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Firm Brochure ADV Part 2A
The financial advisors of WJ Wealth Management are registered representatives with securities offered
through LPL Financial, member FINRA/SIPC.
Registered As:
WJ Wealth Management, LLC
Doing Business As:
WJ Wealth Management
Registered Investment Adviser
18275 N. 59th Avenue, Suite B-110
Glendale, Arizona 85308
(602) 942-1321
www.wjwealthmanagement.com
March 6, 2026
NOTICE TO PROSPECTIVE CLIENTS: READ THIS DISCLOSURE BROCHURE IN ITS ENTIRETY
All the material within this brochure should be reviewed by those who are considering becoming a client of our
firm. This brochure provides information about the qualifications and business practices of WJ Wealth
Management doing business as WJ Wealth Management. If you have any questions about the contents of this
brochure, please contact WJ Wealth Management at
(602) 942-1321 or jeffry.r.jones@lpl.com.
In accordance with federal and state regulations, this brochure is on file with the appropriate securities’
regulatory authorities
as required. The information provided within this brochure is not to be construed as an endorsement or
recommendation by state securities authorities in any jurisdiction within the United States, or by the United States
Securities and Exchange
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Commission. The information in this brochure has not been approved or verified by the United States Securities
and Exchange Commission or by any state securities authority. Registration of a Registered Investment Adviser
does not imply any level of skill or training.
Additional information about WJ Wealth Management LLC is also available on the SEC’s website at
www.adviserinfo.sec.gov.
Material Changes
At least annually, this section will summarize the material changes that have been made to WJ
Wealth Management’s brochure. We will also reference the date of our last annual update of our
brochure. We will ensure that you receive a summary of any material changes to this and
subsequent brochures within 120 days of the close of our business’ fiscal year. We may further
provide other ongoing disclosure information about material changes as necessary. We will further
provide you with a new brochure as necessary based on changes or new information, at any time,
without charge.
There have been no material changes since our last brochure dated February 1, 2025.
Currently, our Disclosure Brochure may be requested by contacting us at (602) 942-1321 or at
jeffry.r.jones@lpl.com . We welcome visitors to our website at
www.wjwealthmanagement.com for a comprehensive overview of our firm and the
professional services we offer.
Additional information about WJ Wealth Management is also available via the SEC’s website
www.advserinfo.sec.gov . The SEC’s website also provides information about any persons affiliated
with WJ Wealth Management who are registered, or are required to be registered, as investment
adviser representatives of WJ Wealth Management.
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Table of Contents
Part 2A
Cover Page…………………………………………………………………………………………………1
Material Changes…………………………………………………………………………………..……..2
Table of Contents………………………………………………………………………………………….3
Advisory Business………………………………………………………….………………………………4
Fees and Compensation……………...……………………….………………………………………..7
Performance-Based Fees and Side-by-Side ..……………………………………………………..12
Types of Clients…...……….…………………………………………………….………………………..12
Method of Analysis, Investment Strategies and Risk of Loss………….………………………….12
Disciplinary Information………………………………………………………………………………….13
Other Financial Industry Activities and Affiliations……………………………………….…………14
Brokerage Practices……………………..………………………………………………………...……..15
Review of Accounts………...……………………………………………………………………………..17
Client Referrals and Other Compensation…………………...……………………………………….18
Custody…………………………………………………………………..………………………………….18
Investment Discretion……..………………………………………………………………………………19
Voting Client Securities…….……………………………………………………………………………..19
Financial Information…………………..………………………………………………………………….19
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Advisory Business
WJ Wealth Management is a registered investment adviser in Arizona. The firm’s founding members
Roger L. Wilson and Jeffry R. Jones organized the firm as an LLC in 2013 under the name WSJ/2nd50
Advisors while acting as Registered Representative and Investment Adviser Representatives of LPL
Financial. In 2014, the name, WSJ/2nd 50 Advisors, was changed to WJ Wealth Management and
registered as an independent investment adviser in Arizona.
Mr. Wilson and Mr. Jones remain as Registered Representative of LPL Financial.
Any and all material conflicts of interest are disclosed herein.
WJ Wealth Management provides fee-based investment advisory services primarily to individual client
and high –net worth individuals.
•
The firm is a Registered Investment Adviser regulated by the U.S. Securities and Exchange
Commission.
The firm is compensated based on a percentage of assets under management.
•
•
The individuals associated with WJ Wealth Management are appropriately licensed and
authorized to provide advisory services on behalf of WJ Wealth Management.
Advisor representatives are restricted to providing services and charging fees based in accordance
with the descriptions detailed in this document and the account agreement. However, the exact
service and fees charged to a particular client are dependent upon the representative that is
working with the client. Advisors are instructed to consider the individual needs of each client when
recommending an advisory platform. Investment strategies and recommendations are tailored to
the individual needs of each client. Individuals associated with WJ Wealth Management are also
registered representatives of LPL Financial, an SEC registered broker/dealer, a member of the
Financial Regulatory Authority (“FINRA”) and the Securities Investors Protection Corporation (“SIPC”).
