Overview
- Headquarters
- Evanston, IL
- Total Firm Assets
- $472 million
- Average High-Net-Worth Client Portfolio Size
- $2.2 million
- Minimum Account Size
- $2,000,000
Fee Structure
Primary Fee Schedule (ZIMMERMAN WEALTH MANAGMENT, LLC 2026 UPDATED BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $5,000,000 | 1.00% |
| $5,000,001 | $10,000,000 | 0.75% |
| $10,000,001 | $15,000,000 | 0.65% |
| $15,000,001 | $25,000,000 | 0.50% |
| $25,000,001 | and above | Negotiable |
Minimum Annual Fee: $20,000
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | Below minimum client size | |
| $5 million | $50,000 | 1.00% |
| $10 million | $87,500 | 0.88% |
| $50 million | Negotiable | Negotiable |
| $100 million | Negotiable | Negotiable |
Clients
- High-Net-Worth Share of Firm Assets
- 99.97%
- Number of High-Net-Worth Clients
- 216
- Total Client Accounts
- 225
- Discretionary Accounts
- 213
- Non-Discretionary Accounts
- 12
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Regulatory Filings
- SEC CRD Number
- 127526
Primary Brochure: ZIMMERMAN WEALTH MANAGMENT, LLC 2026 UPDATED BROCHURE (2026-08-27)
View Document Text
Part 2A of Form ADV: Firm Brochure
Zimmerman Wealth Management, LLC
500 Davis Street, Suite 1005, Evanston, IL 60201
Telephone: 847-556-3200
Email: thz@zimmermanwealth.com
Web Address: www.zimmermanwealth.com
August 27, 2026
This brochure provides information about the qualifications and business practices of
Zimmerman Wealth Management, LLC. If you have any questions about the contents of this
thz@zimmermanwealth.com. The
brochure, please contact us at 847-556-3200 or
information in this brochure has not been approved or verified by the United States Securities
and Exchange Commission or by any state securities authority.
Zimmerman Wealth Management, LLC is a registered investment adviser. Registration of an
investment adviser does not imply any level of skill or training.
Additional information about Zimmerman Wealth Management, LLC is available on the SEC’s
website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number,
known as a CRD number. Our firm’s CRD number is 127526.
Item 2 Material Changes
Since the last annual update filed with the Securities and Exchange Commission on March
24, 2025, there have been no material changes.
-2-
Item 3 Table of Contents
Page
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 .................................................................... 7
ITEM 6
BASED FEES AND SIDE-BY-SIDE
PERFORMANCE
MANAGEMENT ........................................................................................ 10
-
ITEM 7
TYPES OF CLIENTS ................................................................................ 11
ITEM 8
METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK
OF LOSS .................................................................................................. 12
ITEM 9
DISCIPLINARY INFORMATION ................................................................ 15
ITEM 10
OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS .......... 16
ITEM 11
CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT
TRANSACTIONS AND PERSONAL TRADING ......................................... 17
ITEM 12
BROKERAGE PRACTICES ...................................................................... 19
ITEM 13
REVIEW OF ACCOUNTS ......................................................................... 23
ITEM 14
CLIENT REFERRALS AND OTHER COMPENSATION ............................ 24
ITEM 15
CUSTODY ................................................................................................ 25
ITEM 16
INVESTMENT DISCRETION .................................................................... 26
ITEM 17
VOTING CLIENT SECURITIES ................................................................. 27
ITEM 18
FINANCIAL INFORMATION ...................................................................... 28
-3-
Item 4 Advisory Business
Zimmerman Wealth Management, LLC (the “firm,” “we,” “us” or “our”) is an SEC-registered
investment adviser with its principal place of business located in Evanston, IL. Zimmerman
Wealth Management, LLC began conducting business in 2003. Thomas H. Zimmerman
(CFP®), Founder, Managing Member and Chief Compliance Officer, is the firm’s principal
shareholder and controls more than 25% of the firm.
Zimmerman Wealth Management, LLC prides itself on its personalized, objective and
responsive approach to helping investors better plot their financial futures. The firm is
standing by to design solid, personalized programs to help clients reach their life and financial
goals. Zimmerman Wealth Management, LLC offers the following advisory services to our
clients:
INVESTMENT SUPERVISORY SERVICES
INDIVIDUAL PORTFOLIO MANAGEMENT
Our firm provides continuous advice to a client regarding the investment of client funds based
on the individual needs of the client. Through personal discussions in which goals and
objectives based on a client’s particular circumstances are established, we develop a client’s
personal investment policy and create and manage a portfolio based on that policy. During
this process, we determine the client’s individual objectives, time horizons, risk tolerance, and
liquidity needs. As appropriate, we also review and discuss a client’s prior investment history,
as well as family composition and background.
