Disclosure
Landmark Wealth Management Group is a dba of LWMG, LLC (“Landmark” or the “Firm”). The Firm is an SEC registered investment adviser. Registration as an investment adviser does not imply a certain level of skill or training. The publication of Landmark’s web site on the Internet should not be construed by any consumer or prospective client as the Firm’s solicitation or attempt to effect transactions in securities or the rendering of personalized investment advice over the internet. A copy of Landmark’s current written disclosure statement as set forth on Form ADV, discussing the Firm’s business operations, services, and fees is available from the Firm upon written request. Landmark does not make any representations as to the accuracy, timeliness, suitability, or completeness of any information prepared by any unaffiliated third party, whether linked to or incorporated herein. All such information is provided solely for convenience purposes only and all users thereof should be guided accordingly.
The information contained herein is based upon certain assumptions, theories, and principles that do not completely or accurately reflect your specific circumstances. Landmark makes no representation as to whether investment in any security or strategy mentioned herein was profitable or would have been profitable for any person in the past. Different types of investments involve varying degrees of risk. Therefore, it should not be assumed that future performance of any specific investment or investment strategy will be profitable. Should there be an forward-looking statements that indicate future possibilities, there is no guarantee that any views and opinions expressed herein will come to pass. Due to known and unknown risks, other uncertainties, and factors, actual results may differ materially. Past performance is no guarantee of future results.
ACCESS TO THIS WEB SITE IS PROVIDED FOR INFORMATIONAL PURPOSES ONLY AND WITHOUT ANY WARRANTIES, EXPRESSED OR IMPLIED, REGARDING THE ACCURACY, COMPLETENESS, TIMELINESS, OR RESULTS OBTAINED FROM ANY INFORMATION POSTED ON THIS WEB SITE OR ANY THIRD-PARTY WEB SITE LINKED TO THIS WEB SITE.
FACTS WHAT DOES Landmark Wealth Management Group DO WITH YOUR FINANCIAL INFORMATION? Why? Financial companies choose how they share your personal information. Federal law
gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Pleaseread this notice carefully to understand what we do. What? The types of personal information we collect and share depends on the product or service you have with us. This information can include:
▪ Social Security number and income
▪ Account balances and assets
▪ Transaction history
How? All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Landmark Wealth Management Group, LLC chooses to share; and whether you can limit this sharing.Reasons we can share your personal information Does Landmark Wealth Management Group share? Can you limit this sharing? For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal
investigations, or report to credit bureaus Yes No For our marketing purposes – to offer our products and services to you Yes No For joint marketing with other financial companies No Not Applicable
For our affiliates’ everyday business purposes information about your transactions and experiences No Not Applicable For our affiliates’ everyday business purposes information about your creditworthiness No Not Applicable For our affiliates to market to you No Not Applicable For nonaffiliates to market to you No Not Applicable Questions? Call (800) 251-9932 or go to www.landmarkwealth.com Privacy Policy Notice Who we are Who is providing this notice? Landmark Wealth Management Group What we do How does Landmark Wealth Management Group, LLC protect my personal information? To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and building. How does Landmark Wealth Management Group, LLC collect my personal information?
We collect your personal information, for example, when
you:
▪ Open an account
▪ Deposit money
▪ Seek advice about your investments
▪ Enter into an investment advisory contract
▪ Tell us about your investment or retirement portfolio or earnings We also collect your personal information from other companies. Definitions Affiliates Companies related by common ownership and control. They can be financial and nonfinancial companies. We do not share with our affiliates. Nonaffiliates Companies not related by common ownership and control. They can be financial or nonfinancial companies. We do not share with nonaffiliates so that they can
market to you. Joint marketing A formal agreement between nonaffiliated financial companies that together market financial products or
service to you. We do not jointly market.
We are registered with the U.S. Securities and Exchange Commission as an investment adviser. Brokerage and investment advisory services fees differ and it is important for you to understand the differences. Free and simple tools are available to research firms and financial professionals at http://investor.gov/crs, which also provides educational materials about broker-dealers, investment advisers and investing. What investment services and advice can you provide me? Our firm offers investment advisory services, which are fully described in our Form ADV Part 2A (“Disclosure
Brochure”). Our services include financial planning, consulting, and investment management services. As part of our standard services, we monitor investments that we manage on a continuous and ongoing basis. Financial planning and investment consulting recommendations are not actively monitored. There are no material limitations to our monitoring. We accept discretionary and/or non-discretionary authority to implement the recommended transactions in client accounts. The level of discretion is determined in our agreement and there are no material limitations on the
authority. For non-discretionary services, you make the ultimate decision regarding the purchase or sale of investments. We do not offer advice only with respect to proprietary products. We offer advice on various mutual funds and exchange-traded funds (“ETFs”). The Firm also allocates assets among independent investment managers and individual debt and equity securities when it deems it appropriate. Our services are subject to a minimum account value. We impose a minimum portfolio of $100,000. We may, in its sole discretion, accept clients with smaller portfolios based upon certain criteria, including anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing client, account
retention, and pro bono activities. Additional information about our services can be found in Items 4, 5 and 7 of our Disclosure and available to all clients or by going here: https://adviserinfo.sec.gov/
Let’s discuss…
• Given my financial situation, should I choose an investment advisory service? Why or why not?”