Any securities transactions shall be directed to LPL Financial for execution. WJ Wealth Management
and LPL Financial are not affiliated legal entities.
Financial Planning Services
As a part of our financial planning services, WJ Wealth Management, through its IARs, may provide
personal financial planning tailored to the individual needs of the client. These services may include,
as selected by the client on the financial planning agreement, information and recommendations
regarding tax planning, investment planning, retirement planning, pension consulting, estate needs
business needs, education planning, life and disability insurance needs, long-term care needs and
cash flow/budget planning. The services take into account information collected from the client
such as financial status, investment objectives and tax status, among other data. Fees for such
services are negotiable and detailed in the financial planning agreement. The financial plan may
include generic recommendations as to general types of investment products or specific securities
which may be appropriate for the Client to purchase given his/her financial situation and objectives.
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The Client is under no obligation to act upon the investment adviser’s recommendation or purchase
such securities through WJ Wealth Management and the IAR. However, if the Client desires to
purchase securities or advisory services in order to implement his/her financial plan, WJ Wealth
Management may make a variety of products and services available through its IARs, in their
separate capacity as registered representatives and/or investment adviser representatives of LPL
Financial. This may result in the payment of normal and customary commissions, advisory fees, or
other types of compensation to the IARs of WJ Wealth Management in their separate capacity.
A conflict exists between the interest of the investment adviser and the interests of the client.
Depending on the type of account that could be used to implement a financial plan, such
compensation may include, but is not limited to, advisory fees; commissions; mark-ups and mark-
downs; transaction charges; confirmation charges; small account fees; mutual fund 12b- fees; mutual
fund sub-transfer agency fees; hedge fund, managed futures, and variable annuity investor servicing
fees; retirement plan fees; fees in connection with an insured deposit account program; marketing
support payments from mutual funds; annuity and insurance sponsors; administrative servicing fees for
trust accounts; referral fees; compensation for directing order flow; and bonuses, awards or other
things of value offered by WJ Wealth Management to the IAR. To the extent that IAR recommends
that Client invest in products and services that will result in compensation being paid to the IARs of WJ
Wealth Management, in their capacity as registered representatives or investment adviser
representatives of LPL Financial, this presents a conflict of interest.
This compensation to IAR of WJ Wealth Management may be more or less, depending on the
product or service that the IAR recommends. Therefore, the IAR may have a financial incentive to
recommend that a financial plan be implemented using a certain product or service over another
product or service.
The IAR, in his/her capacity as a registered representative and/or investment adviser representative of
LPL Financial, may receive additional cash or non-cash compensation from advisory product
sponsors. Such compensation may not be tied to the sale of any products. Compensation may
include such items as gifts valued at less than $100 annually, an occasional dinner or ticket to a
sporting event, or reimbursement in connection with education meetings or marketing or advertising
initiatives.
Hourly Consulting Services
WJ Wealth Management, though its IARs, may provide consulting services on an hourly basis, with
fees not to exceed $400.00 per hour. These services may include, as selected by the client in the
consulting agreement, advice regarding tax planning, investment planning, retirement planning,
pension consulting, estate planning, cash flow/budget planning, business planning, education
planning, and personal financial planning. The services take into account information collected from
the client such as financial status, investment objectives and tax status, among other data. The IARs
may or may not deliver to the client a written analysis or report as part of the services. The IARs tailor
the hourly consulting services to the individual needs of the client based on the investment objective
chosen by the client. The engagement terminates upon final consultation with the client. Fees for
such services are negotiable and detailed in the consulting agreement.
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Neither the firm nor any investment advisor representative are registered or have any application
pending to register, as a futures commission merchant, commodity pool operator, a commodity
trading advisor, or a representative of the foregoing.
Asset Management
WJ Wealth Management through its Investment Adviser Representatives provides ongoing investment
advice and management on assets in the client’s custodial Strategic Wealth Management (SWM) /
Managed Wealth Portfolio – Advisor Sleeve (MWP) accounts held at LPL Financial. More specific
account information and acknowledgements are further detailed on the account application.
Investment advisor representatives provide advice on the purchase and sale of various types of
investments, such as mutual funds, exchange-traded funds (“ETFs”), real estate investment trusts
(“REITs”), equities, and fixed income securities. The advice is tailored to the individual needs of the
client based on the investment objective chosen by the client in order to help assist clients in
attempting to meet their financial goals. Accounts are reviewed on a regular basis and rebalanced
as necessary according to each client’s investment profile.