We manage these advisory accounts on a discretionary basis. Account supervision is guided
by the client’s stated objectives (i.e., maximum capital appreciation, growth, income, or
growth and income), which may include certain tax considerations.
Clients may impose reasonable restrictions on investing in certain securities, types of
securities, or industry sectors. Any such restrictions will be set forth in writing in the client’s
Investment Policy Statement.
While our investment recommendations generally focus on portfolios of mutual funds,
exchange-traded funds (“ETFs”) and closed-end funds, our investment recommendations are
not limited to any specific product or service offered by a broker-dealer or insurance company
and will generally include advice regarding the following securities:
•
Exchange-listed securities
•
Securities traded over-the-counter
•
Foreign issuers
•
Commercial paper
•
Certificates of deposit
•
Municipal securities
•
Variable life insurance
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•
Variable annuities
•
Mutual fund shares
•
United States governmental securities
•
Interests in partnerships investing in real estate
Because some types of investments involve certain additional degrees of risk, they will only
be implemented/recommended when consistent with the client’s stated investment
objectives, tolerance for risk, liquidity and suitability.
FINANCIAL PLANNING AND PENSION CONSULTING
We also provide financial planning services to individuals and a small number of employee
benefit plans, mainly defined-contribution plans such as 401(k) plans, which generally
consists of providing advice to the plan or to individual plan participants.
For advice to plans, the firm generally assists the plan in the selection of investment options,
which typically consist of mutual funds offered to plan participants. The firm evaluates the
number of funds offered under the plan and recommends a menu of investment options. To
the extent the firm provides pension consulting services, such services are provided on a non-
discretionary basis.
For individuals, financial planning is a comprehensive evaluation of a client’s current and
future financial state by using currently known variables to predict future cash flows, asset
values and withdrawal plans. Through the financial planning process, all questions,
information and analysis are considered as they impact and are impacted by the entire
financial and life situation of the client. Financial planning clients receive a written report which
provides the client with a detailed financial plan designed to assist the client in achieving his
or her financial goals and objectives.
In general, the financial plan can address any or all of the following areas:
• PERSONAL: We review family records, budgeting, personal liability, estate information
and financial goals.
• TAX & CASH FLOW: We analyze the client’s income tax and spending and planning for
past, current and future years; then illustrate the impact of various investments on the
client’s current income tax and future tax liability.
•
INVESTMENTS: We analyze investment alternatives and their effect on the client’s
portfolio.
•
INSURANCE: We review existing policies to ensure proper coverage for life, health,
disability, long-term care, liability, home and automobile.
• RETIREMENT: We analyze current strategies and investment plans to help the client
achieve his or her retirement goals.
• DEATH & DISABILITY: We review the client’s cash needs at death, income needs of
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surviving dependents, estate planning and disability income.
• ESTATE: We assist the client in assessing and developing long-term strategies, which
may incorporate, as appropriate, living trusts, wills, estate tax considerations, powers of
attorney, asset protection plans, Medicaid, assisted living and long-term care services and
other considerations under applicable law.
We gather required information through in-depth personal interviews. Information gathered
includes the client’s current financial status, tax status, future goals, returns objectives and
attitudes towards risk. We carefully review documents supplied by the client, including a
questionnaire completed by the client, and prepare a written report. Should the client choose
to implement the recommendations contained in the plan, we suggest the client work closely
with his or her attorney, accountant, insurance agent, and/or stockbroker. Implementation of
financial plan recommendations is entirely at the client’s discretion.
We also provide general non-securities advice on topics that may include tax and budgetary
planning, charitable giving, estate planning and business planning, including succession
planning.
For clients receiving financial planning services only, our investment recommendations are
not limited to any specific product or service offered by a broker-dealer or insurance company
and will generally include advice in securities similar to those noted above for individual
portfolio management. For clients receiving financial planning only, with no investment advice,
we will recommend investments by broad asset allocation categories, as opposed to individual
funds or securities. Typically the financial plan is presented to the client within six months of
the contract date, provided that all information needed to prepare the financial plan has been
promptly provided.
AMOUNT OF MANAGED ASSETS
As of December 31, 2025, the firm managed on a discretionary basis approximately
$468,109,019 in regulatory assets under management. As of the same date, the firm
managed non-discretionary assets of $4,326,204.