• How will you choose investments to recommend to me?
• What is your relevant experience, including your licenses, education and other qualifications?
What do these qualifications mean? What fees will I pay? We offer our services on a fee basis. We charge a fixed for financial planning and investment consulting and a fee based upon assets under management for investment management and wealth management services. For project-based services one half of the fees are due upon engaging us while the remainder is due upon delivery of the services. For ongoing services, the annual fee is prorated and charged monthly. In addition to the advisory fees paid to us, you also incur certain charges imposed by other third parties, such as broker-dealers, custodians, etc. These additional charges include securities brokerage commissions, transaction fees, custodial fees, fees attributable to alternative assets, reporting charges, fees charged by the Independent Managers, margin and other borrowing costs, charges imposed directly by a mutual fund or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, odd-lot differentials,
transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. The more assets there are in your advisory accounts, the more you will pay in fees, so the firm may therefore have an incentive to encourage you to increase the assets in your account or manage them in a way where we charge higher fees. You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time. Please make sure you understand what fees and costs
you are paying. Additional information about our fees can be found in Item 5 of our Disclosure Brochure and available to all clients or by going here: https://adviserinfo.sec.gov/ Let’s discuss… Help me understand how these fees and costs might affect my investments. If I give you $10,000 to invest, how much will go to fees and costs, and how much will be invested for me? Relationship Summary
Page | 2 August 1, 2022 What are your legal obligations to me when acting as my investment adviser? How else does your firm make money and what conflicts of interest do you have?
When we act as your investment adviser, we have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. You should understand and ask us about these conflicts because they can affect the investment advice we provide you. Here are some examples to help you understand what this means.
• Third-Party Payments: Our supervised persons or affiliates can recommend securities and/or insurance investments to you for compensation in their individual capacities. This results in an incentive for our supervised persons or affiliates to recommend those investments and potentially more frequent purchases.
• Support from Custodian: We receive administrative support, computer software, related systems support, as well as other third party support from the custodian that we recommend. This results in an incentive to recommend that custodian because we do not have to produce or pay for the products or services provided. Let’s discuss… How might your conflicts of interest affect me, and how will you address them? Additional information about our conflicts of interest can be found throughout our Disclosure Brochure and available to all clients or by going here: https://adviserinfo.sec.gov/ How do your financial professionals make money? Our financial professionals are compensated based on the following factors and conflicts of interest: The amount of client assets they service. This results in an incentive to favor clients with more assets being serviced. Product sales commissions in their individual capacity. Sales commissions, while not earned as financial professionals of our firm, result in an incentive to sell certain investments and more frequently. Additional information about our financial professionals can be found on their respective Form ADV Part 2 Brochure Supplements that you will be provided. Do you or your financial professionals have legal or disciplinary history? No, neither we nor our financial professionals have a legal or disciplinary history. You can visit http://investor.gov/crs
for a free and simple search tool to research us and our financial professionals. Let’s discuss… As a financial professional, do you have any disciplinary history? For what type of conduct?
You can find additional information about our services in our Disclosure Brochure. To request a copy of this Relationship Summary and any of our other disclosure documents referred to in this document, please call us at (800) 251-9932. Let’s discuss… Who is my primary contact person? Is he or she a representative of an investment adviser or a broker-dealer? Who can I talk to if I have concerns about how this person is treating me?
Item 4. Advisory Business LWMG offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to LWMG rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with LWMG setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”).
