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Part 2A of Form ADV: Firm Brochure
FORM ADV PART 2 UNIFORM
APPLICATION FOR INVESTMENT ADVISOR
REGISTRATION FOR
WHITE LIGHTHOUSE INVESTMENT MANAGEMENT INC.
(Previously known as White Lighthouse Investment Management and JJK Investment
Management)
5 Dutton Lane
Bedford, MA 01730
Contact: Jonathan Lachowitz – Owner – 508-471-4431
This Firm brochure provides information about the qualifications and business practices of
White Lighthouse Investment Management Inc. If you have any questions about the contents of
this Firm Brochure, please contact us at the above phone number. The information in this Firm
Brochure has not been approved or verified by the United States Securities and Exchange
Commission or by any state securities authority. Additional information about White Lighthouse
Investment Management Inc. is available on both our firm’s website at white-lighthouse.com and
at
the United States Securities and Exchange Commission’s
(SEC) website at
https://www.adviserinfo.sec.gov/.
By the fact that White Lighthouse Investment Management Inc. is a Registered Investment
Advisor does not in itself imply a certain level of skill or training.
Any material changes which have occurred since the last update in 2024 are reflected in
this Firm brochure.
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Table of Contents
Page 3. Advisory Business (Assets under Management)
Page 4. Fees and Compensation
Page 6. Performance Based Fees and Side-By-Side Management
Page 6. Types of Clients
Page 7. Methods of Analysis, Investment Strategies and Risk of Loss
Page 8. Disciplinary Information
Page 8. Other Financial Industry Activities and Affiliations
Page 9. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Page 9. Brokerage Practices
Page 10. Review of Accounts
Page 11. Client Referrals and Other Compensation
Page 11. Custody
Page 12. Investment Discretion
Page 12. Voting Client Securities
Page 13. Financial Information
Page 13. Requirements for State-Registered Advisors
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Advisory Business
Assets Under Management
White Lighthouse Investment Management Inc. was founded by Jonathan Lachowitz to
provide investment management and financial services to Americans and multinational families
living in the United States and abroad. As of December 31, 2024, the firm had approximately
$671,314,000 of discretionary assets under management and approximately $18,002,000 of non-
discretionary assets for a total of approximately $689,316,000 under management calculated
according to the method prescribed by the SEC.
Investment Management Services
For investment management clients, the firm conducts a discovery process to understand
each client’s income and net worth, their goals, risk tolerance and other factors that inform the
investment policy that guides the design and management of their portfolio. We create diversified
portfolios with a custom designed asset allocation largely composed of low-to-moderate cost, high
quality, liquid investments, which are primarily in the form of Exchange Traded Funds from
companies like Vanguard, BlackRock (iShares), and others though we may use or retain individual
securities and mutual funds.
Financial Planning and Comprehensive Wealth Management Services
We provide financial planning services in the areas of tax, retirement, and estate planning,
with a focus on US cross-border issues, either on a project-basis for clients whom we do not
manage assets, or on an ongoing basis for investment management clients and wealth
management clients. Examples of specialized financial planning include outbound and inbound
US planning due to international relocations; business planning for professionals and owners with
operations in multiple countries; rental real estate planning inside and outside of the USA;
expatriation (surrendering US citizenship or green cards) and naturalization planning; estate and
tax planning for beneficiaries of foreign trusts or complex structures and tax compliance review,
including IRS international compliance programs.
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Retirement Account Rollovers
When assessing a client’s retirement accounts, we may recommend that a client rollover
their retirement plan assets to an Individual Retirement Account (IRA) that the client can choose
to be managed by us. As a result of this rollover, we may earn fees on the future management
of these accounts. This means that our advice may present a conflict of interest, as we may have
a financial incentive to recommend that a client roll over retirement assets into an IRA we would
manage. This potential conflict is disclosed to clients verbally and in this brochure. Clients are
also advised that they are under no obligation to implement the recommendations to rollover
retirement plan assets or to continue with our management, which is always billed in arrears, not
in advance. We attempt to mitigate this potential conflict by requiring that all investment
recommendations have a sound basis, and by requiring advisors to acknowledge their fiduciary
responsibility towards each client. When we provide investment advice to clients regarding their
retirement plan accounts or individual retirement accounts, we are fiduciaries within the meaning
of Title I of the Employee Retirement Income Securities Act and/or the Internal Revenue Code,
as applicable, which are laws governing retirement accounts. The way we earn money may create
some conflicts with our clients' interests, so we operate under a special rule that requires us to
act in their best interests and not put our own interests ahead of our clients. 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 our clients’
interests 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 our clients’ best interests; charge no more than is reasonable for our
services; and give basic information about conflicts of interest.