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Item 5 Fees and Compensation
INVESTMENT SUPERVISORY SERVICES:
INDIVIDUAL PORTFOLIO MANAGEMENT FEES
The annualized fee for investment supervisory services is typically charged as a percentage
of assets under management, according to the following schedule:
Assets Under Management
Annual Fee
First $5,000,000
1.00%
Next $5,000,000
0.75%
Next $5,000,000
0.65%
Next $10,000,000
0.50%
Over $25,000,000
Quoted on a customized basis
All client assets are held by a qualified custodian which may be a broker-dealer. The specific
manner in which fees are charged to a client is established in the applicable client’s advisory
agreement. The firm may invoice a client for its fees, but more typically fees are debited
directly from the client’s account by the custodian in accordance with the client authorization.
Fees are typically billed quarterly, in advance, at the beginning of each calendar quarter
based upon the value (market value or fair market value in the absence of market value), of
the client’s account at the end of the previous quarter. In the event a client makes an additional
contribution to an account after the inception of a quarter, the fee payable with respect to such
additional contribution will generally be prorated based on the number of days remaining in the
quarter and added to the fee payable for the quarter immediately following. In the event a
client makes a partial withdrawal from an account after the inception of a quarter, any prepaid
fees will generally be credited towards the fee payable with respect to the quarter immediately
following, prorated based on the number of days remaining in the quarter.
A client’s custodian will generally determine the market value of the investments in a client’s
portfolio. If the custodian is unable to determine a market value for an investment, the firm
7
will provide a fair valuation. To the extent the firm provides a fair value for an investment, the
firm has a conflict of interest as its fee will be based on such valuation.
Limited Negotiability of Advisory Fees: Although Zimmerman Wealth Management, LLC
has established the aforementioned fee schedule(s), we retain the discretion to negotiate
alternative fees, including fixed or hourly fees, on a client-by-client basis. Client facts,
circumstances and needs are considered in determining the fee schedule. These include the
complexity of the client, assets to be placed under management, anticipated future additional
assets, related accounts, portfolio style, account composition and reports, among other
factors. The specific annual fee schedule is identified in the contract between the adviser and
each client.
We may group certain related client accounts for the purposes of achieving the minimum
account size requirements and determining the annualized fee.
Discounts not generally available to our advisory clients may be offered to family members
and friends of employees of our firm.
FINANCIAL PLANNING FEES
Zimmerman Wealth Management, LLC’s financial planning fee arrangement is determined
based on the nature of the services being provided and the complexity of the client’s
circumstances. All fees are agreed upon prior to entering into a contract with any client.
Our financial planning fees may be charged as a percentage of client assets, at the rates set
forth in the individual portfolio management fee chart above, or on a fixed fee and/or an hourly
basis. Fees charged on an hourly basis generally range from $95 to $600 per hour. Although
the length of time it will take to provide a financial plan will depend on each client’s personal
situation, we will provide an estimate for the total hours at the start of the advisory relationship.
Our fixed fee arrangements typically range from $8,500 to $20,000, depending on the
complexity of the case and the specific fee arrangement reached with the client.
We may request a retainer upon completion of our initial fact-finding session with the client;
however, advance payment will never be incurred for work that will not be completed within
six months. Any remaining balances are due upon completion of the plan.
Typically, a client will be billed quarterly in advance based on our total estimated financial
planning fees. In no case is a client billed for services more than six months in advance.
GENERAL INFORMATION
Fees in General: The firm and its employees are not compensated for the sale of securities
or other investment products recommended to clients. Clients have the option to purchase
the securities and investment products the firm recommends through other brokers or agents
8
that are not affiliated with the firm and should note that advisory services similar to those
provided by the firm may be available from other registered (or unregistered) investment
advisers for similar or lower fees.
Minimum Investments: For individual portfolio management, there is an initial minimum
investment of $2,000,000 for the opening of an advisory account and a minimum annual fee
of $20,000. However, the firm may waive these requirements in its sole discretion. For clients
seeking only financial planning advice, the firm does not impose a minimum net worth
requirement or a minimum fee. There are no minimums relating to any pension consulting
client.
Termination of the Advisory Relationship: A client agreement typically may be canceled
at any time, by either party, for any reason upon receipt of 30 days’ written notice. As
disclosed above, certain fees are paid in advance of services being provided. Upon
termination of any account, any prepaid, unearned fees will be promptly refunded. In
calculating a client’s reimbursement of unearned fees, we will prorate the reimbursement
according to the number of days remaining in the billing period. Clients can contact the firm
with any questions regarding refunded fees.
