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Item 1 - Cover Page
Firm CRD #170230
Wisdom Wealth Strategies, LLC
7400 E. Orchard Road, Suite 130
Greenwood Village, CO 80111
Telephone: (720) 314-8009
Facsimile: (720) 222-8435
www.wisdomws.com
Form ADV Part 2A
Firm Brochure
February 10, 2026
This brochure provides information about the qualifications and business practices of Wisdom Wealth
Strategies, LLC. If you have any questions about the content of this brochure, please contact our Chief
Compliance Officer at (720) 314-8009.
The information in this brochure has not been approved or verified by the United States Securities and
Exchange Commission (SEC) or any state securities administrator. Additional information about Wisdom
Wealth Strategies, LLC is available on the SEC’s website at www.adviserinfo.sec.gov. Click on the
“Investment Adviser Search” link and then search for “Investment Adviser Firm” using the firm’s IARD
(“CRD”) number, which is 170230.
While the firm and its associates may be registered and/or licensed within a particular jurisdiction, that
registration and/or licensing in of itself does not imply an endorsement by any regulatory authority, nor
does it imply a certain level of skill or training on the part of the firm or its associated personnel.
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Item 2 - Material Changes
Wisdom Wealth Strategies, LLC amended its Form ADV Part 2 brochure from the previous version dated
January 30, 2025 as part of its annual updating amendment. Please see Item 4 for the firm’s assets under
management as of its most recent fiscal year-end. Services to retirement plan sponsors has been removed
from Items 4 and 5, and additional product-specific risks have been added in section 8.
The firm may at any time update this document and either send a copy of its updated brochure or provide a
summary of material changes to its brochure and an offer to send an electronic or hard copy form of the
updated brochure. Clients are also able to download this brochure from the SEC’s website at
www.adviserinfo.sec.gov or may contact our firm at (720) 314-8009 to request a copy at any time.
As with all firm documents, clients and prospective clients are encouraged to review this brochure in its
entirety and are encouraged to ask questions at any time prior to or throughout the engagement.
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Item 3 - Table of Contents
Item 1 - Cover Page ............................................................................................................................................. 1
Item 2 - Material Changes ................................................................................................................................... 2
Item 3 - Table of Contents ................................................................................................................................... 3
Item 4 - Advisory Business ................................................................................................................................... 4
Item 5 - Fees and Compensation ......................................................................................................................... 6
Item 6 - Performance-Based Fees and Side-By-Side Management ................................................................... 10
Item 7 - Types of Clients .................................................................................................................................... 10
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ............................................................. 10
Item 9 - Disciplinary Information ....................................................................................................................... 18
Item 10 - Other Financial Industry Activities and Affiliations ............................................................................ 18
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ..................... 19
Item 12 - Brokerage Practices ........................................................................................................................... 21
Item 13 - Review of Accounts ............................................................................................................................ 24
Item 14 - Client Referrals and Other Compensation ......................................................................................... 26
Item 15 - Custody .............................................................................................................................................. 26
Item 16 - Investment Discretion ........................................................................................................................ 27
Item 17 - Voting Client Securities ...................................................................................................................... 28
Item 18 - Financial Information ......................................................................................................................... 28
Throughout this document Wisdom Wealth Strategies, LLC shall also be referred to as “Wisdom Wealth
Strategies,” “the firm,” “firm,” “our,” “we” or “us.” The client or prospective client may be also referred to
as “you,” “your,” etc., and refers to a client engagement involving a single person as well as two or more
persons and may refer to natural persons and legal entities.
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Item 4 - Advisory Business
Description of the Firm
Wisdom Wealth Strategies, LLC is a Colorado domiciled limited liability company originally formed in
December of 2009. We operate under the business name Wisdom Wealth Strategies. We are not a
subsidiary of, nor do we control, another financial services industry entity.
Our original registration as an investment adviser occurred in 2014 with the State of Colorado and has since
changed to an SEC registration during 2021. Our firm and its associates may register, become licensed or
meet certain exemptions to registration and/or licensing in other jurisdictions in which we conduct
investment advisory business.
Andrea L. Blackwelder, CFP®, ChFC® and Joseph D. Clemens, CFP®, EA are the firm’s Managing Members and
shareholders. Ms. Blackwelder also serves as our Chief Compliance Officer (supervisor). Additional
information about Ms. Blackwelder and Mr. Clemens and their professional experience may be found in
their respective Form ADV Part 2B brochure supplements.
Description of Advisory Services
If you choose to engage Wisdom Wealth Strategies for its services, you must first complete our client
agreement. Thereafter, discussion and analysis will be conducted to determine your financial needs, goals,
holdings, etc. Depending on the scope of the engagement, you may be asked to provide copies of the
following documents early in the process:
• Wills, codicils, and trusts
• Insurance policies
• Mortgage information
• Tax returns
• Current financial specifics including W-2s or 1099s
• Information on current retirement plans and benefits provided by your employer
• Statements reflecting current investments in retirement and non-retirement accounts
• Employment or other business agreements you may have in place
• Completed risk profile questionnaires or other forms provided by our firm
It is important that the information and/or financial statements you provide are accurate. Our firm is not
obligated to verify the information you have provided which will then be used in the advisory process.
Financial Planning
For those interested in areas such as: cash flow and budgeting, education funding, retirement planning, risk
management, estate planning, as well as periodic investment advice, we offer our financial planning
services. Your financial plan is customized for your situation. The incorporation of most or all the above
subjects allows not only a thorough analysis but also a tailored plan that is focused on your unique
requirements so that we are able to assist you in reaching your goals.
A range of variables can affect the development of a financial plan, such as the quality of your own records,
complexity and number of current investments, diversity of insurance products and employee benefits you
currently hold, size of the potential estate, and special needs of the client or their dependents, among
others. At your request, we may concentrate on reviewing only a specific area, such as an employer
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retirement plan allocation, funding an education, etc. When our planning services focus only on certain
areas of your interest, your overall situation may not be fully addressed due to limitations you may have
established. In all instances involving our financial planning engagements, our clients retain full discretion
over all implementation decisions and are free to accept or reject any recommendation we make.
Portfolio Management
Our firm is able to implement investment strategies that we have recommended to you. Depending on your
risk profile, goals and needs, among other considerations, your portfolio will involve the employment of one
of our investment strategies as well as either a broad range or more narrowly focused choice of investment
vehicles which are further discussed in Item 8 of this brochure, and our fee rates are noted in Item 5. Where
appropriate, we will prepare investment guidelines reflecting your objectives, time horizon, tolerance for
risk, as well as any account constraints you may have for the portfolio. For example, you have the right to
exclude certain securities from your portfolio (e.g., no options or foreign stocks). Investment guidelines are
designed to be specific enough to provide future guidance while allowing flexibility to work with changing
market conditions. We do not sponsor or serve as portfolio manager of a wrap fee investment program.
Investment Supervisory Services
Through our investment supervisory services offering we develop a customized portfolio for you based on
your unique situation, investment goals and tolerance for risk. We serve as your portfolio manager under a
discretionary or non-discretionary agreement (refer to Item 16), and the engagement includes:
• Determination of risk tolerance
• Investment strategy
• Investment guideline development
• Asset allocation
• Asset selection
• Regular monitoring
• Periodic rebalancing
Tax Return Preparation
Qualified firm personnel are available to provide our clients assistance in the preparation of federal and
state income tax returns. Combining personal and/or small business income tax return preparation with
financial planning may assist clients with a thorough, coordinated understanding of their finances. Clients
are not obligated to use our firm for multiple services.
Retirement Plan Advice and Rollovers
As a registered investment adviser, our firm is a fiduciary to every client, meaning that we are obligated to
act in our clients’ best interests at all times. In addition to our fiduciary status as an investment adviser firm,
when our firm provides advice to retirement investors, such as advice on an employer-sponsored retirement
plan, Individual Retirement Account (IRA) or other qualified retirement plan, we may also be considered by
the Department of Labor and the Internal Revenue Service to be acting as a fiduciary under Title I of ERISA
and the Internal Revenue Code. These fiduciary obligations include requirements that we disclose our
services and fees, conflicts of interest, and the reasons our recommendations are in the client’s best
interests.