A minimum account value of $25,000 is generally required for the program. In certain instances, WJ
Wealth Management will permit a lower minimum account size.
Assets managed in a wrap fee account are not managed differently from a non-wrap fee account.
However, WJ Wealth Management may charge a higher fee, up to 2.5%, and receive a portion of
the wrap fee for services provided.
WJ Wealth Management offers asset management on a discretionary and non-discretionary basis.
As of January 15, 2026 the firm has $261,532,091.00 in discretionary assets under management.
Optimum Market Portfolios Program (OMP)
OMP offers clients the ability to participate in a professionally managed asset allocation program
using Optimum
Funds Class I shares. Under OMP, client will authorize LPL on a discretionary basis to purchase and sell
Optimum Funds pursuant to investment objectives chosen by the client. Advisor will assist the client in
determining the suitability of OMP for the client and assist the client in setting an appropriate
investment objective. Advisor will have discretion to select a mutual fund asset allocation portfolio
designed by LPL consistent with the client’s investment objective. LPL will have discretion to purchase
and sell Optimum Funds pursuant to the portfolio selected for the client. LPL will also have authority to
rebalance the account.
A minimum account value of $10,000 is required for OMP.
Model Wealth Portfolios Program (MWP)
MWP offers clients a professionally managed mutual funds asset allocation program. WJ Wealth
Management investment advisor representatives will obtain the necessary financial data from the
client; assist the client in determining the suitability of the MWP program and assist the client in setting
an appropriate investment objective. The Advisor will initiate the steps necessary to open an MWP
account and have discretion to select a model portfolio designed by LPL’s Research Department
consistent with the client’s stated investment objective. LPL’s Research Department is responsible for
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selecting the mutual funds within a model portfolio and for making changes to the mutual funds
selected.
The client will authorize LPL to act on a discretionary basis to purchase and sell mutual funds
(including in certain circumstances exchange traded funds) and to liquidate previously purchased
securities. The client will also authorize LPL to effect rebalancing for MWP accounts.
The MWP platform does make available model portfolios designed by strategists other than LPL’s
Research Department. This includes the Guidance Model portfolios which are personally managed
by the Principals of WJ Wealth Management using Exchange Traded Funds (ETF’s). If such models are
made available, Advisor will have discretion to choose among the available models designed by LPL
and outside strategists and/or WJ Wealth Management.
A minimum account value of $25,000 is required for MWP / Advisor Sleeve.
Fees and Compensation
Financial Planning
Fees for financial planning and consulting services are charged on an hourly or flat fee basis. The fee
will be based on the type of services to be provided. Our standard fee is $200 per hour. Fixed fees
range between $500 and $2,500. The client may choose to pay the fee upon execution of an
Agreement with WJ Wealth Management, upon delivery of the written financial plan, or a
combination of upfront and in arrears.
For clients that elect to receive ongoing services, the fee may be payable on a monthly basis. The
client generally makes a check payable to WJ Wealth Management for financial planning and
consulting services but may also pay by credit card. In the event that the client pays by credit card,
each transaction will be invoiced. The total estimated fee, as well as the ultimate fee charged, is
based on the scope and complexity of the engagement. Lower fees for comparable services may
be available from other sources. In the event that a client desires, a client can engage certain
representatives of the firm, in their individual capacities as registered representatives or investment
adviser representatives of LPL Financial, an SEC registered investment adviser and FINRA/SIPC
member broker-dealer, to implement investment recommendations on a commission or advisory fee
basis. In the event a client chooses to purchase investment products through LPL Financial, LPL
Financial will charge brokerage commissions to effect securities transactions, a portion of which
commissions LPL Financial shall pay to the firm’s representatives, as applicable. The brokerage
commissions charged by LPL Financial may be higher or lower than those charged by other broker-
dealers.
Asset Management
The specific manner in which fees are charged by the firm is established in a client’s written
agreement and account application between the client and WJ Wealth Management – up to 2.5%
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of assets under management. The account fee is typically a straight percentage based on the value
of all assets in the account, including cash holdings. The account fee also may be structured on a
tiered basis, with a reduced percentage rate based on reaching certain thresholds.
Maximum Fee Schedule:
Example of a Typical Fee
Schedule:
Account Balance
$0 - $50,000
$50,001 - $100,000
$100,001 - $250,000
$250,001 +
Fee Account Balance
2.5% $0 - $100,000
2.0% $100,001 - $500,000
1.5% $500,001 - $1,000,000
1.0% $1,000,000 +
Fee
1.25%
1.05%
1.00%
0.85%
In this example, if the fee is charged on a straight percentage basis, the annual fee on an account
valued at $150,000 would be calculated as follows:
$150,000 x 1.05% = $1,575 annually; $1,575/4 = $393.75 quarterly
If the fee is charged on a tiered basis, the annual fee on an account valued at $150,000 would be
calculated as follows:
$100,000 x 1.25% = $1,250 annually; $1,250/4 = $312.50 quarterly
$50,000 x 1.05% = $525.00 annually; $525.00/4 = $131.25 quarterly
100% of the account fee is paid to WJ Wealth Management and is shared with the IAR.