Mutual Fund and Other Investment Vehicle Fees: All fees paid to Zimmerman Wealth
Management, LLC for investment advisory services are separate and distinct from the fees
and expenses charged by mutual funds, closed-end funds and/or ETFs to their shareholders
as well as for any other investment vehicle in which a client invests. These fees and expenses
are described in each fund’s prospectus or offering materials. These fees will generally
include a management fee, other fund expenses, and a possible distribution fee. If the fund
also imposes sales charges, a client may pay an initial or deferred sales charge. A client could
invest in a mutual fund or other investment vehicle directly, without our services. In that case,
the client would not receive the services provided by our firm which are designed, among
other things, to assist the client in determining which mutual fund or other investment vehicle
is most appropriate to each client’s financial condition and objectives. Accordingly, the client
should review both the fees charged by the funds and our fees to fully understand the total
amount of fees to be paid by the client so that the client can evaluate the advisory services
being provided.
Many investment vehicles offer multiple share classes available for investment based upon
certain eligibility and/or purchase requirements. For instance, in addition to more commonly
offered retail mutual fund share classes, some funds offer institutional share classes or other
share classes specifically designed for purchase by an account for a fee-based investment
advisory program. Such share classes may have varying operating expenses and may have
minimum purchase or other criteria that limit availability. The firm has implemented practices
designed to assure that each client is invested in the share class with the lowest expense
ratio for which the client is eligible to invest and that is determined appropriate by the firm, in
its sole discretion, after consideration of certain relevant factors, including account size and
anticipated holding period.
Additional Fees and Expenses: In addition to our advisory fees, clients are also responsible
for the fees and expenses charged by custodians, broker-dealers and other third parties,
including, but not limited to, any transaction charges imposed by a broker-dealer with which
the firm effects transactions for the client’s account(s), wire transfer and electronic funds fees
9
and markups and/or markdowns (bonds). Please refer to the “Brokerage Practices” section
(Item 12) of this Form ADV for additional information.
Grandfathering of Minimum Account Requirements: Advisory clients are subject to
Zimmerman Wealth Management, LLC’s minimum account requirements and advisory fees
when they become clients. The firm’s minimum account requirements and advisory fees have
evolved over time, therefore, our firm’s minimum account requirements and advisory fees
differ among clients.
Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of
fees more than six months in advance of services rendered.
10
Item 6 Performance-Based Fees and Side-By-Side Management
Zimmerman Wealth Management, LLC does not charge performance-based fees.
11
Item 7 Types of Clients
Zimmerman Wealth Management, LLC typically provides advisory services to the following
types of clients:
•
Individuals (other than high net worth individuals)
•
High Net Worth Individuals
•
Trusts and Estates
•
Pension and profit sharing plans (other than plan participants)
•
Charitable organizations
•
Corporations or other entities not listed above
The conditions for managing an account are described above in Item 5, “Fees and
Compensation.” As noted above, account size and fee minimums may be waived in the sole
discretion of the firm.
12
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
METHODS OF ANALYSIS
We use the following methods of analysis in formulating our investment advice and/or
managing client assets:
Charting. In this type of technical analysis, we review charts of market and security activity
in an attempt to identify when the market is moving up or down and to predict how long the
trend may last and when that trend might reverse.
Fundamental Analysis. We attempt to measure the intrinsic value of a security by looking
at economic and financial factors (including the overall economy, industry conditions, and the
financial condition and management of the company itself) to determine if the company is
underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time
to sell).
Fundamental analysis does not attempt to anticipate market movements. This presents a
potential risk, as the price of a security can move up or down along with the overall market
regardless of the economic and financial factors considered in evaluating the stock.
Technical Analysis. We analyze past market movements and apply that analysis to the
present in an attempt to recognize recurring patterns of investor behavior and potentially
predict future price movement.
Technical analysis does not consider the underlying financial condition of a company. This
presents a risk in that a poorly-managed or financially unsound company may underperform
regardless of market movement.
Cyclical Analysis. In this type of technical analysis, we measure the movements of a
particular stock against the overall market in an attempt to predict the price movement of the
security.
Risks for all forms of analysis. Our securities analysis methods rely on the assumption that
the companies whose securities we purchase and sell, the rating agencies that review these
securities, and other publicly-available sources of information about these securities, are
providing accurate and unbiased data. While we are alert to indications that data may be
incorrect, there is always a risk that our analysis may be compromised by inaccurate or
misleading information.
INVESTMENT STRATEGIES
Zimmerman Wealth Management, LLC generally employs a conservative long-term asset
allocation investment strategy based on the needs of the client and consistent with the client’s
investment objectives, risk tolerance, and time horizons, among other considerations. While
the firm generally utilizes mutual funds, ETFs and closed-end funds for portfolio allocation,
the firm may recommend other types of securities to clients.
Long-term purchases. We typically purchase securities with the idea of holding them in the
client’s account for a year or longer. Typically we employ this strategy when:
•
we believe the securities to be currently undervalued, and/or
13
•
we want exposure to a particular asset class over time, regardless of the current
projection for this class.