Fees and Compensation
We offer two different service levels for financial planning and investment management:
Professional Level
Clients pay both an Annual Fixed Fee and a variable Assets Under Management (AUM) Fee
quarterly in arrears. The Annual Fixed Fee is $10,000 annually. It covers standard financial
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planning such as tax and retirement planning, estate planning, and insurance needs analysis for
the client’s independent implementation. This service level is a good fit for clients with smaller
investment accounts and for those with less complex situations. Investment management for up
to $1,000,000 in AUM is included in the Annual Fixed Fee. Additional AUM Fees apply on top of
the Annual Fixed Fee for assets under management over $1,000,000 as per the table below:
Between
Assets under Management % Fee
1.00%
$1,000,000 to $2,000,000
Between
$2,000,001 to $5,000,000
0.60%
Between
Between
$5,000,001 to $10,000,000
$10,000,001 and above
0.55%
0.50%
Clients are further required to pay trading fees to brokers/custodians (typically ranging
from $0 to $30.00 per equity trade) and trading fees to mutual funds (which may vary). Most
mutual funds and exchange traded funds have their own management expense fees, typically
ranging from .03% to .50% or more per year, although, exceptionally, some may be higher.
White Lighthouse is a fee-only firm and we only receive compensation from clients. We do not
receive any fees, commissions, or payments from any brokers, funds, or other third parties.
At the discretion of the Investment advisor and based on experience and client discovery,
the Professional Level may not be appropriate for certain clients who have greater requirements
better served under the Concierge Level.
Concierge Level
Clients pay an Annual Fixed Fee quarterly in arrears. The minimum annual fee starts at
$40,000 and is based on the complexity of assets under management and assets under advisory.
Depending on the amount of assets under management, an AUM Fee may apply. The Annual
Fixed Fee covers all of the services provided under the Professional Level without hourly limitation,
as well as additional advice for adult children. Fees are generally deducted quarterly in arrears,
directly from client accounts. At the discretion of the firm, we may agree to bill for these services
separately, in which case, an agreed upon administrative fee may apply.
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Working with specific advisors may require higher minimum fees at each service level.
Under certain circumstances and at the discretion of the individual advisor, fixed fee financial
planning projects, investment management limited mandates, or special discounts to standard
fees may be offered.
For clients at the Professional Level, services beyond the scope of engagement may be
provided by a mutual client-advisor agreement at a rate of between $450/hour to $1,000/hour
depending on the advisor and complexity of the work.
As an additional safeguard to our clients, we send all invoiced amounts to the custodian
who reviews the amounts before they are posted to the client accounts. We send a copy of the
invoice amount charged to each client as part of their quarterly report. The custodian also provides
monthly reports and online real-time access to account activity. The client may call the custodian
at any time to terminate our ability to trade, view, or deduct fees from their account(s). Clients
must authorize the custodian to allow White Lighthouse Investment Management Inc. to deduct
their management fees. Please note, as mentioned above, that brokerage transactions may
include fees other than those charged directly by White Lighthouse Investment Management Inc.
Performance Based Fees and Side-by-Side Management
We have never charged any performance-based fees. Side-by-side management is when
some accounts are charged by assets under management, and some are charged by performance.
Since we do not charge by performance, we do not tend to favor charging one type of account
over another.
Types of Clients
Our clients include individuals, families, and in some cases, their adult children. We also
work with small corporations, trusts, and retirement plans such as SEP IRAs or Solo 401ks of
individual clients or their corporations. Most of our clients are families and individuals including
small business owners.
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We do not have account minimums, but we have a minimum annual fee. See page 4 (Fees
and Compensation) for more details. At our discretion or for historical reasons, we may charge
clients less than our stated minimum or provide pro-bono services.
Methods of Analysis, Investment Strategies and Risk of Loss
We manage each client’s portfolio based on their individual circumstances. This generally
includes our analysis and understanding of their risk profile (risk tolerance, capacity and need),
their age, the cash and income needs from the portfolio, their time horizon and several other
factors that pertain specifically to each client. Asset allocation over several investment classes is
done in order to build a diversified portfolio. Based on macro-economic factors and our own
analysis, we may decide to include or exclude specific investment classes or under- or over-weigh
specific sectors.
All investments and investment strategies contain risk of loss. Based on our understanding
of our clients’ risk profiles, goals, and income needs, we endeavor to create well-diversified
portfolios using primarily index ETFs (that hold the underlying securities), mutual funds, and other
individual securities that are cost efficient and are highly liquid. Historically, globally well-
diversified portfolios which apply the concepts of modern portfolio theory have produced lower
volatility returns for a given level of risk. Where possible, we manage client portfolios for tax
efficiency, taking into consideration their worldwide tax exposure to identify and avoid double
taxation risks, and to take advantage of tax minimization opportunities, though asset allocation
is seen to be more important than tax efficiency.