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After an analysis of the client’s situation and plan documents, we will consider relevant factors including but
not limited to the following:
Alternatives to rolling the employer plan to an IRA, including leaving the money in an employer’s
retirement plan (if permitted); rolling the money to a new employer plan if available; or cashing out;
The fees and expenses associated with both the employer’s plan and the rollover IRA (or other
alternatives such as noted above) and whether the employer current pays for some or all of the plan’s
expenses;
The different levels of services and investments available under the employer plan and the rollover
IRA, and other alternatives;
Evidence that a rollover is the most appropriate choice in light of any additional costs and the
resultant decrease in the client’s returns;
How withdrawals are treated under each alternative (e.g., penalties up to age 55 vs. 59-1/2);
Protection from creditors and legal judgments (unlimited vs. bankruptcy only; federal- and state-
specific);
Required minimum distributions;
Tax implications of rolling shares of employer stock;
The impact of economically significant investment features such as surrender schedules and index
annuity cap and participation rates (such as in an employer-sponsored 403(b) plan account);
Any other relevant variables particular to the client’s situation.
The client will be made aware of conflicts of interest including but not limited to whether our firm will profit
from a recommendation through financial planning and/or investment management fees, and whether
services we offer are already provided by or available through the current plan, potentially at no additional
cost.
As of December 31, 2025, our firm had over $190 million of reportable client assets under its management
via discretionary engagement agreements.1
Item 5 - Fees and Compensation
Forms of payment are based on the types of services being provided, term of service, etc., and will be stated
in your engagement agreement with our firm. Our published fees should not be considered negotiable, but
we do discount accounts for our associates and their family members, as well as pre-existing (“legacy”)
accounts. We strive to offer fees that are fair and reasonable in light of the experience of our firm and the
services to be provided to you.
Fees for financial planning and investment management services may be paid by check or teller’s draft from
US-based financial institutions. With your prior authorization, payment may also be made through a
qualified, unaffiliated third-party processor2 or withdrawal from your investment account held at your
custodian of record. Wisdom Wealth Strategies does not accept cash, money orders or similar forms of
payment for its investment advisory engagements.
1 The term “assets under management” and rounding to the nearest $100,000 per the SEC’s Instructions for Part 2 of Form ADV.
2 We do not retain credit or debit card data. For an explanation of the term “PCI,” who the PCI Security Standards Council is, as well as
its comprehensive standards to enhance payment card data security, please go to
https://www.pcisecuritystandards.org/security_standards/index.php
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Tax preparation fees may be paid by check or teller’s draft from US-based financial institutions, or through
credit card payment via a qualified, unaffiliated third-party processor.
Types of Fees and Payment Schedule
Fixed Fees
Through our fixed-fee services, we are available to help you with a wide variety of financial planning
services. The fee takes into consideration factors such as the complexity of your financial profile and
requirements, the time involved developing your plan and assisting you in its execution, assets that
comprise your overall portfolio, as well as the number of individual accounts comprising your portfolio and
where those accounts are maintained.
We are compensated for project-based services on a fixed fee basis ranging from $500 to $10,000 per plan,
and the fee will be determined by the complexity of the engagement, the time involved developing the plan,
number of accounts involved, etc. Fees of $1,000 or less are due in full upon signing of the engagement
agreement. Fees over $1,000 require a deposit equaling one-half of the fee, which is due upon execution of
the engagement agreement. The remainder of the fee will be due in 6 months or upon completion of the
agreed-upon services, whichever occurs first. The firm will not charge a fee of $1,200 or more for services to
be provided six months or more in the future.
Following delivery of the agreed-upon services, the Client may re-engage the Firm for similar or additional
services by executing a new Addendum or Agreement.
Tax Return Preparation Fees
Tax return preparation fees are assessed a per form/schedule fee ranging from $5 to $500. However, more
extensive engagements may need to be separately quoted after the initial assessment. The necessary filing
forms/schedules required, and our associated fee, will be discussed with you prior to initiating the project.
No advance fee/deposit is required, the entire fee will be due upon our delivery of your prepared tax returns
to you.
For those clients who maintain an investment account with our firm of $600,000 or more (as of each
calendar year-end), we may waive our fee for personal 1040 tax return preparation. This service does not
include corporate tax returns, partnership returns, returns for estates or trusts, or international filings. All
such services will incur a fee. Note that we cap the waived preparation fee at $1,000. In the case of an
exceptionally complicated return, we will apply a credit of up to $1,000 to the cost of preparing the return,
with the balance due to our firm upon our delivery of the prepared returns.
Hourly Fees
Limited financial planning engagements may be accomplished via an hourly fee. Our rate is $350 per hour
billed in 15-minute increments and a partial increment (e.g., nine minutes) will be treated as a whole
increment. Prior to entering into an agreement with the firm you will receive an estimate of the overall fee
based on your requirements and the time involved.
Asset-Based Fees
Fees for investment supervisory services are assessed an annualized asset-based fee that will be calculated
based on the reporting period ending value of your account (e.g., the last market day of the quarter). These
fees will be billed quarterly, in advance.
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Investment Supervisory Services
Our investment supervisory services fees are based on the prior reporting period ending value of your
account as described in the following table. The fee is determined by multiplying the previous quarter-
ending account value by the applicable annualized basis points set forth in the below fee table (one basis
point equals 1/100 of one percent). The result is then divided by four to determine the quarterly fee. The
first quarter’s fee will be prorated if the client entered into the engagement mid-quarter, and we will
prorate our fee for any existing account’s mid-cycle additions or withdrawals of $50,000 or more in a single
transaction.
Formula: ((previous quarter market value) x (applicable annualized number of basis points)) ÷ 4
Assets Under Management
$0 - $499,999
$500,000 - $999,999
$1,000,000 - $1,999,999
$2,000,000 - $2,999,999
$3,000,000 - $3,999,999
$4,000,000 - $4,999,999
$5,000,000 – Above
Annualized Asset-Based Fee
1.25% (125 basis points)
1.10% (110 basis points)
1.00% (100 basis points)
0.90% (90 basis points)
0.80% (80 basis points)
0.70% (70 basis points)
0.60% (60 basis points)
Discounting Asset-Based Fees
For the benefit of discounting your asset-based fee, we will attempt to aggregate investment supervisory
services accounts for the same individual or two or more accounts within the same family, or accounts
where a family member has power of attorney over another family member’s or incompetent person's
account. Should investment objectives be substantially different for any two or more household accounts,
requiring different investment approaches or operational requirements, we reserve the right to apply our
fee schedule separately to each account.
Payment of Asset-Based Fees
Accounts will be assessed in accordance with asset values disclosed on the statement the client will receive
from the custodian of record for the purpose of verifying the computation of the advisory fee. In the rare
absence of a reportable market value, our firm may seek a third-party opinion from a recognized industry
source (e.g., unaffiliated public accounting firm), and the client may choose to separately seek such an
opinion at their own expense as to the valuation of “hard-to-price” securities if necessary.
Advisory fees will be noted on your quarterly account statement you will receive from your custodian of
record. It is important that you review your statements to assess the accuracy of fee calculations; the
account custodian does not verify the accuracy of advisory fee assessments for you.
Your written authorization is required in order for the custodian of record to deduct advisory fees from your
investment account. By signing our firm’s engagement agreement, as well as the selected custodian account
documents, you will be authorizing the withdrawal of both advisory and transactional fees (see following
section) from your account. The withdrawal of these fees from your account will be accomplished by the
selected custodian at the request of our firm, and the custodian will remit fees directly to our firm. Fees
deducted from the account will be noted on statements that you will receive directly from the custodian of
record on a quarterly or more frequent basis.
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You can request to directly pay our advisory firm its investment supervisory services fee in lieu of having the
advisory fee withdrawn from their investment account. Our valuation assessment will remain the same as
described above, and the client’s direct payment must be received by our firm within 15 days of our invoice.
Potential Additional Client Fees
Any transactional or service fees (sometimes termed brokerage fees), individual retirement account fees,
qualified retirement plan fees, account termination fees, or wire transfer fees will be borne by the account
holder and per the separate fee schedule of your custodian of record.
We will ensure you receive a copy of our custodian’s fee schedule at the beginning of the engagement, and
you will be notified of any future changes to these fees by the custodian of record and/or third-party
administrator for certain tax-qualified plans.
Fees paid by our clients to our firm for our advisory services are separate from any of these fees or other
similar charges. In addition, advisory fees paid to our firm for its services are separate from any internal fees
a client pays involving mutual funds, exchange-traded funds (ETFs) or other similar investments.
