential conflicts of
interest are described more fully below.
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Westwood Wealth Management and certain members of its management have acquired, directly or
indirectly, investment interests in the Fund or have other financial interests in the Fund. As investors,
they have an incentive to devote more time to the Fund than to clients. Furthermore, they may have an
incentive to recommend the Fund rather than recommending other investments. Westwood Wealth
Management serves as the manager and investment advisor to the Funds and will receive
compensation from the Fund for these services. This role and the compensation paid to Westwood
Wealth Management provides an incentive to recommend the Fund. Westwood Wealth
Management endeavors at all times to put client-interest first as part of its fiduciary duty. Westwood
Wealth Management addresses the aforementioned conflicts of interest by disclosing them in this
brochure and in the Fund's offering documents. Westwood Wealth Management employees are
required to comply with our Code of Ethics and to act only in the best interest of clients.
Private investment funds generally involve various risk factors, including, but not limited to, potential for
complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of
which is set forth in each fund\'s offering documents, which will be provided to each client for review
and consideration. Unlike liquid investments that a client may maintain, private investment funds do not
provide daily liquidity or pricing. Each prospective investor will be required to complete a subscriptions
agreement, pursuant to which the client shall establish that he/she is qualified for investment in the
fund and acknowledges and accepts the various risk factors that are associated with such an
investment.
Item 11 Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Description of Our Code of Ethics
We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code
of Ethics includes guidelines for professional standards of conduct for persons associated with our
firm. Our goal is to protect your interests at all times and to demonstrate our commitment to our
fiduciary duties of honesty, good faith, and fair dealing with you. All persons associated with our firm
are expected to adhere strictly to these guidelines. Persons associated with our firm are also required
to report any violations of our Code of Ethics. Additionally, we maintain and enforce written policies
reasonably designed to prevent the misuse or dissemination of material, nonpublic information about
you or your account holdings by persons associated with our firm.
Clients or prospective clients may obtain a copy of our Code of Ethics by contacting us at the
telephone number on the cover page of this brochure.
Participation or Interest in Client Transactions
Westwood Wealth Management serves as the Manager and the Adviser to Westwood Alpha
Opportunity Fund, LP ("Fund") in which Clients may be solicited to invest. Westwood Wealth
Management and certain members of its management may acquire, directly or indirectly, investment
interests in the Fund or have other financial interests (e.g., General Partner) in the Fund. This presents
a conflict of interest because Westwood Wealth Management has investments and/or is compensated
by the Fund. Conflicts that arise are mitigated through Westwood Wealth Managements fiduciary
obligation to act in the best interest of our clients, contractual limitations that govern Westwood Wealth
Management's activities as adviser or general partner, as applicable, and the requirement
of Westwood Wealth Management not to place its interests before Clients' interests when managing
the Fund. Clients who are investors in the Fund should refer to the Fund's offering documents for
detailed disclosures regarding the Fund.
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Personal Trading Practices
Our firm or persons associated with our firm buy or sell the same securities that we recommend to you
or securities in which you are already invested. A conflict of interest exists in such cases because we
have the ability to trade ahead of you and potentially receive more favorable prices than you will
receive. To mitigate this conflict of interest, it is our policy that neither our firm nor persons associated
with our firm shall have priority over your account in the purchase or sale of securities.
Aggregated Trading
Our firm or persons associated with our firm may buy or sell securities for you at the same time we or
persons associated with our firm buy or sell such securities for our own account.
We do not combine multiple orders for shares of the same securities purchased for advisory accounts
we manage (the practice of combining multiple orders for shares of the same securities is commonly
referred to as "aggregated trading"). Accordingly, you may pay different prices for the same securities
transactions than other clients pay. Furthermore, we may not be able to buy and sell the same
quantities of securities for you and you may pay higher commissions, fees, and/or transaction costs
than other clients. Refer to the Brokerage Practices for further information.
A conflict of interest exists in such cases because we have the ability to trade ahead of you and
potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, it is
our policy that neither our firm nor persons associated with our firm shall have priority over your
account in the purchase or sale of securities.
Item 12 Brokerage Practices
We recommend the brokerage and custodial services of LPL Financial (whether one or more
"Custodian"). Your assets must be maintained in an account at a "qualified custodian," generally a
broker-dealer or bank. In recognition of the value of the services the Custodian provides, you may pay
higher commissions and/or trading costs than those that may be available elsewhere. Our selection of
custodian is based on many factors, including the level of services provided, the custodian's financial
stability, and the cost of services provided by the custodian to our clients, which includes the yield on
cash sweep choices, commissions, custody fees and other fees or expenses.