Clients can determine to engage the services of WJ Wealth Management on a discretionary or non-
discretionary
basis. WJ Wealth Management representatives may at their discretion negotiate a fee up to the
maximum fee listed above.
If the account is closed within the first six months by the client or as a result of withdrawals which bring
the account value below the required minimum, Advisor reserves the right to retain the pre-paid
quarterly advisory fee for the current quarter or cancel and rebill all transactions in the account at
normal and customary brokerage commission rates, in order to cover the administrative cost of
establishing the account which may include costs to transfer positions into and out of the account,
data entry costs to open the account, cost associated with reconciling of positions in order to issue
quarterly performance reports, and the cost of re-registering positions.
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The account fee charged to the client for each advisory program is negotiable, subject to the
following maximum account fees:
Annual Percentage of Assets Charge
Advisory Program
Asset Management
OMP
2.5%
2.5%
MWP
2.5%
Account fees are payable quarterly either in advance or in arrears.
In the event that a client desires, a client can engage certain representatives of the firm, in their
individual capacities as registered representative of LPL Financial, a SEC registered and FINRA/SIPC
member broker-dealer, to implement investment recommendations on a commission basis. In the
event a client chooses to purchase investment products through LPL Financial, LPL Financial will
charge brokerage commissions to effect securities transactions, a portion of which commissions LPL
Financial shall pay to the firm’s representatives, as applicable.
The brokerage commission charged by LPL Financial may be higher or lower than those charged by
other broker/dealers.
In addition, LPL Financial, as well as the firm’s representatives, relative to commission mutual fund
purchases, may also receive additional ongoing 12b-1 trailing commission compensation directly
from the mutual fund company during the period that the client maintains the mutual fund
investment.
The recommendation that a client purchases a commission product from LPL Financial presents a
conflict of interest, as the receipt of commission may provide an incentive to recommend investment
products based on commissions received, rather than on a particular client’s need. No client is under
any obligation to purchase any commission products from LPL Financial. The firm’s Chief Compliance
Office, Jeffry R. Jones, is available to address any questions that a client or prospective client may
have regarding this conflict of interest.
LPL Financial charges brokerage commissions and transaction fees for affecting certain securities
transactions (i.e., transaction fees are charged for certain no-load mutual funds, commissions are
charged for individual equity and debt securities transactions). LPL enables us to obtain many no-
load mutual funds without transaction charges and other no-load funds at nominal transaction
charges. LPL Financial commission rates are generally discounted from customary retail commission
rates. However, the commission and transaction fees charged by LPL Financial may be higher or
lower than those charged by other custodians and broker-dealers. Clients may direct their brokerage
transactions at a firm other than LPL Financial. Advisory fees are generally not reduced to offset
commissions or markups.
When dealing with investment advisory clients and services, investment adviser representatives have
an affirmative duty of care, loyalty, honesty and good faith to act in the best interests of its clients.
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Investment adviser representatives should fully disclose all material facts concerning any conflict that
does arise with these clients and should avoid even the appearance of a conflict of interest.
The Firm and IARs must abide by honest and ethical business practices including, but not be limited
to:
• Not inducing trading in a client’s account that is excessive in size or frequency in view of the
financial
resources and character of the account;
• Making recommendations with reasonable grounds to believe that they are appropriate
based on the information furnished by the client;
•
Placing discretionary orders only after obtaining client’s written trading authorization
contained within the advisory agreement or via separate amendment;
• Not borrowing money or securities form, or lending money or securities to a client;
• Not placing an order for the purchase or sale of a security if the security is not registered, or
the security or
transaction is not exempt from registration in the specific state;
The Firm and IAR will:
• Allocate securities in a manner that is fair and equitable to all clients
• Not effect agency cross-transactions for client accounts
All Investment Adviser Representatives of WJ Wealth Management are required to sign an
acknowledgement of their understanding and acceptance of these terms.
Please note, clients may purchase investment products recommended by our firm through other,
non-affiliated broker-dealers or agents.
The Firm generally does not receive more than 10% of its revenue from advisory clients as a result of
commissions or other compensation for the sale of investment products the firm recommends to its
clients. When the firm’s representatives sell an investment product on a commission basis, the firm
does not charge an advisory fee in addition to the commissions paid by the client for such product.
When providing services on an advisory fee basis, WJ Wealth Management representatives do not
also receive commission compensation for such advisory services (except for any ongoing 12b-1
trailing commission compensation that may be received as previously discussed). However, a client
may engage the firm to provide investment management services for an advisory fee and also
purchase an investment product from the firm’s representatives on a separate commission basis.