•
A risk in a long-term purchase strategy is that by holding the security for this length
of time, we may not take advantage of short-term gains that could be profitable to a
client. Moreover, if our predictions are incorrect, a security may decline sharply in
value before we make the decision to sell.
Short-term purchases. When utilizing this strategy, we purchase securities with the idea of
selling them within a relatively short time (typically a year or less). We do this in an attempt to
take advantage of conditions that we believe will soon result in a price swing in the securities
we purchase.
A short-term purchase strategy poses risks should the anticipated price swing not materialize;
we are then left with the option of having a long-term investment in a security that was
designed to be a short-term purchase, or potentially taking a loss.
In addition, this strategy involves more frequent trading than does a longer-term strategy, and
will result in increased brokerage and other transaction-related costs, as well as less favorable
tax treatment of short-term capital gains.
RISK OF LOSS
Securities investments are not guaranteed and you may lose some or all of your investment.
We ask that you work with us to help us understand your tolerance for risk.
Below are the material risks associated with investing in the different types of securities held
by our clients.
Mutual Funds/ETFs
Investments in mutual funds or ETFs are subject to all of the risks of the asset classes in
which such funds invest and may include all of the risks described below. Clients will be
subject to the risks disclosed in each fund’s prospectus. Additionally, mutual funds and ETFs
are subject to fees and costs that can lower investment returns.
ETFs may include leveraged or inverse ETFs, which are ETFs that seek to achieve a daily
return that is a multiple or an inverse multiple of the daily return of a securities index. An
important characteristic of these ETFs is that they seek to achieve their stated objectives on
a daily basis, and their performance over longer periods of time can differ significantly from
the multiple or inverse multiple of the index performance over those longer periods of time.
ETFs are subject to tracking errors. A tracking error is the difference between the performance
of a fund and the performance of its underlying index. This is more evident in leveraged ETFs
and can subject the ETF to significant outperformance or significant underperformance in
comparison to the index or basket of assets it is intended to track.
Fixed Income Securities
The primary risks of investing in fixed income securities are credit risk and interest rate risk.
Credit risk is the risk that the issuer of the security will default on principal or interest
payments. Higher yielding bonds present a higher degree of credit risk. Interest rate risk is
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the risk that bond prices fall when interest rates rise. Duration is a measure of interest rate
risk. Generally, bonds with a higher duration are subject to greater price movements than
bonds with lower duration. To the extent that the firm invests globally, fixed income securities
also will be subject to additional risks of foreign securities described below.
Equities
The primary risks of equity securities are market risk and issuer risk. Market risk is the risk
that the markets in which the firm invests may go up or down. Issuer risk is the risk associated
with a particular issuer and its business such as regulatory, legal or economic risks associated
with its product lines or the industry in which it operates.
Foreign Securities Risk
Portfolios that invest in foreign securities are also subject to the risks of fluctuation in currency
values, differences in accounting and economic and political instability.
15
Item 9 Disciplinary Information
We are required to disclose any legal or disciplinary events that are material to a client’s or
prospective client’s evaluation of our advisory business or the integrity of our management.
Our firm and our management personnel have no disciplinary events to disclose.
16
Item 10
Other Financial Industry Activities and Affiliations
Our firm and our related persons are not engaged in other financial industry activities and
have no other industry affiliations.
17
Item 11
Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Our firm has adopted a Code of Ethics which sets forth high ethical standards of business
conduct that we require of our employees, including compliance with applicable federal
securities laws.
Zimmerman Wealth Management, LLC and our personnel owe a duty of loyalty, fairness and
good faith towards our clients, and have an obligation to adhere not only to the specific
provisions of the Code of Ethics but to the general principles that guide the Code of Ethics.
Our Code of Ethics includes policies and procedures for the review of quarterly securities
transactions reports as well as initial and annual securities holdings reports that must be
submitted by the firm’s access persons. Among other things, our Code of Ethics requires the
prior approval of any acquisition of securities in a limited offering (e.g., private placement) or
an initial public offering. Our Code of Ethics also provides for oversight, enforcement and
recordkeeping provisions.
Zimmerman Wealth Management, LLC’s Code of Ethics further includes the firm’s policy
prohibiting the use of material non-public information. While we do not believe that we have
any particular access to non-public information, all employees are reminded that such
information may not be used in a personal or professional capacity.
Our Code of Ethics is designed to assure that the personal securities transactions, activities
and interests of our employees will not interfere with (i) making decisions in the best interest
of advisory clients and (ii) implementing such decisions while, at the same time, allowing
employees to invest for their own accounts.