Per annum interest at the current statutory rate may be assessed on fee balances due more than 30 days;
we reserve the right to refer past due accounts to collections or legal counsel for processing. We suspend
our services once an account is deemed past due.
Additional information about our fees in relationship to our brokerage practices are noted in Items 12 and
14 of this document.
External Compensation involving Sale of Securities
We do not charge or receive a commission or mark-up on your securities transactions, nor do we receive
“trails” or SEC Rule 12b-1 fees from a mutual fund company we may recommend. Our clients have the right
to purchase recommended or similar investments through their own service provider (i.e., brokers, agents,
etc.).
When there is the potential for the receipt of a commission and other similar compensation via an insurance
product transaction (e.g., purchase of a fixed annuity, life insurance policy, etc.), an associate of our firm
that is licensed as an insurance agent has an incentive to make such a recommendation based on the
compensation they receive rather than a client’s need. Our advisory firm and its associates take their
responsibilities seriously and only intend to recommend investments, insurance, or advisory services we
believe appropriate for each client. Please refer to Items 10 and 11 of this firm brochure, in addition to Item
4 of an associate’s Form ADV Part 2B brochure supplement for details.
Termination of Services
Either party may terminate the agreement at any time by communicating the intent to terminate in writing.
Wisdom Wealth Strategies will not be responsible for investment allocation, advice, or transactional services
(except for limited closing transactions) upon receipt of a termination notice. It will also be necessary that
we inform the custodian of record that the relationship between the firm and the client has been
terminated.
The client has the right to terminate the engagement without penalty within five business days after
entering into the agreement with our firm. Should a client terminate an engagement involving hourly or
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fixed fees after this five-day time period, the client may be assessed fees at the firm’s current hourly rate for
any time incurred in the preparation of the client’s analysis or plan.
When an investment supervisory services client terminates their agreement after the five-day period, the
client will be assessed fees on a prorated basis for services incurred from either (i) as a new client, the date
of the engagement to the date of the firm’s receipt of the written notice of termination, or (ii) all other
accounts, the last billing period to the date of the firm’s physical or constructive receipt of written
termination notice.
Our firm will return any of its prepaid, unearned fees within 30 days of our receipt of termination notice.
Earned fees in excess of any prepaid deposit will be billed at the time of termination and will be due upon
receipt of our invoice. Our return of payment to a client for fixed and hourly fees will only be completed via
check from our firm’s US-based financial institution; no credits or “transaction reversals” will be issued. We
will only coordinate remuneration of prepaid asset-based fees to an investment account via our selected
custodian.
Item 6 - Performance-Based Fees and Side-By-Side Management
Our advisory fees will not be based on a share of capital gains or capital appreciation (growth) of any portion
of managed funds, also known as performance-based fees. Our fees will not be based on side-by-side
management, which refers to a firm simultaneously managing accounts that do pay performance-based fees
(such as a hedge fund) and those that do not.
Item 7 - Types of Clients
We provide advisory services to individuals and high net worth individuals, their trusts and estates, as well
as small businesses and their key personnel, and pension and profit-sharing plans. We encourage interested
parties of all economic levels to seek our advisory services; we do not require minimum income, minimum
asset levels or other similar preconditions. Wisdom Wealth Strategies reserves the right to waive or reduce
certain fees based on unique individual circumstances, special arrangements, or preexisting relationships.
We also reserve the right to decline services to any prospective client for any non-discriminatory reason.
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis and Investment Strategies
Method of Analysis
Wisdom Wealth Strategies employs a blend of fundamental and technical analyses. For example,
fundamental analysis involves evaluating economic factors including interest rates, the current state of the
economy, or the future growth of an industry sector. Technical analysis may involve studying the historical
patterns and trends of securities and their markets in an effort to determine potential future behaviors, the
estimation of price movement, and an evaluation of a transaction before entry into the market in terms of
risk and profit potential. Firm research may be drawn from sources that include financial periodicals,
information published by economists and other industry professionals, corporate rating services, as well as
annual reports, prospectuses, and regulatory filings.
Investment Strategies
We recognize that each client’s needs and goals are different; subsequently portfolio strategies and
underlying investment vehicles vary. The firm may employ active, Core + Satellite and passive account
management strategies in order to seek growth while concurrently managing risk through appropriate asset
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allocation. The following defines the common strategies utilized within a client’s portfolio, in alphabetical
order:
Active Asset Management
A portfolio manager engaging in an active asset management strategy believes it is possible to create a
profit from identifying or leveraging mispriced securities, or producing similar returns with less risk, or
producing returns greater than a stated benchmark, such as a well-known index. For example, a “large cap
stock” fund manager might attempt to outperform the Standard & Poor's 500 Index by purchasing
underpriced stocks or derivative instruments representing these positions.
Portfolio managers may attempt to preserve capital during times of high risk through the use of cash and
cash equivalents, and the percentage of account holdings invested in the market vary based on what is
believed to be the prevailing risk in the market. For example, if a manager feels risk in the stock market is
low, he might increase exposure to equities to attempt to take advantage of growth opportunities. When
risk in the stock market is considered high, all of or a portion of the portfolio’s equity exposure may be
moved to more stable short-term fixed income instruments and cash equivalent alternatives in order to
preserve capital.
Core + Satellite
This strategy blends passive (or index) and active investing, where passive investments are used as the basis
or “core” of a portfolio and actively managed investments are added as “satellite” positions. With this
strategy, the portfolio core holdings are indexed to potentially more efficient asset classes, while outlying
selections are generally limited to active holdings in an attempt to outperform a particular category (sector),
or a selection of particular positions to increase core diversification, or to improve portfolio performance.
For example, the core of a portfolio may be built with low-cost index funds or ETFs; satellite holdings would
include active investment managers (mutual funds) with unique strategies that are believed capable of
adding value beyond a stated benchmark over a full market cycle. The core represents the majority of the
total portfolio, using primarily index funds or index-based ETFs. The remainder of the portfolio employs
mutual funds or ETFs that take a shorter duration to assist in the over-or-under allocation to specific sectors,
regions, assets classes, etc.
Passive Account Management
Our passive strategy is based on Modern Portfolio Theory; selecting securities whose price movements have
historically low correlations to create efficient portfolios that offer the highest expected return for a given
level of risk, or one with the lowest level of risk for a given expected return. This practice does not employ
market timing or stock selection methods of investing but rather a long term, buy-and-hold strategy with
periodic rebalancing of the account to maintain desired risk levels.
We will strive to create portfolios that contain investment vehicles that are diversified, tax-efficient, and
low-cost investments whenever practical. Although it is common to find a broad range of index mutual
funds or ETFs within a portfolio, certain accounts may necessitate holding actively managed mutual funds
and individual equity (stock) positions. An account might contain fixed income holdings, such as bonds,
certificates of deposit (CDs) and money markets3 to create as broad a diversification as necessary to meet
demands of the portfolio or to effectively employ pre-existing holdings within your account.
3 Wisdom Wealth Strategies may recommend but does not distribute certificates of deposits, money market accounts or similar
savings vehicles for client accounts. The firm is not a financial institution, is not a member of the Federal Deposit Insurance
Corporation (FDIC) or National Credit Union Association (NCUA), nor is required to be an FDIC or NCUA member. You may learn
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Risk of Loss
Our firm believes its strategies and investment recommendations are designed to produce the appropriate
potential return for the given level of risk; however, there is no guarantee that an investment objective will
be achieved. Investing in securities involves risk of loss that clients should be prepared to bear. While the
following list is not exhaustive, we provide examples of such risk in the following paragraphs, and we believe
it is important that our clients review and consider each prior to investing.
Active Management Risks
A portfolio that employs active management strategies may, at times, outperform or underperform various
benchmarks or other strategies. In an effort to meet or surpass these benchmarks, active portfolio
management may require more frequent trading or “turnover.” This can result in shorter holding periods,
higher transactional costs and/or taxable events generally borne by the client, thereby potentially reducing
or negating certain benefits of active asset management.
Catastrophic Risk
Natural or man-made catastrophes can disrupt financial markets and impact securities prices. Examples
include terrorist attacks, natural disasters, war, etc. Investment companies can use "exigent circumstances"
or "force majeure" as a defense against claims of loss by investors.
Company Risk
When investing in securities, such as stocks, there is always a certain level of company or industry-specific
risk that is inherent in each company or issuer. There is the risk that the company will perform poorly or
have its value reduced based on factors specific to the company or its industry. This is also referred to as
unsystematic risk and can be reduced or mitigated through diversification.