We manage accounts with a long-term investment horizon, which can have short-term
volatility that at times can be extreme. We request that clients let us know as soon as possible of
any changes in their circumstances that would require funding for short-term needs or may
require us to rebalance their portfolio so we can plan accordingly.
Other risks that client portfolios are subject to are inflation, regulatory changes, systemic
risk, currency exchange fluctuations, interest rates exposure, and the overall macro-economic
environment in the United States and globally. It should be noted that investing in securities
involves the potential loss of invested capital and clients should be prepared to bear this loss. We
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try to tailor the account based on a client’s risk profile and cash flow needs in order to keep losses
in line with risk tolerance.
Disciplinary Information
There have been no disciplinary events against White Lighthouse Investment Management
Inc. or any of its current or former advisory personnel.
Other Financial Industry Activities and Affiliations
In addition to White Lighthouse Investment Management Inc., Jonathan also owns and
works in the related firm White Lighthouse Investment Management SARL, which is registered
with the SEC and licensed with FINMA in Switzerland. White Lighthouse Investment Management
Inc. has a representative office in Lausanne Switzerland and is registered with FINMA.
Jonathan Lachowitz is currently a member in good standing of the Swiss Financial Planning
Organization (SFPO) and formerly served as a member of the board (2011-2016). SFPO is
authorized by the Financial Planning Standards Board (FPSB) in Washington, DC to grant the
CFP(R) marks in Switzerland.
In 2014, Jonathan Lachowitz joined the Advisory Board of OnShore Wealth S.A., a Swiss
registered Independent Asset Management firm. In January 2019, OnShore Wealth S.A. was
renamed OnSa Advisors SA. Jonathan receives no compensation for this role and has no
expectation of client referrals.
From 2014 – 2016 Jonathan wrote numerous personal financial articles for The Wall Street
Journal and in 2019 and 2020 he wrote for Bloomberg, both on an unpaid basis.
Jonathan occasionally taught courses at IMD Business School in Lausanne and at ESCP, a
French Business School with several campuses in Europe. The material he presented was
generally of a financial planning nature.
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Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
WLIM has never participated in or had an interest in trades to or from a client account or
between existing client accounts. Trades are made on the open markets. While we do personal
trading, our portfolios consist primarily of mutual funds, ETF’s, and large capitalization stocks
(e.g. Johnson & Johnson, Microsoft, etc.). Our personal trades, other than mutual funds, are
documented and reviewed periodically.
We may buy or sell the same securities as those owned by our clients. These are generally
widely held stocks, mutual funds, or ETFs, and based on the relative size of the trades in both
our client and our personal accounts, we don’t believe we can have any influence over pricing
and the markets.
Investing in the same securities as clients’ accounts may be a potential conflict of interest
but since we almost exclusively invest in high capitalization securities, mutual funds, or ETFs in
the public markets, any potential conflict is minimal at best.
White Lighthouse Investment Management Inc. has its own written code of ethics which
includes the complete CFP® Board’s Code of Ethics and Standards of Conduct. A copy is available
upon request by any client or prospective client.
We have structured our business to minimize conflicts of interest. We receive no
commission or referral fees from other professionals or institutions, and we provide services under
the fiduciary standard, meaning that we provide advice that is in the best interest of the client. If
a conflict of interest arises, we disclose it to our clients.
Brokerage Practices
We will consider any broker and could potentially work with any broker that clients are
already working with or may wish to work with. We recommend brokers based on their technical
ability to deliver information about accounts and investments, their ability to work with our clients
in their country of residence, and their reporting capabilities.
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We also consider the research available to both our firm and our clients. We recommend
our clients to open accounts at Charles Schwab and Co Inc. (Schwab), Pershing (through
Papamarkou), Fiduciary Trust or Interactive Brokers. The majority of our clients have their assets
in custody with Charles Schwab & Co, Inc. A few of our clients have accounts at other brokerage
houses of their choosing.
We do not receive any products or services from Schwab, Pershing or any other brokerage
firm that would not fall under the safe harbor rules. Brokers do provide some minimal research
we can access, such as performance statistics on mutual funds. The convenience and service
provided by Schwab, both for us and for our clients, have induced us to do much of our business
there. While there are some companies that may offer lower fees, that trade off in service does
not warrant a change in our opinion.
We receive some free information from Schwab and other brokers, and we use very little
of this data on a day-to-day basis. Such information does not impact our recommending Schwab
or other brokerage firms as the brokerage services. It is possible that directing clients to Schwab
or another brokerage firm may cost our clients more than some other services that are available
elsewhere, but after in depth examination, their services, convenience, and technology platform
are worth the extra cost to our clients.