Our firm and/or individuals associated with our firm may buy or sell for their personal accounts
securities identical to or different from those recommended to our clients.
With certain limited exclusions for and money market funds, among others (i.e., non-
reportable securities), it is the express policy of our firm that no person employed by us may
purchase or sell any security prior to a transaction(s) being implemented for an advisory
account, thereby preventing such employee(s) from benefiting from transactions placed on
behalf of advisory accounts.
We may aggregate our employee trades with client transactions from time to time. In these
cases, our employees or their related households may participate, as long as their
participation does not have a negative impact on our clients.
As these situations can represent actual or potential conflicts of interest to our clients, we
have established the following policies and procedures for implementing our firm’s Code of
Ethics, to ensure our firm complies with its regulatory obligations and provides our clients and
potential clients with full and fair disclosure of such conflicts of interest:
1.
No principal or employee of our firm may put his or her own interest or the firm’s
interest above the interest of an advisory client.
2.
3.
No principal or employee of our firm may buy or sell securities for their personal
portfolio(s) where their decision is a result of information received as a result of his or
her employment unless the information is also available to the investing public.
We maintain a list of all reportable securities holdings for our firm and anyone
18
4.
5.
6.
7.
8.
9.
associated with this advisory practice that has access to advisory recommendations
(“access person”). These holdings are reviewed on a regular basis by our firm’s Chief
Compliance Officer or his/her designee.
When an access person is aware that the firm is purchasing/selling or considering for
purchase/sale any security on behalf of a client, the access person may not directly or
indirectly effect a transaction in such security until the transaction is completed for all
clients or until a decision has been made to not purchase/sell the security on behalf of
a client.
Access persons must receive prior approval for any transactions involving an IPO or
private placement investment.
We have established procedures for the maintenance of all required books and
records.
Clients can decline to implement any advice rendered, except in situations where our
firm is granted discretionary authority.
All of our principals and employees must act in accordance with all applicable federal
and state regulations governing registered investment advisory practices.
We require delivery and acknowledgement of the Code of Ethics by each supervised
person of our firm.
10. We have established policies requiring the reporting of Code of Ethics violations to the
11.
firm’s principal.
Any individual who violates any of the above restrictions may be subject to termination.
A copy of our Code of Ethics is available to our advisory clients and prospective clients. You
may request a copy by email sent to thz@zimmermanwealth.com, or by calling us at 847-
556-3200.
19
Item 12
Brokerage Practices
Zimmerman Wealth Management, LLC generally requires discretionary clients to provide us
with written authority to determine the broker-dealer to be used to effect transactions for the
client. Clients are responsible for the transaction-related charges imposed by a broker-dealer
with which the firm effects transactions for the client’s account.
Clients must include any limitations on this discretionary authority in a written authority
statement. Clients may change/amend these limitations as required. Such amendments must
be provided to us in writing.
Unless directed otherwise by a client, the firm generally directs clients to the institutional
platform services of National Financial Services LLC and Fidelity Brokerage Services LLC
(collectively, and together with all affiliates, “Fidelity”). The institutional platform services
include brokerage, custody, consolidated statements and other services to firm clients and
the firm. Although we recommend that clients establish accounts at Fidelity, it is the client’s
decision to custody assets with Fidelity. Zimmerman Wealth Management, LLC is
independently operated and owned and is not affiliated with Fidelity.
Zimmerman Wealth Management, LLC has an arrangement with Fidelity through which
Fidelity provides advisory clients of Zimmerman Wealth Management, LLC with “institutional
platform services.” The institutional platform services include, among others, brokerage,
custody, consolidated statements and other related services. As part of Fidelity’s institutional
platform services, Zimmerman Wealth Management, LLC receives access to information,
software and technology that assists it in managing and administering clients’ accounts
including software and other technology that:
1.
provides access to client account data (such as trade confirmations and
account statements);
2.
facilitates trade execution and allocates aggregated trade orders for multiple
client accounts;
3.
provides research, pricing and other market data;
4.
facilitates payment of fees from its clients’ accounts; and
5.
assists with back-office functions, recordkeeping and client reporting.
Fidelity also offers other services intended to help Zimmerman Wealth Management, LLC
manage and further develop the firm’s advisory practice but may not directly benefit our
clients. Such services include, but are not limited to, performance reporting, financial
planning, contact management systems, third party research, publications, access to
educational conferences, roundtables and webinars, practice management resources,
access to consultants and other third party service providers who provide a wide array of
business related services and technology with whom Zimmerman Wealth Management, LLC
may contract directly.