We seek to recommend a custodian/broker that will hold your assets and execute transactions on
terms that are, overall, the most favorable compared to other available providers and their services.
We consider various factors, including:
• Capability to buy and sell securities for your account itself or to facilitate such services.
• The likelihood that your trades will be executed.
• Availability of investment research and tools.
• Overall quality of services.
• Competitiveness of price.
• Reputation, financial strength, and stability.
• Existing relationship with our firm and our other clients.
Research and Other Soft Dollar Benefits
We do not have any soft dollar arrangements.
Economic Benefits
As a registered investment adviser, we have access to the institutional platform of your account
custodian. As such, we will also have access to research products and services from your account
custodian and/or other brokerage firm. These products may include financial publications, information
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about particular companies and industries, research software, and other products or services that
provide lawful and appropriate assistance to our firm in the performance of our investment decision-
making responsibilities. Such research products and services are provided to all investment advisers
that utilize the institutional services platforms of these firms, and are not considered to be paid for with
soft dollars. However, you should be aware that the commissions charged by a particular broker for a
particular transaction or set of transactions may be greater than the amounts another broker who did
not provide research services or products might charge.
Recommendation of Prime Broker
In some circumstances, where a client has not previously made custodial arrangements, we may
suggest that the client use a particular broker-dealer to act as custodian for the funds and securities we
manage. In those cases, we generally only recommend broker-dealers capable of acting as a "prime
broker." Under "prime broker" arrangements, the firm may, on a transaction-by-transaction basis, either
use the "prime broker"/custodian or select other broker-dealers, who will execute transactions for
settlement into the client's "prime brokerage" account. In making suggestions as to "prime
broker"/custodians, we will consider, among other things, the clearance and settlement capabilities of
the broker-dealer where other broker-dealers execute transactions, the broker-dealer's ability to
provide effective and efficient reporting to the client and our firm, the broker-dealer's reliability and
financial stability, and the likelihood that the broker-dealer will often be chosen as executing broker-
dealer on the basis of the considerations described above, including the prospects that the broker-
dealer will provide valuable research services and products.
Brokerage for Client Referrals
We do not receive client referrals from broker-dealers in exchange for cash or other compensation,
such as brokerage services or research.
Directed Brokerage
We routinely require that you direct our firm to execute transactions through LPL Financial. As such,
we may be unable to achieve the most favorable execution of your transactions and you may pay
higher brokerage commissions than you might otherwise pay through another broker-dealer that offers
the same types of services. Not all advisers require their clients to direct brokerage.
Aggregated Trades
We do not combine multiple orders for shares of the same securities purchased for advisory accounts
we manage (the practice of combining multiple orders for shares of the same securities is commonly
referred to as "aggregated trading"). Accordingly, you may pay different prices for the same securities
transactions than other clients pay. Furthermore, we may not be able to buy and sell the same
quantities of securities for you and you may pay higher commissions, fees, and/or transaction costs
than other clients.
Mutual Fund Share Classes
Mutual funds are sold with different share classes, which carry different cost structures. Each available
share class is described in the mutual fund's prospectus. When we purchase, or recommend the
purchase of, mutual funds for a client, we select the share class that is deemed to be in the client's
best interest, taking into consideration the availability of advisory, institutional or retirement plan share
classes, initial and ongoing share class costs, transaction costs (if any), tax implications, cost basis
and other factors. We also review the mutual funds held in accounts that come under our management
to determine whether a more beneficial share class is available, considering cost, tax implications, and
the impact of contingent or deferred sales charges.
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Item 13 Review of Accounts
Michael A. Puryear, President and Chief Compliance Office of WWM will monitor your accounts on an
ongoing basis and will conduct account reviews at least annually to ensure the advisory services
provided to you are consistent with your investment needs and objectives. At our discretion, additional
reviews for certain accounts may be conducted and supplemental reports may be provided based on
various circumstances, including, but not limited to: contributions and withdrawals; year-end tax
planning; market moving events; security specific events, and/or, changes in your risk/return
objectives. You will receive trade confirmations and monthly or quarterly statements from your account
custodian(s).