Fees for customized and participant advisory services are typically based on the value of assets under
management and will vary by engagement. The amount of the fee will be set out in the client
agreement executed by the client at the time the relationship is established.
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The advisory fee is negotiable between the investment advisor representative and the client and is
payable either in advance or in arrears as described in the client agreement. LPL Financial is
responsible for calculating and deducting advisory fees from client accounts held at LPL Financial.
Client will provide LPL Financial with written authorization to deduct fees and pay the advisory fees
to the RIA firm. The advisory fee is paid directly by LPL to the RIA firm (not the individual). The RIA
firm will then share the advisory fee with its advisors/associated persons. A custom program account
may be terminated according to the client agreement. If the advisory agreement is terminated
before the end of the quarterly period, client is entitled to a pro-rated refund of any pre-paid
quarterly advisory fee based on the number of days remaining in the quarter after the termination
date.
In certain cases, LPL may serve as the broker dealer on transactions in a customized advisory
account. In such case, LPL may charge the client transaction charges in connection with trade
execution through LPL.
The transaction charges will be clearly stated in the client agreement executed by the client at the
time the relationship is established. If the custom advisory services apply to variable annuities for
which the investment advisory representative receives trail compensation, such trail fees generally
will be used to offset the advisory fee.
In most cases, however, a third-party broker-dealer will provide trade execution. In such case the
broker-dealer may charge clients commissions, markups, markdowns and/or transaction charges.
Advisor receives compensation as a result of a client’s participation in an LPL program. Depending
on, among other things, the size of the account changes in its value over time, the ability to
negotiate fees or commissions, and the number of transactions, the amount of this compensation
may be more or less than what the Advisor would receive if the client participated in other programs,
whether through LPL or another sponsor, or paid separately for investment advice, brokerage and
other services.
LPL Financial serves as program sponsor, investment advisor and broker-dealer for the LPL advisory
programs. WJ Wealth Management and LPL may share in the account fee and other fees
associated with program accounts.
Associated persons of Advisor may also be registered representatives of LPL.
Lower fees for comparable services may be available from other sources.
Investment Advisor Representatives may also be licensed insurance agents. In the capacity of an
insurance agent, they may recommend the purchase of certain insurance-related products on a
commission basis.
The purchase of securities and/or insurance product commission presents a conflict of interest, as the
receipt of commissions may provide an incentive to recommend investment products based on
commissions received, rather than on a particular client’s need. No client is under any obligation to
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purchase any commission products from Investment Advisor Representatives of the Firm. Clients may
purchase investment products recommended by investment advisory representatives through other,
non-affiliated broker-dealers or insurance agents. Such conflicts are subject to review by the Chief
Compliance Officer for consistency with the firm’s Code of Ethics.
Performance-Based Fees and Side-By-Side Management
Neither the firm or any supervised persons accepts performance-based fees, fees based on a share
of capital gains on or capital appreciation of the assets of a client such as a hedge fund or other
pooled investment vehicle.
Types of Clients
The advisory services offered by WJ Wealth Management are available for individuals, individual
retirement accounts (“IRAs”), banks and thrift institutions, pension and profit-sharing plans, including
plans subject to Employee Retirement Income Security Act of 1974 (“ERISA”), trusts estates, charitable
organizations, state and municipal government entities, corporations and other business entities.
However, the firm generally provides investment advice to individuals and high net-worth individuals.
The firm is currently not working with other types of clients or pursuing them as prospects but would
not turn away any opportunities that may arise.
For LPL Financials’ Sponsored Advisory Programs account minimums are as follows:
• Asset Management: $25,000
• Optimum Market Portfolios Program (OMP): $10,000
Personal Wealth Portfolios Program (PWP): $250,000
•
• Model Wealth Portfolios Program (MWP): $25,000
For customized advisory services, any required minimum account value will be set out in the client
agreement.
Methods of Analysis, Investment Strategies and Risk of Loss
We emphasize continuous and regular account supervision. As part of our asset management
service, we generally create a portfolio, consisting of individual stocks or bonds, exchange traded
funds (“ETFs”), options, mutual funds and other public and private securities or investments.
The client’s individual investment strategy is tailored to their needs and may include some or all of the
previously mentioned securities. Each portfolio will be initially designed to meet a particular
investment goal, which we determine to be suitable to the client’s circumstances. Once the
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appropriate portfolio has been determined, we review the portfolio on a regular basis and if
necessary, rebalance the portfolio based upon the client’s individual needs, state goals and
objectives.
The firm uses a combination of fundamental and technical analysis in order to formulate investment
advice when managing assets. Depending on the analysis, the firm will implement a long- or short-
term trading strategy based on the particular objectives and risk tolerance of a particular client.