Core + Satellite Strategies
Strategies involving Core + Satellite investing may have the potential to be affected by “active risk” (or
“tracking error risk”), which might be defined as a deviation from a stated benchmark. Since the core
portfolio attempts to closely replicate a stated benchmark, the source of the tracking error or deviation may
come from a satellite portfolio or position, or from a “sample” or “optimized” index fund or ETF that may
not as closely align the stated benchmark.
Country/Regional Risk
World events such as political upheaval, financial troubles, or natural disasters will adversely affect the value
of securities issued in foreign countries or regions. This risk is especially high in emerging markets where
securities may be substantially more volatile and less liquid than securities in more developed countries.
Because registered investment company securities (e.g., a mutual fund) may invest a large portion of its
assets in securities located in any one country or region, including emerging markets, its performance may
be hurt disproportionately by the poor performance of its investments in that area.
Failure to Implement
Each planning client is free to accept or reject any or all recommendations made by our firm. While no
advisory firm can guarantee future performance, no plan can succeed if it is not implemented. Clients who
more about the FDIC or NCUA and how they serve financial institution depositors/members by going to their website at
www.fdic.gov or www.ncua.gov. Securities recommended through our advisory firm are not FDIC or NCUA/NCUSIF-insured.
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choose not to take the steps recommended in their financial plan may face an increased risk that their
stated goals and objectives will not be achieved.
Financial Risk
Excessive borrowing to finance business operations increases the risk of profitability, because a company
must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability
to meet loan obligations may result in bankruptcy and/or a declining market value.
Fundamental Analysis
The challenge involving fundamental analysis is that information obtained may be incorrect; the analysis
may not provide an accurate estimate of earnings, which may be the basis for a security’s value.
Inflation Risk
Also called purchasing power risk, is the chance that the cash flows from an investment will not be worth as
much in the future because of changes in purchasing power due to inflation.
Macroeconomic Risk
Macroeconomic risk derives from the behavior of industries and governments and the relationships
between them rather than from individual companies. It concerns fiscal and monetary policies, trade and
investment flows and political developments on a national and international scale. Business cycles,
depressions, inflation, unemployment, interest rates, valuations, prices, and imports/exports volumes are all
unpredictable and can lower or destroy investment portfolios. Central banks and governments often resort
to inflationary policies and excessive fiat currency issuance through borrowing and printing. These
macroeconomic maneuvers may possibly support or increase the nominal value of investment assets short
term but lead to inflation and asset bubbles and later crashes.
Management Risk
An investment with a firm varies with the success and failure of its investment strategies, research, analysis,
and determination of its portfolio. If an investment strategy were not to produce expected returns, the
value of the investment would decrease.
Market Risk
When the stock market as a whole or an industry as a whole fall, it can cause the prices of individual stocks
to fall indiscriminately. This is also called systemic or systematic risk.
Operational Risk
The potential for loss resulting from inadequate or failed internal processes, systems, actions of people, or
external events. Many industries institute policies and procedures to respond and initiate alternative or
supporting operations following a significant business disruption, while others do not. The level of
operational risk and appropriate response are not uniform in definition, requirement, or measurement,
including within the financial services sector.
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Passive Investing
A portfolio that employs a passive, efficient markets approach (representative of Modern Portfolio Theory)
has the potential risk at times to generate lower-than-expected returns for the broader allocation than
might be the case for a more narrowly focused asset class, and the return on each type of asset may be a
deviation from the average return for the asset class. We believe this variance from the expected return is
generally low under normal market conditions when a portfolio is made up of diverse, low or non-correlated
assets.
Research Data
When research and analyses are based on commercially available software, rating services, general market
and financial information, or due diligence reviews, a firm is relying on the accuracy and validity of the
information or capabilities provided by selected vendors, rating services, market data, and the issuers
themselves. Therefore, while our firm makes every effort to determine the accuracy of the information
received, we cannot predict the outcome of events or actions taken or not taken, or the validity of all
information researched or provided which may or may not affect the advice on or investment management
of an account.
Sequence of Return Risk
The risk of receiving lower or negative returns due to early withdrawals from an investment account.
Settlement Risk
Also called delivery risk. The risk that one party will fail to deliver the terms of an investment contract with
another party (contra-party) at the time of settlement. Settlement risk can be a risk associated with default,
along with any timing differences in a settlement between the two parties.
Sociopolitical Risk
The risk of instability in a region due to war, terrorism, pandemics, etc., that might affect investment
markets.
Technical Analysis
The risk of investing based on technical analyses is that it may not consistently predict a future price
movement; the current price of a security may reflect all known information. This may occur due to analyst
bias or misinterpretation, a sector analysis error, late recognition of a trend, etc.
Security-Specific Material Risks
Emerging Markets Securities
Investments in emerging markets securities are considered speculative and subject to heightened risks in
addition to the general risks of investing in foreign securities. Unlike more established markets, emerging
markets may have governments that are less stable, markets that are less liquid, and economies that are
less developed. In addition, the securities markets of emerging market countries may consist of companies
with smaller market capitalizations and may suffer periods of relative illiquidity; significant price volatility;
restrictions on foreign investment; and possible restrictions on repatriation of investment income and
capital. Furthermore, foreign investors may be required to register the proceeds of sales, and future
economic or political crises could lead to price controls, forced mergers, expropriation or confiscatory
taxation, seizure, nationalization, or creation of government monopolies.
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Equity (Stock) Risk
Common stocks are susceptible to general stock market fluctuations and to volatile increases or decreases in
value as market confidence in and perceptions of their issuers change. If an investor held common stock or
common stock equivalents of any given issuer, they may be exposed to greater risk than if they held
preferred stocks and debt obligations of the issuer.
Preferred stocks can be affected by interest rate and liquidity risks (described in adjacent paragraphs). Also
note that their dividend payment is not guaranteed; some are subject to a call provision, meaning the issuer
can redeem its preferred shares on demand, and usually when interest rates have fallen.
ETFs
Exchange-traded fund risks include risks due to their underlying securities (e.g., stocks, bonds, derivatives,
etc.), and can be affected by risks such as market, currency, credit, political, interest rate, etc., that are
described in adjacent paragraphs. The liquidity of the underlying stocks in the index can affect “ETF
liquidity.” Liquidity risk can result from an insufficient number of “active participants” performing their
duties as intermediaries and liquidity providers in the ETF market. “Spread risk” may also occur, which is the
difference between the bid and the ask price of a security. Since ETF transactions are priced throughout the
day and are traded on the exchanges like stocks, widening spreads may occur and have impact on certain
portfolios or transactions. As with any security, if the ETF “fails,” the investor may lose their gains and
invested principal. ETFs can carry additional expenses based on their share of operating expenses and
certain brokerage fees. Indexed ETFs have the potential to be affected by “active risk;” a deviation from its
stated index. We do not recommend leveraged or inverse ETFs to our clients due to their greater risk.
Fixed Income Risks
Various forms of fixed income instruments, such as bonds, money market or bond funds may be affected by
various forms of risk, including:
Call Risk - During periods of falling interest rates, issuers of callable bonds may call (redeem) securities
with higher coupons or interest rates before their maturity dates. The owner of the bond would then
lose any potential price appreciation above the bond’s call price and would be forced to reinvest the
unanticipated proceeds at lower interest rates, resulting in a decline in the owner’s income. Call risk is
generally low for short-term bond funds, moderate for intermediate-term bond funds, high for long-
term bond funds, and high for high-yield bonds.
Credit Risk - The potential risk that an issuer would be unable to pay scheduled interest or repay
principal at maturity, sometimes referred to as “default risk.” Credit risk may also occur when an
issuer’s ability to make payments of principal and interest when due is interrupted. Bondholders are
creditors of an issuer and have priority to assets before equity holders (e.g., stockholders) when
receiving a payout from liquidation or restructuring. When defaults occur due to bankruptcy, the type
of bond held will determine seniority of payment.
Interest Rate Risk - The risk that the value of the fixed income holding will decrease because of an
increase in interest rates. The longer the maturity of the bond, the more sensitive its value is to
changes in interest rates. Bond prices and interest rate changes are inversely correlated.
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Prepayment Risk - The prepayment risk is the premature return of principal on a fixed-income security.