Upon request, we will provide you with additional or regular written reports in conjunction with the
annual account reviews. Reports we provide to you will contain relevant account and/or market-related
information such as an inventory of account holdings and account performance, etc. You will receive
trade confirmations and monthly or quarterly statements from your account custodian(s).
Item 14 Client Referrals and Other Compensation
We are independently owned and operated, and we are not affiliated with LPL Financial. LPL Financial
provides us with access to their institutional trading and custody services. We receive an economic
benefit from LPL Financial in the form of the support products and services that it makes available to
us and other independent investment advisors that have their clients maintain accounts at LPL
Financial. The availability to us of LPL Financial's products and services is not based on us giving
particular investment advice, such as buying particular securities for our clients. In connection with this
relationship.
Such benefits include research reports, services and annual conferences, computer software and other
products and services to assist the Firm in research and other facets of its day-today activities.
Because the Firm does not have to produce or pay for such research, products or services, WWM has
an incentive to select or recommend a broker-dealer based on these incidental benefits rather than in
the clients' interest in receiving most favorable execution. These practices may also cause clients to
pay fees that are higher than those that another qualified broker-dealer might charge to effect the
same or similar transaction. WWM does not attempt to match a particular client's trade executions with
broker-dealers who have provided research services which have directly benefited that client's
portfolio. Rather, research services and other benefits received by WWM are generally used for the
ultimate benefit of all of its clients. Alternatively, some of the services may benefit only a specific
segment of WWM's clients. To help mitigate the conflicts of interest created by WWM's receipt of
incidental benefits and to help ensure that broker-dealer custodians recommended by the Firm are
conducting overall best qualitative execution, WWM will periodically evaluate its trading process and
brokers utilized. WWM will review the brokerage firm's services, their value added to the Firm's
investment process along with the broker's ability to affect trades in a fair and timely manner at
competitive commission rates.
Refer to the Brokerage Practices section above for disclosures on research and other benefits we may
receive resulting from our relationship with your account custodian.
We do not receive any compensation from any third party in connection with providing investment
advice to you nor do we compensate any individual or firm for client referrals.
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Item 15 Custody
Direct Debiting of Fees
Your independent custodian will directly debit your account(s) for the payment of our advisory fees.
This ability to deduct our advisory fees from your accounts causes our firm to exercise limited custody
over your funds or securities. Your funds and securities will be held with a bank, broker-dealer, or other
qualified custodian. You will receive account statements from the qualified custodian(s) holding your
funds and securities at least quarterly. The account statements from your custodian(s) will indicate the
amount of our advisory fees deducted from your account(s) each billing period. You should carefully
review account statements for accuracy.
Private Pooled Investment Vehicle
Westwood Wealth Management serves as the investment adviser to Westwood Alpha Opportunity
Fund LP ("Fund,"), a private pooled investment vehicle in which our clients are not solicited to invest.
The Fund is offered to certain sophisticated investors, who meet certain requirements under applicable
state and/or federal securities laws. Investors to whom the Fund is offered will receive a private
placement memorandum and other offering documents. The fees charged by the Fund are separate
and apart from our advisory fees. You should refer to the offering documents for a complete
description of the fees, investment objectives, risks and other relevant information associated with
investing in the Fund. Persons affiliated with our firm may have made an investment in the Fund and
may have an incentive to recommend the Fund over other investments.
In our capacity as investment adviser to the Fund, we will have access to the Fund's funds and
securities, and therefore have custody over such funds and securities. We provide each investor in the
Fund with audited annual financial statements. If you are a Fund investor and have questions
regarding the financial statements or if you did not receive a copy, contact us directly at the telephone
number on the cover page of this brochure.
Item 16 Investment Discretion
Before we can buy or sell securities on your behalf, you must first sign our discretionary management
agreement and the appropriate trading authorization forms.
You may grant our firm discretion over the selection and amount of securities to be purchased or sold
for your account(s) without obtaining your consent or approval prior to each transaction. You may
specify investment objectives, guidelines, and/or impose certain conditions or investment parameters
for your account(s). For example, you may specify that the investment in any particular stock or
industry should not exceed specified percentages of the value of the portfolio and/or restrictions or
prohibitions of transactions in the securities of a specific industry or security. Refer to the Advisory
Business section in this brochure for more information on our discretionary management service
Item 17 Voting Client Securities
We will not vote proxies on behalf of your advisory accounts. At your request, we may offer you advice
regarding corporate actions and the exercise of your proxy voting rights. If you own shares of
applicable securities, you are responsible for exercising your right to vote as a shareholder.