Review of Accounts
All client accounts are reviewed by an investment manager on a periodic (at least quarterly)
basis with particular attention to market conditions or significant changes in a client profile, cash
deposits or withdrawals.
Client reports are available to each client through the client’s secure portal on a quarterly
basis and include account holdings, performance reports, and a billing statement. Each report
consists of an account summary showing beginning and end values and interest and dividends
received, and a performance review showing the relationship-to-date: 5-year, 3-year, 1-year, and
quarter performance with Return on Investment information.
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Portfolio statements are displayed in graph format and contain the classes of assets held,
followed by a specific breakdown of securities held, including cost basis and current market value.
A report showing the management fees broken down by the client’s individual accounts and a
total is included, followed by a comprehensive performance report for each security held in the
client accounts.
Client Referrals and Other Compensation
We gladly accept client referrals from existing clients and other professionals, though at
our discretion, we may choose not to work with these prospective clients.
We pay for referrals on a limited basis to OnSa Advisor S.A. (formally known as OnShore
Wealth Management) in Lausanne, Switzerland and Rubin and Rudman LLP in Boston, Ma. These
are generally for high-net-worth clients with complex situations where White Lighthouse
Investment Management Inc. serves as the Investment Manager for US-based investments. This
currently applies to less than 10 clients.
We do not get compensated by any institution or individual for any client’s referrals we
may make to them.
Custody
We use independent custodians and have limited custody of client assets to the extent that
they allow us to debit our investment management fees from their accounts.
Clients receive statements from us on a quarterly basis and from Schwab or the other
brokerage firms either monthly or quarterly. It is recommended that clients review and compare
these reports and notify us of any discrepancies. Clients can independently access their accounts,
statements, and transactions any time online at the custodian’s website.
For their convenience, clients can give us limited authority to transfer assets between their
own accounts. This authority is granted exclusively at the custodian Charles Schwab and Company
and follows the 7 requirements of the SEC’s custody rule to not require an annual surprise audit.
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Investment Discretion
The firm has investment discretion for almost all the accounts that we manage, with a
limited power of attorney to buy and sell on the clients’ behalf, in accounts titled in the name of
the clients or for their benefit. Investment management fees are a percentage of assets under
management and/or a fixed quarterly fee [often with a minimum quarterly/annual fee] and can
include ancillary financial planning advice generally related to the financial and investment goals
of the client and their families.
Occasionally, we may give investment management advice to clients for accounts that are
not managed by us. This advice is generally in the context of comprehensive wealth management
and may include investment selection in client retirement accounts not able to be managed by
us, or more general investment allocation recommendations. Generally, no individual securities
are recommended outside of the client’s retirement accounts, where we do not have discretionary
management over the client’s investments.
Analysis consists of investment/asset allocation across several different investment classes
based on the client’s risk tolerance, which is formulated based on client interviews, goals and
objectives, and a risk profiling questionnaire.
Decision makers in investment allocation at White Lighthouse Investment Management Inc
must have a CFP® qualification or comparable experience and licensing to make investment
trades for clients.
Voting Client Securities
Most clients choose to give us authority to vote proxies for their convenience. Others
choose to retain the responsibility to vote proxies on the securities they own in their accounts.
When clients delegate proxy voting to us, most of the time we vote with the management of the
individual companies and funds.
Clients can request copies of written proxies or can ask us how we voted on those that are
submitted electronically. Clients may direct us to vote in a specific manner at their discretion.
Since our personal equity holdings are in large capitalization stocks, we perceive no conflict of
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interests in our voting versus our clients’ instructions. In the ShareFile system under the Public
folder, clients can see how proxies were voted. Clients can also call or email us if they choose to
vote themselves. White Lighthouse Investment Management Inc. has a proxy policy which is
available electronically to all clients.
Financial Information
Since we do not have the ability to withdraw client assets (other than our fees, which we
collect in arrears or on a non-refundable basis), our financial situation would not have any impact
on our clients’ contractual obligations. While we do have discretionary authority over our clients’
accounts, there are no incidences in which our financial condition would impact their trading
activities. Therefore, it is not necessary for us to report on any of our financial information.
We may require pre-payments for some financial planning services, which are not
refundable.
Requirements for State-Registered Advisors
White Lighthouse Investment Management Inc. is registered with the SEC and makes
notice filings in the states of California, Connecticut, Texas, Florida, New York, North Carolina,
and Massachusetts. It is not required to register with any state securities authority.
For the latest up-to-date information, please see our filing on the SEC’s website as
occasionally this information changes with the SEC before the ADV 2A is updated.
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