LWMG filed for registration as an investment adviser in May 2022 and is owned by Todd Gillingham, Gary Tangwall, Thomas Selbo, Jennifer Beyl-Lee, Chad Broberg, and Bjorn Nesvold. As of December 31, 2022, LWMG had $717,201,934 in assets under management, of which $686,020,799 was managed on a discretionary basis and $31,181,134 was managed on a non-discretionary basis. While this brochure generally describes the business of LWMG, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying
a similar status or performing similar functions), employees or other persons who provide investment advice on LWMG’s behalf and are subject to the Firm’s supervision or control. Financial Planning and Consulting Services LWMG offers clients a broad range of financial planning and consulting services, which include any or all of the following functions: Business Planning Cash Flow Forecasting Trust and Estate Planning Financial Reporting Investment Consulting Insurance Planning Retirement Planning Risk Management Charitable Giving Distribution Planning Tax Planning Education Planning While each of these services is available on a stand-alone basis, certain of them can also be rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (described in more detail below). In performing these services, LWMG is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. LWMG recommends certain clients engage the Firm for additional related services, its Supervised Persons in their individual capacities as insurance agents or registered representatives of a broker-dealer and/or other professionals to implement its recommendations. Clients are advised that a Disclosure Brochure Page | 5 conflict of interest exists for the Firm to recommend that clients engage LWMG or its affiliates to provide (or continue to provide) additional services for compensation, including investment management services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by LWMG under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising LWMG’s recommendations and/or services. Investment and Wealth Management Services LWMG manages client investment portfolios on a discretionary or non-discretionary basis. In addition, LWMG provides certain clients with wealth management services which include a broad range of financial
planning and consulting services as well as discretionary and/or non-discretionary management of investment portfolios. LWMG primarily allocates client assets primarily among various mutual funds and exchange-traded funds (“ETFs”). The Firm also allocates assets among independent investment managers (“Independent Managers”), and individual debt and equity securities when it deems it appropriate. Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios, but clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically agreed upon. Clients can engage LWMG to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, LWMG directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. LWMG tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. LWMG consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify LWMG if there are changes in their financial situation or if they wish to place
any limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if LWMG determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts.
Disclosure Brochure Page | 6 Use of Independent Managers As mentioned above, LWMG selects certain Independent Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager are set forth in a separate written agreement with the designated Independent Manager. That agreement can
be between the Firm and the Independent Manager (often called a subadvisor) or the client and the Independent Manager (sometimes called a separate account manager). In addition to this brochure, clients will typically also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. LWMG evaluates a variety of information about Independent Managers, which includes the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers’ investment strategies, past performance and risk results in relation to its clients’ individual portfolio allocations and risk exposure. LWMG also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors.
LWMG continues to provide services relative to the discretionary or non-discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. LWMG seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. Note for IRA and Retirement Plan Clients: When LWMG provides investment advice to you regarding your retirement plan account or individual retirement account, LWMG is a fiduciary within the meaning of title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable,which are laws governing retirement accounts. The way LWMG makes money creates some conflicts with your interests, so RWS operates under a special rule that requires LWMG to act in your best interest and not put LWMG’s interest ahead of yours.
Item 5. Fees and Compensation LWMG offers services on a fee basis, which includes planning, as well as fees based upon assets under management. Additionally, certain of the Firm’s Supervised Persons, in their individual capacities, offers securities brokerage services and/or insurance products under a separate commission-based arrangement. Disclosure Brochure Page | 7 Financial Planning and Consulting Fees LWMG charges a fixed fee for providing financial planning and consulting services. These fees range from $500 to $100,000+ per year, depending upon the scope and complexity of the services and the professional rendering the financial planning and/or the consulting services. The fee can be for a defined project, such as the delivery of a plan, or for ongoing services.
The terms and conditions of the financial planning and/or consulting engagement are set forth in the Advisory Agreement. For one-time services, LWMG requires the entirety of the fee payable upon execution of the Advisory Agreement but will not be charged six months or more in advance. The outstanding balance is due upon delivery of the financial plan or completion of the agreed upon services. Ongoing services can be prorated and charged monthly. Investment Management Fees LWMG offers investment management services for an annual fee based on the amount of assets under the
Firm’s management. This management fee varies in accordance with the following blended fee schedules:
PORTFOLIO VALUE FEE
Up to $100,000 1.55%
$100,000 - $250,000 1.40%
$250,000 - $500,000 1.30%
$500,000 - $1,000,000 1.15%
$1,000,000 - $3,000,000 0.95%
$3,000,000 - $5,000,000 0.85%
$5,000,000 - $7,500,000 0.80%
$7,500,000 - $10,000,000 0.75%
$10,000,000 - $15,000,000 0.70%
$15,000,000 - $20,000,000 0.65%
Above $20,000,000 0.60%
The annual fee is prorated and charged monthly, in advance, based upon the market value of the assets being managed by LWMG on the last day of the previous month as determined by a party independent from the Firm (including the client’s custodian or another third-party). The Firm combines households to determine breakpoints. Households are determined in the Firm’s discretion, but general include spouses and children living in the same household. Disclosure Brochure Page | 8 The Firm includes cash in a clients account in determining the valuation for billing purposes. The Firm
may, in its sole discretion, not include cash in determining the fee, especially where a client has a high percentage of cash for reasons other than the Firm's investment management decision.