When principal is returned early on a security, future interest payments will not be paid on that part
of the principal. The owner of the security would lose any price appreciation above the principal and
forced to reinvest the unanticipated proceeds possibly at lower interest rates, resulting in a decline of
dividends, income, and returns. The risk of prepayment is most prevalent in fixed-income securities
such as callable bonds and mortgage-backed securities.
Reinvestment Risk - With declining interest rates, investors may have to reinvest interest income or
principal at a lower rate.
State Government and Municipal Securities Risk - State government and municipal securities are
subject to various risks based on factors such as economic and regulatory developments, changes or
proposed changes in the federal and state tax structure, deregulation, court rulings and other factors.
Repayment of state and municipal securities depends on the ability of the issuer or project backing
such securities to generate taxes or revenues. There is also a risk the interest on an otherwise tax-
exempt municipal security may be subject to federal income tax. Unfavorable developments in any
economic sector may have far-reaching ramifications on the overall state and municipal market.
U.S. Government Securities Risk - U.S. government securities are subject to varying interest rates and
inflation risks. Not all U.S. government securities are backed by the full faith and credit of the U.S.
government. Certain securities issued by agencies and instrumentalities of the U.S. government are
only insured or guaranteed by the issuing agency or instrumentality, which must rely on its own
resources to repay the debt. As a result, there is risk these entities will default on a financial
obligation.
Foreign Securities Risk
Investments in securities of foreign companies, including direct investments as well as investments through
American Depository Receipts (ADRs), can be more volatile than investments in US companies. Diplomatic,
political, or economic developments, including nationalization or appropriation, could affect investments in
foreign companies. Foreign securities markets generally have less trading volume and less liquidity than US
markets. In addition, the value of securities denominated in foreign currencies, and of dividends from these
securities, can change significantly when foreign currencies strengthen or weaken relative to the US
dollar. Financial statements of foreign issuers are governed by different accounting, auditing, and financial
reporting standards than the financial statements of US issuers and may be less transparent and uniform
than in the United States. Thus, there may be less information publicly available about foreign issuers than
about most US issuers. Transaction costs generally are higher than those in the United States and expenses
for custodial arrangements of foreign securities may be somewhat greater than typical expenses for
custodial arrangements of similar US securities. Some foreign governments levy withholding taxes against
dividend and interest income. Although in some countries a portion of these taxes are recoverable, the non-
recovered portion will reduce the income received from the securities comprising an account’s portfolio.
These risks may be heightened with respect to emerging market countries since political turmoil and rapid
changes in economic conditions are more likely to occur in these countries.
Information Technology Sector Risk
Information technology companies face intense competition, both domestically and internationally, which
may have an adverse effect on profit margins. As with other technology companies, information technology
companies may have limited product lines, markets, financial resources, or personnel.
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The products of information technology companies may face obsolescence due to rapid technological
developments, frequent new product introduction, unpredictable changes in growth rates, and competition
for the services of qualified personnel. Companies in the information technology sector are heavily
dependent on patent and intellectual property rights. The loss or impairment of these rights may adversely
affect the profitability of these companies.
Index Investing
You will need to keep in mind that investment vehicles such as certain ETFs and indexed funds have the
potential to be affected by “tracking error risk” (see earlier paragraph under Core + Satellite Strategies).
Liquidity Risk
Liquidity risk is the inability to readily buy or sell an investment for a price close to the true underlying value
of the asset due to a lack of buyers or sellers. There are times when there is no trading volume/market
depth to support a security’s current price. As such, the true value of the bond (for example) may not be
supported by the current price. Conversely, when trading volume is high, there is also a risk of not being
able to purchase a particular issue at the desired price.
Money Market Funds
A money market fund is managed to maintain a stable net asset value (NAV) of $1 per share, the value of
the fund may fluctuate, and you could lose money (termed “breaking the buck”). Money market funds are a
type of mutual fund investing in high-quality, short-term debt securities, pays dividends that generally
reflect short-term interest rates and seeks to maintain a stable NAV per share (typically $1). An investment
in a money market mutual fund is not insured or guaranteed by the Federal Deposit Insurance Corporation,
National Credit Union Association, or any government agency.
Mutual Funds
As with ETFs, the risk of owning a mutual fund is reflected in the underlying security(ies). Mutual funds are
affected by risks such as market, interest rate, currency, credit, political, active risk, etc., as described in
adjacent paragraphs. It is important to note that even “conservative” funds, such as a money market fund or
fixed income fund, can and have lost their value below the principal amount invested. Mutual funds typically
carry additional expenses based on their share of operating expenses and trading (brokerage) fees, which
may result in the potential duplication of certain fees paid by the investor. Indexed mutual funds can also be
adversely affected by “QDI ratios” that are described in a following paragraph. There are essentially nine
main types of mutual fund shares classes, as well as sub-classes for some of these. Some open and closed-
ended funds are sold through brokerage firms and assess a commission (“load) in addition to their
underlying fees earlier noted, while others are offered through investment advisers, retirement plans and
other institutions. “No load” funds are also available to the public through brokerage firms, and they usually
incur trading (brokerage) fees. If a client chooses to purchase a mutual fund on their own through a
broker/dealer, they should consider the trading fees, internal operating costs, as well as potential
commissions they pay through that executing firm. Our firm is not a broker/dealer and (per Items 5 and 10
of this brochure) does not recommend nor is compensated by a “loaded” fund.
Cryptocurrency and Crypto-Related Products
Cryptocurrencies are highly speculative and are subject to significant price fluctuations and volatility. Prices
can decline to zero and investors should be prepared to lose the entire investment. Crypto-related
exchange-traded products may experience discrepancies between net asset value (NAV) and market price.
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At present, the regulatory environment for crypto markets is uncertain and may lack protections enjoyed by
other products. Wisdom Wealth Strategies utilizes ETF products to obtain crypto exposure when
appropriate, but does not directly invest in the asset class on behalf of clients.
Alternative Investments and Private Market Investments
Private market investments, including private equity, hedge funds, real estate funds, and private credit
funds are illiquid investments. While some structures may allow shares to be redeemed quarterly or twice
per year, many funds require a longer time commitment. Funds may restrict the percentage of shares that
may be redeemed during redemption windows, leading to additional reduction in liquidity.
Alternative investments may utilize leveraging and other speculative practices that increase an investor’s
risk of loss. Alternative investments may lack diversification, involve complex tax structures and have delays
in reporting important tax information. Registered and unregistered alternative investments are not subject
to the same regulatory requirements as mutual funds or exchange-traded products.
The valuation of private market assets may not reflect the price at which an asset may be sold. In addition,
private market funds may not provide complete transparency into fund holdings and risks. Private asset
funds may incur high fees. Additional custodian fees may apply to certain private markets funds.
QDI Ratios
While many ETFs/ETNs and index mutual funds are known for their potential tax-efficiency and higher
“qualified dividend income” (QDI) percentages, there are asset classes within these investment vehicles or
holding periods within that may not benefit. Shorter holding periods, as well as commodities and currencies
(that may be part of an ETF/ETN or mutual fund portfolio), may be considered “non-qualified” under certain
tax code provisions. A holding’s QDI will be considered when tax-efficiency is an important aspect of the
client’s portfolio.
Small- and Mid-Capitalization Company Risk
The small- and mid-capitalization companies in which an account may invest may be more vulnerable to
adverse business or economic events than larger, more established companies. Investments in these small-
and mid-sized companies may pose additional risks, including liquidity risk, because these companies tend to
have limited product lines, markets, and financial resources, and may depend upon a relatively small
management group. Small- and mid-cap stocks, therefore, may be more volatile than those of larger
companies. These securities may be traded over-the-counter (OTC) or listed off-exchange.
Item 9 - Disciplinary Information
Neither the firm nor its management has been involved in a material criminal or civil action in a domestic,
foreign, or military jurisdiction, an administrative enforcement action, or self-regulatory organization
proceeding that would reflect poorly upon our offering advisory business or its integrity.
Item 10 - Other Financial Industry Activities and Affiliations
Firm policies require associated persons to conduct business activities in a manner that avoids conflicts of
interest between the firm and its clients, or that may be contrary to law. Wisdom Wealth Strategies will
provide disclosure to each client prior to and throughout the term of an engagement regarding any conflicts
of interest involving its business relationships that might reasonably compromise its impartiality or
independence.