In most cases, you will receive proxy materials directly from the account custodian. However, in the
event we were to receive any written or electronic proxy materials, we would forward them directly to
you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we
would forward any electronic solicitations to vote proxies.
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Item 18 Financial Information
Our firm does not have any financial condition or impairment that would prevent us from meeting our
contractual commitments to you. We do not take physical custody of client funds or securities, or serve
as trustee or signatory for client accounts, and, we do not require the prepayment of more than $1,200
in fees six or more months in advance. Therefore, we are not required to include a financial statement
with this brochure.
We have not filed a bankruptcy petition at any time in the past ten years.
Item 19 Requirements for State-Registered Advisers
We are a federally registered investment adviser; therefore, we are not required to respond to this
item.
Item 20 Additional Information
Trade Errors
In the event a trading error occurs in your account, our policy is to restore your account to the position
it should have been in had the trading error not occurred. Depending on the circumstances, corrective
actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account.
Class Action Lawsuits
We do not determine if securities held by you are the subject of a class action lawsuit or whether you
are eligible to participate in class action settlements or litigation nor do we initiate or participate in
litigation to recover damages on your behalf for injuries as a result of actions, misconduct, or
negligence by issuers of securities held by you.
IRA Rollover Considerations
As part of our investment advisory services to you, we may recommend that you withdraw the assets
from your employer's retirement plan and roll the assets over to an individual retirement account
("IRA") that we will manage on your behalf. If you elect to roll the assets to an IRA that is subject to our
management, we will charge you an asset based fee as set forth in the agreement you executed with
our firm. This practice presents a conflict of interest because persons providing investment advice on
our behalf have an incentive to recommend a rollover to you for the purpose of generating fee based
compensation rather than solely based on your needs. You are under no obligation, contractually or
otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no
obligation to have the assets in an IRA managed by our firm.
Many employers permit former employees to keep their retirement assets in their company plan. Also,
current employees can sometimes move assets out of their company plan before they retire or change
jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options
are available, you should consider the costs and benefits of:
1. Leaving the funds in your employer's (former employer's) plan.
2. Moving the funds to a new employer's retirement plan.
3. Cashing out and taking a taxable distribution from the plan.
4. Rolling the funds into an IRA rollover account.
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Each of these options has advantages and disadvantages and before making a change we encourage
you to speak with your CPA and/or tax attorney.
If you are considering rolling over your retirement funds to an IRA for us to manage here are a few
points to consider before you do so:
1. Determine whether the investment options in your employer's retirement plan address your
needs or whether you might want to consider other types of investments.
a. Employer retirement plans generally have a more limited investment menu than IRAs.
b. Employer retirement plans may have unique investment options not available to the
public such as employer securities, or previously closed funds.
2. Your current plan may have lower fees than our fees.
a. If you are interested in investing only in mutual funds, you should understand the cost
structure of the share classes available in your employer's retirement plan and how the
costs of those share classes compare with those available in an IRA.
b. You should understand the various products and services you might take advantage of
at an IRA provider and the potential costs of those products and services.
3. Our strategy may have higher risk than the option(s) provided to you in your plan.
4. Your current plan may also offer financial advice.
5. If you keep your assets titled in a 401k or retirement account, you could potentially delay your
required minimum distribution beyond age 72.
6. Your 401k may offer more liability protection than a rollover IRA; each state may vary.
a. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA
assets have been generally protected from creditors in bankruptcies. However, there
can be some exceptions to the general rules so you should consult with an attorney if
you are concerned about protecting your retirement plan assets from creditors.
7. You may be able to take out a loan on your 401k, but not from an IRA.
8. IRA assets can be accessed any time; however, distributions are subject to ordinary income tax
and may also be subject to a 10% early distribution penalty unless they qualify for an exception
such as disability, higher education expenses or the purchase of a home.
9. If you own company stock in your plan, you may be able to liquidate those shares at a lower
capital gains tax rate.
10.Your plan may allow you to hire us as the manager and keep the assets titled in the plan name.
It is important that you understand the differences between these types of accounts and to decide
whether a rollover is best for you. Prior to proceeding, if you have questions contact your investment
adviser representative, or call our main number as listed on the cover page of this brochure.
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