Fundamental analysis involves an evaluation of the financial condition and competitive position of a
particular fund or issuer which typically involves an analysis of an issuer’s management team,
investment strategies, style, past performance, reputation and financial strength in relation to the
asset class concentrations and risk exposures of the Firm’s model asset allocations. A substantial risk in
relying upon fundamental analysis is that while the overall health and position of a company may be
good, evolving market conditions may negatively impact the security.
Technical analysis involves the examination of past market data rather than specific issuer information
in determining the recommendations made to clients. Technical analysis may involve the use of
mathematical based indicators and charts, such as moving averages and price correlations, to
identify market patterns and trends which may be based on investor sentiment rather than the
fundamentals of the company. A substantial risk in relying upon technical analysis is that identifying
historical trends may not help to predict such trends in the future. Even if the trend will eventually
reoccur, there is no guarantee that WJ Wealth Management, LLC will be able to accurately predict
such a reoccurrence. Past performance does not guarantee future results and results will vary.
Please note, investing in securities involves risk of loss that clients should be prepared to bear. There
are different types of investments that involve varying degrees of risk, and it should not be assumed
that future performance of any specific investment or investment strategy will be profitable or equal
any specific performance level(s). Past performance is not indicative of future results.
The Firms’ methods of analysis and investment strategies do not represent any significant or unusual
risks however all strategies have inherent risks and performance limitations such as:
•
• Market Risk – The risk that the value of securities may go up or down, sometimes rapidly or
unpredictably due to factors affecting securities markets generally or particular industries.
Interest Rate Risk – The risk that fixed income securities will decline in value because of an
increase in interest rates; a bond or a fixed income fund with a longer duration will be more
sensitive to changes in interest rates than a bond or bond fund with a shorter duration.
• Credit Risk – The risk that an investor could lose money if the issuer or guarantor of a fixed
income security is unable or unwilling to meet its financial obligations.
Disciplinary Information
Registered Investment Advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of any advisory firm or the integrity of a
firm’s management.
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Any such disciplinary information for the company and the company’s investment advisor
representatives would be provided herein and publicly accessible by selecting the Investment
Advisor Search option at http://www.adviserinfo.sec.gov.
There are no legal or disciplinary events to disclose involving WJ Wealth Management.
Other Financial Industry Activities and Affiliations
Investment Advisor Representatives may also be registered representatives of LPL Financial, an
unaffiliated SEC registered and FINRA/SIPC member broker-dealer. Clients may choose to engage a
registered investment advisor in their capacity as a registered representative of the unaffiliated LPL
Financial broker-dealer, to implement investment recommendations on a commission basis.
Investment advisor representatives of WJ Wealth Management are also dually registered with LPL
Financial, an SEC registered investment adviser. This dual registration does not represent a conflict of
interest as similar services for identical fees are charged. LPL Financial serves as the custodian for
both advisers.
Representatives of our firm are insurance agents/brokers. They may offer insurance products and
receive customary fees as a result of insurance sales. A conflict of interest may arise as these
insurance sales may create an incentive to recommend products based on the compensation
adviser and/or our supervised persons may earn and may not necessarily be in the best interests of
the client. Such potential conflicts of interest are subject to review by the Chief Compliance Officer
and subject to LPL Financial surveillance controls.
Neither WJ Wealth Management nor any of the management persons are registered or has a
registration pending to register as a futures commission merchant, commodity pool operator, a
commodity trading advisor, or an associated person of the foregoing entities.
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
WJ Wealth Management maintains a Code of Ethics, which serves to establish a standard of business
conduct for all employees that are based upon fundamental principles of openness, integrity,
honesty and trust.
The code of ethics includes guidelines regarding personal securities transactions of its employees and
investment advisor representatives. The code of ethics permits employees and investment advisor
representatives or related
persons to invest for their own personal accounts in the same or different securities that an investment
advisor representative may purchase for clients in program accounts. This presents a potential
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conflict of interest because trading by an employee or investment advisor representatives in a
personal securities account in the same or different security on or about the same time as trading by
a client could potentially disadvantage the client. WJ Wealth Management addressed this conflict
of interest by requiring in its Code of Ethics that employees and investment advisor representatives
report certain personal securities transactions and holdings to the Chief Compliance Officer for
review.
An investment advisor is considered a fiduciary. As a fiduciary, it is an investment adviser’s
responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest
of each of our clients at all times. We have a fiduciary duty to all clients. Our fiduciary duty is
considered the core underlying principle for our Code of Ethics which also includes Insider Trading
and Personal Securities Transactions Policies and Procedures. We require all of our supervised
persons to conduct business with the highest level of ethical standards and to comply with all federal
and state securities laws at all times. Upon employment or affiliation and at least annually thereafter,
all supervised persons will sign an acknowledgement that they have read, understand, and agree to
comply with our Code of Ethics. Our firm and supervised persons must conduct business in an honest,
ethical, and fair manner and avoid all circumstances that might negatively affect or appear to
affect our duty of complete loyalty to all clients. This disclosure is provided to give all clients a
summary of our Code of Ethics. However, if a client or a potential client wishes to review our Code of
Ethics in its entirety, a copy will be provided promptly upon request.