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Wisdom Wealth Strategies and its associates are not registered, nor do they have an application pending to
register as a Financial Industry Regulatory Authority (FINRA) or National Futures Association (NFA) member
firm. We are not required to be registered with such entities, nor do they supervise our firm, its activities, or
our associates. Neither our firm nor its management is or has a material relationship with any of the
following types of entities:
bank, credit union or thrift institution, or their separately identifiable departments or divisions
accounting firm or accountant
lawyer or law firm
another pension consultant
real estate broker or dealer
sponsor or syndicator of limited partnerships
trust company
issuer of a security, to include an investment company or other pooled investment vehicles
Our firm’s management and associates are also licensed insurance agents appointed with unaffiliated
insurance carriers. Further information regarding these other activities may be found in each associates’
Form ADV Part 2B brochure supplement (in Item 4). Whether they are serving a client in one or more
capacities, each associate will disclose in advance how they are being compensated and if there is a conflict
of interest involving any advice or service they may provide. At no time will there be tying between business
practices and/or services; a condition where a client or prospective client would be required to accept one
product or service which is conditional upon the selection of a second, distinctive tied product or service.
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Wisdom Wealth Strategies holds itself to a fiduciary standard, which means the firm and its associates will
act in the utmost good faith, performing in a manner believed to be in the best interest of its clients. Our
firm believes that business methodologies, ethics rules, and adopted policies are designed to eliminate or at
least minimize material conflicts of interest and to appropriately manage any material conflicts of interest
that remain. You should be aware that no set of rules can possibly anticipate or relieve all material conflicts
of interest. Our firm will disclose to its advisory clients any material conflict of interest relating to the firm,
its representatives, or any of its employees which could reasonably be expected to impair the rendering of
unbiased and objective advice.
Code of Ethics Description
We have adopted a Code of Ethics that establishes policies for ethical conduct for our personnel. Our firm
accepts the obligation not only to comply with all applicable laws and regulations but also to act in an ethical
and professionally responsible manner in all professional services and activities. Firm policies include
prohibitions against insider trading, circulation of industry rumors, and certain political contributions, among
others. Wisdom Wealth Strategies periodically reviews and amends its Code of Ethics to ensure that it
remains current and requires firm personnel to annual attest to their understanding of and adherence to the
firm’s Code of Ethics. A copy of the firm’s Code of Ethics is made available to any client or prospective client
upon request.
Firm associates that are CERTIFIED FINANCIAL PLANNERTM Practitioners also adhere to the Certified Financial
Planner Board of Standards, Inc.’s Code of Ethics & Professional Responsibility which you may find at
www.cfp.net.
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Privacy Policy Statement
We respect the privacy of all clients and prospective clients both past and present (collectively termed
“customers”). It is recognized that you have entrusted our firm with non-public personal information, and it
is important that both access persons and customers are aware of firm policy concerning what may be done
with that information.
The firm collects personal information about customers from the following sources:
• Information clients provide to complete their financial plan or investment recommendation;
• Information clients provide in engagement agreements and other documents completed in connection
with the opening and maintenance of an account;
• Information customers provide verbally; and
• Information received from service providers, such as custodians, about client transactions.
The firm does not disclose non-public personal information about our customers to anyone, except in the
following circumstances:
• When required to provide services our clients have requested;
• When our customers have specifically authorized us to do so;
• When required during the course of a firm assessment (i.e., independent audit); or
• When permitted or required by law (i.e., periodic regulatory examination).
To ensure security and confidentiality, the firm maintains physical, electronic, and procedural safeguards to
protect the privacy of customer information. Within the firm, access to customer information is restricted to
personnel that need to know that information. All access persons and service providers understand that
everything handled in firm offices are confidential and they are instructed not to discuss customer
information with someone else that may request information about an account unless they are specifically
authorized in writing by the customer to do so. This includes providing information about a family member’s
account.
The firm will provide you with its updated privacy policy, in advance, if firm privacy policies are expected to
change.
Firm Recommendations and Conflicts of Interest
Our associates are prohibited from borrowing from or lending to a client unless the client is an approved
financial lending institution.
Neither our firm nor its associates are authorized to recommend to a client, or effect a transaction for a
client, involving any security in which our firm or a “related person” (associates, their immediate family
members, etc.) has a material financial interest, such as in the capacity as an underwriter, adviser to the
issuer, etc.
Our firm and its related persons may buy or sell securities that are the same as, similar to, or different from,
those we recommend to clients for their accounts. A recommendation made to one client may be different
in nature or in timing from a recommendation made to a different client. Clients often have different
objectives and risk tolerances. At no time will our firm or any related party receive preferential treatment
over our clients. We mitigate this conflict by ensuring that we have policies and procedures in place to
ensure that the firm or a related person will not receive preferential treatment over a client. In order to
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reduce or eliminate certain conflicts of interest involving personal trading (e.g., trading ahead of client
recommendations or trades, etc.), firm policy requires that we restrict or prohibit certain related parties’
transactions. Any exceptions must be approved in writing by our Chief Compliance Officer, and personal
trading accounts are reviewed on a quarterly or more frequent basis. Please refer to Item 6 of the
accompanying Form ADV Part 2B for further details.
Our firm is able to provide a range of advisory services to you and all of our clients. Due to our firm’s ability
to offer two or more services and receive a fee for each engagement, a conflict of interest exists due to the
extended services provided. We therefore note that you are under no obligation to act on our
recommendations and, if you elect to do so, you are under no obligation to complete all of them through
our firm or our recommended service providers.
Item 12 - Brokerage Practices
Wisdom Wealth Strategies does not maintain physical custody of your assets. Your account must be
maintained by an unaffiliated, qualified custodian, such as a broker/dealer, futures commission merchant,
national bank, or a trust company. Our firm is not a custodian or broker/dealer, nor do we have an affiliate
that is a custodian or broker/dealer. We do not receive referrals from a custodian or broker/dealer, nor
would client referrals a factor in our recommendation of a custodian or broker/dealer.
If we are engaged to provide an investment consultation component of our financial planning service, we
may recommend the service provider where client assets are currently maintained. If a client prefers a new
service provider, a recommendation made by the firm would be based on client need, overall cost, and ease
of use.
We have entered into an agreement with Charles Schwab & Co., Inc. (“Schwab”) to serve as custodian of
record for our clients. Schwab is a FINRA and SIPC member,4 as well as an SEC-registered broker/dealer.
While we recommend that you use Schwab as custodian, you must decide whether to do so, and you will
open the account by entering into an account agreement directly with Schwab. We do not technically open
the account for you, but we will assist you in doing so. If you do not wish to place your account assets with
Schwab, we may be able to manage the account at your preferred custodian depending on that custodian’s
account trading policies.
We seek to use a custodian who will hold client assets and execute transactions on terms that are overall
advantageous when compared to other available providers and their services. Our firm considers a wide
range of factors, including, among others, these:
combination of transaction execution services along with asset custody services (generally without a
separate fee for custody)
capability to execute, clear and settle trades (buy and sell securities for an account)
capabilities to facilitate transfers and payments to and from accounts (wire transfers, check requests,
bill payment, etc.)
breadth of investment products made available (stocks, bonds, mutual funds, ETFs, etc.)
availability of investment research and tools that assist us in making investment decisions
quality of services
4 Our advisory firm is not, nor required to be, a Securities Investor Protection Corporation (SIPC) member. Clients may learn more
about the SIPC and how it serves member firms and the investing public by going to their website at http://www.sipc.org.
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competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.)
and willingness to negotiate them
reputation, financial strength, and stability of the provider
their prior service to us and our other clients
availability of other products and services that benefit us, as discussed below.
When your account is maintained at Schwab, you are typically not charged separately for custody services
and Schwab is compensated by charging a commission or other fees on trades that Schwab executes or that
settle into a Schwab account. Schwab’s commission rates applicable to our client accounts were negotiated
based on our commitment to maintain a certain amount of clients’ assets in accounts held at Schwab. This
commitment benefits our client because overall commission rates are lower than they would be if we had
not made the commitment. Schwab Advisor ServicesTM (formerly called “Schwab Institutional”) is Schwab’s
business serving independent investment advisory firms similar to ours. They provide our firm and its clients
with access to its institutional brokerage - trading, custody, reporting and related services - many of which
are not typically available to Schwab retail customers. Schwab also makes available various support services.