Fidelity generally does not charge clients of participating advisers separately for custody
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services but is compensated by account holders through commissions and other transaction-
related or asset-based fees for securities trades that are executed through Fidelity or that
settle into Fidelity accounts (i.e., transaction fees are charged for certain no-load mutual
funds, commissions are charged for individual equity and debt securities transactions).
Fidelity provides access to many no-load mutual funds without transaction charges and other
no-load funds at nominal transaction charges.
The firm invests principally in mutual funds and exchange-traded funds on behalf of client
accounts. The firm recommends Fidelity to clients based on a number of factors including,
but not limited to: (1) breadth of investment products made available to clients, particularly
mutual funds and exchange-traded funds, (2) custodial platform provided to clients for which
separate fees are not charged by Fidelity, (3) reputation, financial strength and stability, (4)
prior service to firm clients, and (5) other products and services that benefit the firm, as
discussed above. Fidelity charges a transaction fee for transactions placed with other brokers
(“trade away fee”), which is in addition to the fee charged by the executing broker. Because
of the trade away fee and our emphasis on mutual funds and exchange-traded funds, we
expect to execute all or substantially all transactions through Fidelity and we generally do not
negotiate individual trades among brokers. The firm may not obtain execution as favorable as
the execution obtained by using broker-dealers other than Fidelity. To the extent that we
execute individual equities and bond transactions for clients, we will periodically compare the
prices obtained through the Fidelity, as applicable, with prices available through other brokers
or execution venues for reasonableness, taking into account any applicable trade away fee.
BROKERAGE FOR CLIENT REFERRALS
While broker-dealers that we select to execute transactions may from time to time refer clients
to the firm, Zimmerman Wealth Management, LLC does not make commitments to any broker
or dealer to compensate that broker or dealer through brokerage or dealer transactions for
client referrals; however, a potential conflict of interest may arise between the client’s interest
in obtaining the lowest commission cost and Zimmerman Wealth Management, LLC’s interest
in receiving future referrals.
SOFT DOLLARS
While it is not the firm’s current practice, the firm may in the future determine whether to effect
brokerage transactions of a client through broker-dealers who provide the firm with “brokerage
or research services” as that term is used in Section 28(e)(3) of the Securities Exchange Act
of 1934. Those services, if provided, could benefit all of the firm’s clients, and not only those
having brokerage transactions. In the event that the firm in the future should elect to do so,
the firm will determine in good faith that the amount of the commission mark-up/mark-down
paid is reasonable in relation to the value of the products and brokerage and research
services received from such broker-dealer, viewed in terms of either that particular transaction
or the firm’s overall responsibilities to all of its clients.
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TRADE AGGREGATION
We often aggregate orders for the purchase or sale of securities with all or most clients, to obtain
favorable execution, lower commission rates, and/or more favorable average prices. When we
aggregate orders, participating clients will receive an average share price, and transaction costs
will generally be shared on a pro-rata basis or another fair and equitable basis as defined in our
trading policies.
We do not receive any additional compensation or preferential treatment from our vendors as a
result of aggregating trades. If an aggregated order is filled in its entirety, it is allocated to
participating accounts as specified. If an order is filled partially, we allocate the executed portions
pro-rata or on another basis designed to prevent any client from being favored over another.
However, partial fills may be allocated differently if necessary to avoid unworkable share
quantities, provided that the reallocation treats all accounts fairly over time. Trades for our firm
employees, related entities or people may be aggregated with client transactions only if clients
are not disadvantaged.
If we choose not to aggregate a transaction because of an impracticality, some clients may pay
higher transaction costs or receive less favorable execution prices than would have been the
case if the orders were combined. We randomize those account assignments, using our trading
software, as adapted, to treat all accounts fairly over time.
For these and many other reasons, with our expanding use of ETF’s, we aggregate most client
trades.
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DIRECTED BROKERAGE
A Client may direct Zimmerman Wealth Management, LLC to execute transactions for the
client through a specific broker-dealer. If a client directs its brokerage to a specific broker-
dealer, the firm may be unable to obtain the lowest commission cost.
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Item 13
Review of Accounts
INVESTMENT SUPERVISORY SERVICES
INDIVIDUAL PORTFOLIO MANAGEMENT
REVIEWS: While the underlying securities within Individual Portfolio Management services
accounts are continually monitored, these accounts are reviewed at least quarterly. Accounts
are reviewed in the context of each client’s stated investment objectives and guidelines. More
frequent reviews may be triggered by material changes in variables such as the client’s
individual circumstances, or the market, political or economic environment.
REPORTS: In addition to the monthly statements and confirmations of transactions that
clients receive from their broker-dealer/custodian, we provide written quarterly reports
summarizing account performance, balances, fees paid and holdings.