It is the expressed policy of our firm that no person employed by us may purchase or sell any security
prior to a transaction being implemented for an advisory account, thereby preventing an employee
from benefiting from transactions placed on behalf of advisory accounts.
Neither WJ Wealth Management, nor a related person, recommends to clients, or buys or sells for
client accounts
securities in which you or a related person has a material financial interest.
Brokerage Practices
WJ Wealth Management receives support services and/or products from LPL Financial, many of
which assist the WJ Wealth Management to better monitor and service program accounts
maintained at LPL Financial. These support services and/or products may be received without cost,
at a discount, and/or at a negotiated rate, and may include the following:
Investment related research
•
• Pricing information and market data
•
Software and other technology that provide access to client account data • Compliance
and/or practice management-related publications
• Consulting services
• Attendance at conferences, meetings, and other educational and/or social events
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• Marketing support
• Computer hardware and/or software
• Other products and services used by Advisor in furtherance of its investment advisory business
operations
These support services are provided to WJ Wealth Management based on the overall relationship
between WJ Wealth Management and LPL Financial. It is not the result of soft dollar arrangements or
any other express arrangement with LPL Financial that involves the execution of client transactions as
a condition to the receipt of services. WJ Wealth Management will continue to receive the services
regardless of the volume of client transactions executed with LPL Financial. Clients do not pay more
for services as a result of this arrangement.
There is no corresponding commitment made by WJ Wealth Management to LPL Financial or any
other entity to
invest any specific amount or percentage of client assets in any specific securities as a result of the
arrangement.
WJ Wealth Management has an arrangement with LPL Financial. LPL Financial offers to independent
investment advisors non-soft dollar services which include custody of securities, trade execution,
clearance and settlement of transactions. We receive some non-soft dollar benefits from LPL
Financial through our participation in the program.
LPL Financial may make certain research and brokerage services available at no additional cost to
our firm. These services may be directly from independent research companies, as selected by our
firm (within specific parameters). Research products and services provide by LPL Financial may
include research reports on recommendations or other information about, particular companies or
industries; economic surveys, data and analyses; financial publications; portfolio evaluation services;
financial database software and services; computerized news and pricing services, quotation
equipment for use in running software used in investment decision-making; and other products or
services that provide lawful and appropriate assistance by LPL Financial to our firm in the
performance of our investment decision-making responsibilities.
Although the non-soft dollar investment research products and services that may be obtained by our
firm will generally be used to service all of our clients, a brokerage commission paid by a specific
client may be used to pay for research that is not used in managing that specific client’s account.
As a result of receiving the services WJ Wealth Management may have an incentive to continue to
use or expand the use of LPL Financial services. Our firm examined this potential conflict of interest
when we chose to enter into the relationship with LPL and we have determined that the relationship is
in the best interest of our firm’s clients and satisfies our fiduciary obligations, including our duty to seek
best execution.
LPL Financial charges brokerage commissions and transactions fees for effecting certain securities
transactions (i.e., transaction fees are charged for certain no-load mutual funds, commissions are
charged for individual equity and debt securities transactions). LPL enables us to obtain many no-
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load mutual funds without transaction charges and other no-load funds at nominal transaction
charges. LPL Financial commission rates are generally discounted from customary retail commission
rates. However, the commission and transaction fees charged by LPL Financial may be higher or
lower than those charged by other custodians and broker-dealers.
Clients may pay a commission to LPL Financial that is higher than another qualified broker-dealer
might charge to affect the same transaction where we determine in good faith that the commission
is reasonable in relation to the value of the brokerage and research services received. In seeking
best execution, the determining factor is not the lowest possible cost, but whether the transactions
represent the qualitative execution, taking into consideration the full range of a broker-dealer’s
services, including the value of research provided, execution capability, commission rates, and
responsiveness. Accordingly, although we will seek competitive rates, to the benefit of all clients, we
may not necessarily obtain the lowest possible commission rates for specific client account
transactions.
Neither we nor any of our firm’s related persons have discretionary authority in making the
determination of the
brokers with whom orders for the purchase or sale of securities are placed for execution and the
commission rates at which such securities transactions are affected. We routinely recommend that
a client directs us to execute through a specified broker-dealer. Our firm recommends the use of LPL
Financial. Each client that chooses LPL Financial will be required to establish an account if not
already done. Please note that not all advisers have this requirement.