Some of those services help us manage or administer our clients’ accounts, while others help us manage and
grow our business. Schwab’s support services are generally available to us on an unsolicited basis (we don’t
have to request them) and at no charge to us as long as we keep a certain level of our clients’ assets in
accounts at Schwab. If we have less than the desired amount of client assets at Schwab, they may charge us
quarterly service fees that we pay from our operating account. Schwab’s institutional brokerage services
include access to a broad range of investment products, execution of securities transactions, and custody of
client assets. The investment products available through Schwab include some to which we might not
otherwise have access or that would require a significantly higher minimum initial investment by our clients.
Schwab’s services described in previous paragraphs generally benefit our clients.
Schwab also makes available to our advisory firm other products and services that benefit us but may not
directly benefit each client’s account. These products and services assist us in managing and administering
our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We
may use this research to service all or some substantial number of our clients’ accounts, including accounts
not maintained at Schwab. In addition to investment research, Schwab also makes available software and
other technology that:
provides access to client account data (such as duplicate trade confirmations and account statements);
facilitates trade execution and allocates aggregated trade orders for multiple client accounts;
provides pricing and other market data;
facilitates payment of our fees from our clients’ accounts; and
assists with back-office functions, recordkeeping and client reporting.
Schwab also offers other services intended to help us manage and further develop our business enterprise,
such as:
educational conferences and events;
technology, compliance, legal, and business consulting;
publications and conferences on practice management and business succession; and
access to employee benefits providers, human capital consultants and insurance providers.
Schwab may provide some of these services itself. In other cases, they may arrange for third-party vendors
to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all
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or a part of a third party’s fees. Schwab may also provide us with other benefits such as occasional business
entertainment of our personnel. Some of the noted tools and services made available by Schwab may
benefit our advisory firm but may not directly benefit a client account. Certain tools, services or discounts
made available to our firm by our custodian benefit our advisory firm but may not directly benefit each
client account. While our firm does not think these services are considered "brokerage or research services"
under Section 28(e) of the Securities Exchange Act of 1934, certain jurisdictions where we serve client
accounts believe they fall under this definition. The availability of these services benefits our firm because
we do not have to produce or purchase them as long as clients maintain assets in accounts at our
recommended custodian. There is a conflict of interest since our firm has an incentive to select or
recommend a custodian based on our firm’s interest in receiving these benefits rather than the client’s
interests in receiving favorable trade execution.
It is important to mention that the benefit received by our firm through participation in any custodian’s
program does not depend on the amount of brokerage transactions directed to that custodian, and our
selection of a custodian is primarily supported by the scope, quality, and cost of services provided as a
whole, not just those services that benefit only our advisory firm. Further, we will act in the best interest of
our clients regardless of the custodian we may select. Our firm conducts periodic assessments of any
recommended service provider which generally involves a review of the range and quality of services,
reasonableness of fees, among other items, in comparison to industry peers.
Best Execution
“Best execution” means the most favorable terms for a transaction based on all relevant factors, including
those listed in the earlier paragraphs. We recognize our obligation in seeking best execution for our clients;
however, it is our belief that the determinative factor is not always the lowest possible cost but whether the
selected custodian’s transactions represent the best “qualitative execution” while taking into consideration
the full range of services provided. Our firm will seek services involving competitive rates, but it may not
necessarily correlate into the lowest possible rate for each transaction. We have determined having our
portfolio management clients’ accounts trades completed through our recommended custodian is
consistent with our obligation to seek best execution of client trades. A review is regularly conducted with
regard to recommending a custodian to our clients in light of our duty to seek best execution.
Directed Brokerage
Not all investment advisers require their clients to direct brokerage, nor do we think our firm is involved in
directed brokerage per industry definition. However, our operational relationship with our custodian
requires client accounts custodied with them to have trades executed per their order routing requirements.
We do not direct which executing broker should be selected for client account trades, whether that is an
affiliate of our preferred custodian or another executing broker of our custodian’s choice. As a result, the
client may pay higher commissions or other transaction costs, experience greater spreads, or receive less
favorable net prices on transactions than might otherwise be the case. In addition, since we routinely
recommend a custodian to our advisory clients, and that custodian may choose to use the execution
services of its broker affiliate for some or all our client account transactions, there is an inherent conflict of
interest involving our recommendation since our advisory firm receives various products or services
described above from that custodian. Note that we are not compensated for trade routing/order flow, nor
are we paid commissions on such trades. We do not receive interest on an account’s cash balance.
Client accounts maintained at our custodian are unable to direct brokerage. As a result, they may pay higher
commissions or other transaction costs, potentially experience greater spreads, or receive less favorable net
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prices on transactions for their account than would otherwise be the case if they had the opportunity to
direct brokerage.
For accounts maintained at a custodian of the client’s choice (e.g., held-away accounts), the client may
choose to request that a particular broker is used to execute some or all account transactions. Under these
circumstances, the client will be responsible for negotiating, in advance of each trade, the terms and/or
arrangements involving their account with that broker, and whether the selected broker is affiliated with
their custodian of record or not. We will not be obligated to seek better execution services or prices from
these other brokers, and we will be unable to aggregate transactions for execution via our custodian with
other orders for accounts managed by our firm. As a result, the client may pay higher commissions or other
transaction costs, potentially experience greater spreads, or receive less favorable net prices on transactions
for their account than would otherwise be the case.
Aggregating Securities Transactions
Trade aggregation involves the purchase or sale of the same security for several clients/accounts at
approximately the same time. This may also be termed “blocked” or “batched” orders. Aggregated orders
are effected in an attempt to obtain better execution, negotiate favorable transaction rates, or to allocate
equitably among multiple client accounts should there be differences in prices, brokerage commissions or
other transactional costs that might otherwise be unobtainable through separately placed orders. Our firm
may, but is not obligated, to aggregate orders, and our firm does not receive additional compensation or
remuneration as a result of aggregated transactions.
Transaction charges and/or prices may vary due to account size and/or method of receipt. To the extent that
the firm determines to aggregate client orders for the purchase or sale of securities, including securities in
which a related person may invest, the firm will generally do so in accordance with the parameters set forth
in SEC No Action Letter, SMC Capital, Inc. (publicly available September 5th, 1995)
(https://www.sec.gov/divisions/investment/noaction/smccapital090595.htm), or similar guidance if the
jurisdiction in which the client resides provides such direction. A copy of the referenced No Action Letter will
be provided upon request.
Please note that when trade aggregation is not allowed or infeasible and necessitates individual transactions
(e.g., withdrawal or liquidation requests, odd-lot trades, non-discretionary accounts, etc.), an account may
potentially be assessed higher costs or less favorable prices than those where aggregation has occurred.
We review firm trading processes on a periodic basis to ensure they remain within stated policies and
regulation. Our clients will be informed, in advance, should trading practices change at any point in the
future.
Item 13 - Review of Accounts
Scheduled Reviews
Financial Planning Services
Periodic financial check-ups or reviews are recommended if you are receiving our financial planning services,
and we recommend that they occur at least on an annual basis whenever practical. Reviews will be
conducted by your assigned investment adviser representative and may involve analysis and possible
revision of your previous financial plan or investment allocation.
A copy of revised plans or asset allocation reports will be provided to the client upon request. Unless
provided for in your engagement agreement, reviews are generally conducted under a new or amended
agreement and will be assessed at our current fee rate.
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Investment Supervisory Services
Investment supervisory services accounts are reviewed on an annual or more frequent basis by assigned
internal portfolio manager as well as firm supervisory personnel. Client reviews are completed by your
investment adviser representative, and we recommend that they occur on at least an annual basis. A copy of
a revised investment guideline or asset allocation reports will be provided to the client upon request.
Retirement Plan Services
Periodic plan sponsor reviews are encouraged, and we believe they should occur at least on an annual basis
if practical. Reviews will be conducted by your assigned investment adviser representative, and typically
involves an analysis and possible revision of previous plan recommendations. We will conduct annual plan
participant group review sessions upon plan sponsor request.
Unscheduled Reviews
Financial Planning Services
You should contact our firm for additional reviews when you anticipate or have experienced changes in your
financial situation (i.e., changes in employment, an inheritance, the birth of a new child, etc.), or should you
prefer to change requirements involving your investment account. Non-periodic reviews are generally
conducted by your investment adviser representative, which may occur under a new or amended
agreement, and will be assessed at our published rate. A copy of revised plans or asset allocation reports will
be provided to the client upon request.
Investment Supervisory Services and Investment Management
Additional reviews by your portfolio manager and/or firm supervisory personnel may be triggered by news
or research related to a specific holding, a change in our view of the investment merits of a holding, or news
related to the macroeconomic climate affecting a sector or holding within that sector. A portfolio may be
reviewed for an additional holding or when an increase in a current position is under consideration.