FINANCIAL PLANNING AND PENSION CONSULTING SERVICES
REVIEWS: Reviews for Financial Planning Clients may occur at different stages depending
on the nature and terms of the specific engagement and client circumstances. We attempt to
update and review plans every 12 to 36 months. For clients that are not interested in these
updates or are non-responsive to our attempts to gather the appropriate information to
complete the updates, these services are not considered ongoing.
Reviews for Pension Consulting clients, to the extent ongoing, typically occur annually.
REPORTS:
Financial Planning clients will receive a completed financial plan.
Pension Consulting clients will receive a written report of the investment recommendations
for the plan.
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Item 14
Client Referrals and Other Compensation
Currently, it is Zimmerman Wealth Management, LLC’s policy not to engage solicitors or to
pay related or non-related persons for referring potential clients to our firm. In the past, one
non-related person provided one referral and is paid a fee on an ongoing basis for that client.
No new relationships are planned to be initiated using this arrangement.
Upon request for a service provider referral by a client, such as for attorneys or accountants,
the firm may provide a list of service providers. The firm is not directly compensated for
providing such referrals. From time to time, service providers may refer clients to the firm.
Neither the firm nor the applicable client pays any fee in connection with such referral.
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Item 15
Custody
The firm is deemed to have custody of client accounts where the firm has authority to instruct
the custodian of the client account to deduct for the firm’s advisory fees directly from the client
account. As part of this billing process, the client’s custodian is advised of the amount of the
fee to be deducted from that client’s account. On at least a quarterly basis, the custodian is
required to send to the client a statement showing all transactions within the account during
the reporting period.
Because the custodian does not calculate the amount of the fee to be deducted, it is important
for clients to carefully review their custodial statements to verify the accuracy of the
calculation, among other things. Clients should contact us directly if they believe that there
may be an error in their statement.
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Item 16
Investment Discretion
Clients may hire us to provide discretionary asset management services, in which case we
place trades in a client’s account without contacting the client prior to each trade to obtain the
client’s permission.
Our discretionary authority includes the ability to do the following without contacting the client:
•
determine the security to buy or sell; and/or
•
determine the amount of the security to buy or sell
Clients give us discretionary authority when they sign a discretionary agreement with our firm,
and may limit this authority by giving us written instructions. Clients may also change/amend
such limitations by once again providing us with written instructions.
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Item 17
Voting Client Securities
We vote proxies for all client accounts; however, clients always have the right to vote proxies
themselves. Clients can exercise this right by instructing us in writing to not vote proxies in
their account.
We will vote proxies in the best interests of our clients and in accordance with our established
policies and procedures. Our firm will retain all proxy voting books and records for the
requisite period of time, including a copy of each proxy statement received, a record of each
vote cast, a copy of any document created by us that was material to making a decision how
to vote proxies, and a copy of each written client request for information on how the adviser
voted proxies. If our firm has a conflict of interest in voting a particular action, we will notify
the client of the conflict and retain an independent third party to cast a vote.
We will neither advise nor act on behalf of the client in legal proceedings involving companies
whose securities are held in the client’s account(s), including, but not limited to, the filing of
“Proofs of Claim” in class action settlements. If desired, clients may direct us to transmit
copies of class action notices to the client or a third party. Upon such direction, we will make
commercially reasonable efforts to forward such notices in a timely manner.
With respect to ERISA accounts, we will vote proxies unless the plan documents specifically
reserve the plan sponsor’s right to vote proxies.
Clients can instruct us to vote proxies according to particular criteria (for example, to always
vote with management, or to vote for or against a proposal to allow a so-called “poison pill”
defense against a possible takeover). These requests must be made in writing. Clients can
also instruct us on how to cast their vote in a particular proxy contest by contacting us at
thz@zimmermanwealth.com or by telephone at 847-556-3200.
Clients may obtain a copy of our complete proxy voting policies and procedures by contacting
us at thz@zimmermanwealth.com or by telephone at 847-556-3200. Clients may request, in
writing, information on how proxies for his/her shares were voted. If any client requests a
copy of our complete proxy policies and procedures or how we voted proxies for his or her
account(s), we will promptly provide such information to the client.
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Item 18
Financial Information
Under no circumstances do we require or solicit payment of fees more than six months in
advance of services rendered. Therefore, we are not required to include a financial statement.
As an advisory firm that maintains discretionary authority for client accounts, we are also
required to disclose any financial condition that is reasonably likely to impair our ability to
meet our contractual obligations. Zimmerman Wealth Management, LLC has no additional
financial circumstances to report.
Zimmerman Wealth Management, LLC has not been the subject of a bankruptcy petition at
any time during the past ten years.
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