For customized advisory services, the Applicant and its related persons may aggregate transactions in
equity and fixed income securities for a client with other clients to improve the quality of execution.
When transactions are so aggregated, the actual prices applicable to the aggregated transactions
will be averaged, and the client account will
be deemed to have purchased or sold its proportionate share of the securities involved at the
average price obtained. The Applicant and its related persons may determine not to aggregate
transacts, for example, based on the size of the trades, number of client accounts timing of trades,
the liquidity of the securities and the discretionary or nondiscretionary nature of the trades. If the
Applicant or its related persons do not aggregate orders, some clients purchasing securities around
the same time may receive a less favorable price than other clients. This means that this practice of
not aggregating may cost clients more money.
Review of Accounts
For those clients to whom WJ Wealth Management provides investment supervisory services, account
reviews are conducted on an ongoing basis by Jeffry R. Jones, the Chief Compliance Officer. All
investment supervisory clients are advised that it remains their responsibility to advise WJ Wealth
Management of any changes in their investment objectives and/or financial situation. All clients (in
person or via telephone) are encouraged to review financial planning issues (to the extent
applicable), investment objectives and account performance with their investment advisor
representative on an annual basis.
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Jeffry R. Jones, the Chief Compliance Officer, may also conduct account reviews based on the
occurrence of a triggering event, such as a change in client investment objectives and/or financial
situation, market corrections and by client request. Clients are provided, at least quarterly, with
written transaction confirmation notices and regular written summary account statements directly
from the broker-dealer/custodian and/or program sponsor for the client accounts. WJ Wealth
Management may also provide a written periodic report summarizing account activity and
performance.
Client Referrals and Other Compensation
WJ Wealth Management receives an economic benefit from LPL Financial in reimbursement for
marketing related expenses. Please see detailed discussion of the categories of marketing related
expenses and potential conflicts of interest referenced in Brokerage Practices.
WJ Wealth Management and employees may receive additional compensation from product
sponsors. However, such compensation may not be tied to the sales of any products. Compensation
may include such items as gifts valued at less than $100 annually, an occasional dinner or ticket to a
sporting event, or reimbursement in connection with educational meetings with investment advisor
representative, client workshops or events, marketing events or advertising initiatives, including
services for identifying prospective clients. Product sponsors may also pay for, or reimburse WJ
Wealth Management for the costs associated with, education or training events that may be
attended by WJ Wealth Management employees and investment advisor representatives and for WJ
Wealth Management sponsored conferences and events.
• WJ Wealth Management does not have any agreements in place to pay solicitors a portion of
advisory fees.
• WJ Wealth Management does not directly or indirectly compensate any person who is not a
•
supervised person for client referrals.
There are no other economic benefits provided by someone who is not a client for providing
investment advice.
Custody
WJ Wealth Management does not have actual or constructive custody of client funds. LPL Financial
will serve as the custodian of client assets on behalf of the WJ Wealth Management. WJ Wealth
Management may also provide advisory services on assets held at different third-party custodians.
WJ Wealth Management urges you to carefully review the statements provided by the custodian and
compare such official custodial records to the account statements that may be provided by WJ
Wealth Management.
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LPL Financial as the custodian sends statements at least quarterly to clients showing all disbursements
in account
including the amount of the advisory fees paid to advisor, the value of client assets upon which
advisor’s fee was based, and the specific manner in which advisor’s fee was calculated. Clients
provide authorization to LPL financial permitting advisory fees to be deducted from client advisory
account. LPL Financial calculates the advisory fees and deducts them from client’s account every
quarter.
Investment Discretion
The client can determine to engage the WJ Wealth Management to provide investment advisory
services on a discretionary basis. Prior to the WJ Wealth Management assuming discretionary
authority over a client’s account, the client shall be required to execute an Investment Advisory
Agreement, naming WJ Wealth Management as the client’s attorney and agent in fact, granting the
WJ Wealth Management full authority to buy, sell, or otherwise effect investment transactions
involving the assets in the client’s name found in the discretionary account. Clients who engage WJ
Wealth Management on a discretionary basis may, at any time, impose restrictions, in writing, on the
WJ Wealth Management discretionary authority (i.e. limit the types/amounts of particular securities
purchased for their account, exclude the ability to purchase securities with an inverse relationship to
the market, limit or proscribe the use of margin, etc.).
Voting Client Securities
WJ Wealth Management does not vote client proxies but third-party money managers selected or
recommended by our firm may vote proxies for clients. Clients will otherwise receive their proxies or
other solicitations directly from their custodian. Clients may contact WJ Wealth Management at (602)
942-1321 to discuss any questions they may have with a particular solicitation.
Financial Information
There are no financial conditions that are reasonable or likely to impair the firm’s ability to meet
contractual commitments to clients. At no time has WJ Wealth Management been the subject of a
bankruptcy petition.
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