If assets are deposited into or withdrawn from an account after the inception of a billing period, the fee payable with respect to such assets is not adjusted to reflect the interim change in portfolio value. For the initial period of an engagement, the fee is calculated on a pro rata basis. In the event the advisory agreement is terminated, the fee for the final billing period is prorated through the effective date of the termination and the outstanding or unearned portion of the fee is charged or refunded to the client, as appropriate. Additionally, for asset management services the Firm provides with respect to certain client holdings (e.g., held-away assets, accommodation accounts, alternative investments, etc.), LWMG can negotiate a fee rate that differs from the range set forth above. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage LWMG for additional services for compensation, including rolling over retirement accounts or moving other assets to the Firm’s management. Clients retain absolute discretion over all decisions regarding engaging the Firm and are under no obligation to act upon any of the
recommendations. Fee Discretion LWMG may, in its sole discretion, negotiate to charge a lesser fee based upon certain criteria, such as anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing/legacy client relationship, account retention, pro bono activities, or competitive purposes.
Additional Fees and Expenses In addition to the advisory fees paid to LWMG, clients also incur certain charges imposed by other third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions (collectively “Financial Institutions”). These additional charges include securities brokerage commissions, transaction fees, custodial fees, fees attributable to alternative assets, margin and other borrowing costs, charges imposed directly by a mutual fund or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. The Firm’s brokerage practices are described at length in Item 12, below. Disclosure Brochure Page | 9 Direct Fee Debit Clients provide LWMG and/or certain Independent Managers with the authority to directly debit their accounts for payment of the investment advisory fees. The Financial Institutions that act as the qualified custodian for client accounts, from which the Firm retains the authority to directly deduct fees, have agreed to send statements to clients not less than quarterly detailing all account transactions, including any amounts paid to LWMG. Account Additions and Withdrawals Clients can make additions to and withdrawals from their account at any time, subject to LWMG’s right to terminate an account. Additions can be in cash or securities provided that the Firm reserves the right to liquidate any transferred securities or declines to accept particular securities into a client’s account. Clients can withdraw account assets on notice to LWMG, subject to the usual and customary securities settlement
procedures. However, the Firm designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. LWMG may consult with its clients about the options and implications of transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, short-term redemption fees, fees assessed at the mutual fund level (e.g., contingent deferred sales charges) and/or tax ramifications. Commissions and Sales Charges for Recommendations of Securities
Clients can engage certain persons associated with LWMG (but not the Firm directly) to render securities brokerage services under a separate commission-based arrangement. Clients are under no obligation to engage such persons and may choose brokers or agents not affiliated with LWMG. Under this arrangement, the Firm’s Supervised Persons, in their individual capacities as registered
representatives of Purshe Kaplan Sterling Investments, Inc. (“PKS”), can provide securities brokerage services and implement securities transactions under a separate commission based arrangement. Supervised Persons are entitled to a portion of the brokerage commissions paid to PKS, as well as a share of any ongoing distribution or service (trail) fees from the sale of mutual funds. LWMG can also recommend no- load or load-waived funds, where no sales charges are assessed, but where the Supervised Person receives other forms of compensation. Prior to effecting any transactions, clients are required to enter into a separate account agreement with PKS. A conflict of interest exists to the extent that a Supervised Person of LWMG recommends the purchase or
sale of securities through a brokerage relationship where that Supervised Persons receives commissions or other additional compensation as a result of that recommendation (the “Brokerage Relationship”). Because the Supervised Persons receive compensation in connection with the sale of securities in the Brokerage Relationship, a conflict of interest exists as such Supervised Persons, have an incentive to recommend more Disclosure Brochure Page | 10 expensive securities or services to clients where such Supervised Persons earn more compensation with respect to the sale of such securities through the Brokerage Relationship rather than through an advisory relationship with the Firm. The Firm has procedures in place to ensure that any recommendations made by
such Supervised Persons to engage in the Brokerage Relationship are in the best interest of that client. Clients should understand that the investments made in the Brokerage Relationship are not receiving advisory services from the Firm. Therefore, the Firm does not have a fiduciary duty over the Brokerage Relationship recommendations. Item 6. Performance-Based Fees and Side-by-Side Management LWMG does not provide any services for a performance-based fee (i.e., a fee based on a share of capital gains or capital appreciation of a client’s assets). Item 7. Types of Clients
LWMG offers services to individuals, charitable organizations, trusts and estates, corporations and other business entities, pension and profit-sharing plans.Minimum Account Value As a condition for starting and maintaining an investment management relationship, LWMG imposes a minimum portfolio value of $100,000. LWMG may, in its sole discretion, accept clients with smaller
portfolios based upon certain criteria, including anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, preexisting client, account retention, and pro bono activities. LWMG only accepts clients with less than the minimum portfolio size if the Firm determines the smaller portfolio size will not cause a substantial increase of investment risk beyond the client’s identified risk tolerance. LWMG may, in its sole discretion, aggregate the portfolios of family members to meet the minimum portfolio size.