Account cash levels above or below what we deem appropriate for the investment environment, given the
client's stated tolerance for risk and investment objectives, may also trigger a review.
Retirement Plan Services
Plan sponsors should contact our firm for additional reviews when there are material changes to the plan
requirements or financial situation. The review is conducted by your investment adviser representative and
typically involves an analysis and possible revision of previous plan recommendations. We do not conduct
unscheduled participant-level reviews.
Client Reports
Whether you have opened and maintained an investment account on your own or with our assistance, you
will receive account statements sent directly from mutual fund companies, transfer agents, custodians, or
brokerage companies where your investments are held. We urge you to carefully review these account
statements for accuracy and clarity, and to ask questions when something is not clear.
Our firm may provide portfolio “snapshots” if we are engaged to provide periodic asset allocation or
investment advice. However, we do not provide ongoing performance reporting under our financial planning
engagements. For investment supervisory services accounts, our advisory firm may provide written portfolio
performance reports, and such reports will be in prepared in accordance with appropriate jurisdictional
guidance. Clients are urged to carefully review and compare account statements that they have received
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from their account custodian with any report they may receive from any source if that report contains any
type of performance information.
Item 14 - Client Referrals and Other Compensation
Economic Benefit from External Sources and Conflicts of Interest
As disclosed in Item 12, Wisdom Wealth Strategies receives economic benefit from our custodian in the
form of various products and services they make available to the firm and other independent investment
advisers that may not be made available to a “retail investor.” As previously stated, there is no direct link
between our firm’s participation in their program and the investment advice we may provide to our clients.
These benefits include the following products and services (provided either without cost or at a discount):
receipt of duplicate client statements and confirmations
research related products and tools
access to trading desks serving our clients
access to block trading services
the ability to have advisory fees deducted directly from a client’s accounts (per written agreement)
resource information related to capital markets and various investments
access to an electronic communications networks for client order entry and account information
access to mutual funds with no transaction fees and/or select investment managers
discounts on marketing, research, technology, and practice management products or services provided
to our firm by third-party providers
Some of the noted products and services made available by Schwab benefit our advisory firm but may not
directly benefit a client account. There is a conflict of interest since our firm has an incentive to select or
recommend a custodian based on our firm’s interest in receiving these benefits rather than your interest in
receiving favorable trade execution. It is important to mention that the benefit received by our firm through
participation in any custodian’s program does not depend on the amount of brokerage transactions directed
to that custodian, and our selection of a custodian is primarily supported by the scope, quality, and cost of
services provided as a whole -- not just those services that benefit only our advisory firm. As part of our
fiduciary duty, our firm endeavors to place the interests of our clients first, without consideration to our
own financial interest or the interest of a related person. Our clients should be aware that the receipt of any
economic benefit by our firm or its associates in and of itself creates a potential conflict of interest and may
indirectly influence our choice of Schwab for its custody and brokerage services. However, we strive to
overcome any implicate bias these benefits might create, and we will avoid recommending services or offer
investment advice that is not in your best interest.
Advisory Firm Payments for Client Referrals
We do not engage in solicitation activities involving unregistered persons. If we receive or offer an
introduction to a client, we do not pay or earn referral fee, nor are there established quid pro quo
arrangements. Each client retains the option to accept or deny such referral or subsequent services.
Item 15 - Custody
Your assets will be maintained by an unaffiliated, qualified custodian, they are not held by our firm or any
associate or our firm. In keeping with this policy involving our client funds or securities, Wisdom Wealth
Strategies:
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Restricts the firm or an associate from serving as trustee or having general power of attorney over a
client account;
Prohibits any associate from having authority to directly withdraw securities or cash assets from a client
account. Although we may be deemed to have “constructive custody” of your assets since we may
request the withdrawal of advisory fees from an account, we will only do so through the engagement of
a qualified, unaffiliated custodian maintaining your account assets, via your prior written approval (see
Item 5);
Does not accept or forward client securities (i.e., stock certificates) erroneously delivered to our firm;
Will not collect advance fees of $500 or more for services that are to be performed six months or more
into the future; and
Will not authorize an associate to have knowledge of a client’s account access information (i.e., online
401(k), brokerage or bank accounts) if such access would allow physical control over account assets.
Your custodian of record will provide you with your investment account transaction confirmations and
account statements, which will include debits and credits as well as our firm’s advisory fee for that period.
Statements are provided on at least a quarterly basis or as transactions occur within their account. Wisdom
Wealth Strategies will not create a separate account statement for any client nor serve as the sole recipient
of a client account statement.
If you receive periodic reports from our advisory firm that includes investment performance information,
you are urged to carefully review and compare your account statements that you have received directly
from your custodian of record with any performance report from our firm.
Item 16 - Investment Discretion
Investment Supervisory Services
Wisdom Wealth Strategies generally provides its investment supervisory services on a discretionary basis.
Discretionary trading authority allows our firm to implement investment decisions, such as the purchase or
sale of a security on behalf of your account, without requiring your prior authorization for each transaction
in order to meet your stated investment objectives. This authority will be granted through your execution of
our engagement agreement and your custodian’s account documents. Note that the custodian will limit our
firm’s authority within your account to the placement of trade orders and the request for the deduction of
our advisory fees.
Our firm prefers to not manage client accounts on a non-discretionary basis, but we may accommodate such
requests on a case-by-case basis. This type of trading authority requires your ongoing prior approval
involving the investment and reinvestment of account assets, including portfolio rebalancing. If you find it
necessary to require such restrictions, our advisory firm may choose to not serve as your investment
adviser, or we may assess the higher fee range due to the additional operational costs involved managing
your account. Please note that in light of the requirement for your pre-approval you must make yourself
available and keep our firm updated on your contact information so that instructions can be efficiently
effected on your behalf. You will be required to execute our firm’s client services agreement that describes
our limited account authority, as well as the custodian of record’s account documents that includes their
limited power of attorney form or clause. In addition, non-discretionary accounts are generally unable to be
aggregated (see Item 12) and may experience higher trading fees or receive less favorable prices than those
accounts where trade aggregation has occurred.
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You may amend our account authority by providing our firm revised written instructions. As noted in Item 4,
we will allow for reasonable restrictions involving the management of your account. It remains your
responsibility to notify us if there is any change in your situation and/or investment objective so that we
may reevaluate previous investment recommendations or portfolio holdings.
Investment Consultation Engagements
If you ask us to assist you in any trade execution (including account rebalancing) under an investment
consultation engagement through our financial planning engagement, such as assisting you with your held-
away assets, it will only be accomplished on a non-discretionary basis.
Retirement Plan Services
Our firm does not serve as an ERISA retirement plan investment manager. We do not have trading authority
within plan participants’ self-directed accounts.
Item 17 - Voting Client Securities
You may periodically receive proxies or other similar solicitations sent directly from your selected custodian
or transfer agent. If we receive a duplicate copy, we do not normally forward these or any correspondence
relating to the voting of your securities, class action litigation, or other corporate actions.
Our firm does not vote proxies on your behalf, including accounts that we have discretionary trading
authority over; nor do we offer guidance on how to vote proxies. We do not offer guidance involving any
claim or potential claim in any bankruptcy proceeding, class action securities litigation or other litigation or
proceeding relating to securities held at any time in a client account, including, without limitation, to file
proofs of claim or other documents related to such proceeding, or to investigate, initiate, supervise or
monitor class action or other litigation involving client assets. However, we will answer limited questions
with respect to what a proxy voting request or other corporate matter may be and how to reach the issuer
or their legal representative.
Item 18 - Financial Information
Our advisory firm will not take physical custody of your assets, nor do we have the type of account authority
to have such control. Fee withdrawals must be done through a qualified intermediary (e.g., your custodian
of record), per your prior written agreement.
Engagements with our firm do not require that we collect fees from you of $500 or more for our advisory
services that we have agreed to perform six months or more into the future.
Neither our firm nor its management serve as general partner for a partnership or trustee for a trust in
which the firm’s advisory clients are either partners of the partnership or beneficiaries of the trust.
The firm and its management do not have a financial condition likely to impair its ability to meet
commitments to clients, nor has the firm and its management been the subject of a bankruptcy petition.
Due to the nature of our firm’s advisory services and operational practices, an audited balance sheet is not
required nor included in this brochure.
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