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategies LWMG builds portfolios that attempt to maximize returns for an expected level of risk. Absolute risk is measured in many ways at the Firm, but the primary measures are standard deviation of returns and Disclosure Brochure Page | 11 maximum drawdown of a portfolio. LWMG uses historical results, sourced through recognized commercial sources, to inform its views of asset class and portfolio risks. The Firm also analyzes asset class expected returns, risks and correlations, for major asset classes, published by various sources. This combination of historical and expected returns and risks help the Firm build appropriate portfolios for clients. A second level of risk is risk relative to a market or asset class benchmark. Portfolios have assigned benchmarks reflecting the target mix of asset classes. Performance of actual portfolios can be evaluated compared to common investment indices matching the target asset allocations. At a fund or manager level, investment performance is analyzed compared to the most appropriate strategy benchmark. LWMG has processes in place to manage portfolio risks. The Firm systematically monitors portfolio risks and report results to its internal investment committee for review on a monthly basis. LWMG has additional policies in place to help manage risks through, asset class targets and limits, position limits, diversification objectives and frequent rebalancing. The Firm uses both quantitative and qualitative inputs to help
determine if portfolio risk aligns with client objectives. In order to find investment opportunities that provide potential for attractive returns, LWMG researches and monitors the global economic environment and economic trends, asset class returns for the US and major international markets, as well as, returns of various styles and sectors within asset classes. The Firm’s investment research is often split into research supporting asset allocation decisions and research related to manager selection decisions. Asset allocation decisions are often the most impactful. The Firm’s processes help it determine the percentage of a portfolio allocated to different investment styles, market sectors or geographies. Manager decisions focus on the selection of products that help with the implementation of portfolio objectives or strategies. Manager decisions include the selection of the investment type, such as ETFs, mutual funds or individual securities; management style tradeoffs between active and passive approaches; and other criteria specific to the investment management firm. Firm specific decisions often result from a focus on the people, the investment process and past performance. Although
it can vary by the risk tolerance of the portfolio, most of the Firm’s investments are added as strategic longterm positions, because LWMG believes that markets are more predictable over longer periods of time. However, there may be times where portfolios may be tilted to underweight or overweight particular asset classes, styles or sectors based on a shorter-term tactical view. Risk of Loss The following list of risk factors does not purport to be a complete enumeration or explanation of the risks involved with respect to the Firm’s investment management activities. Clients should consult with their
legal, tax, and other advisors before engaging the Firm to provide investment management services on their behalf. Disclosure Brochure Page | 12 Market Risks Investing involves risk, including the potential loss of principal, and all investors should be guided accordingly. The profitability of a significant portion of LWMG’s recommendations and/or investment
decisions may depend to a great extent upon correctly assessing the future course of price movements of stocks, bonds and other asset classes. In addition, investments may be adversely affected by financial markets and economic conditions throughout the world. There can be no assurance that LWMG will be able to predict these price movements accurately or capitalize on any such assumptions.
Volatility Risks The prices and values of investments can be highly volatile, and are influenced by, among other things, interest rates, general economic conditions, the condition of the financial markets, the financial condition of the issuers of such assets, changing supply and demand relationships, and programs and policies of governments. Cash Management Risks The Firm may invest some of a client’s assets temporarily in money market funds or other similar types of investments, during which time an advisory account may be prevented from achieving its investment objective. Equity-Related Securities and Instruments The Firm may take long positions in common stocks of U.S. and non-U.S. issuers traded on national securities exchanges and over-the-counter markets. The value of equity securities varies in response to many factors. These factors include, without limitation, factors specific to an issuer and factors specific to the industry in which the issuer participates. Individual companies may report poor results or be negatively affected by industry and/or economic trends and developments, and the stock prices of such companies may suffer a decline in response. In addition, equity securities are subject to stock risk, which is the risk that stock prices historically rise and fall in periodic cycles. U.S. and non-U.S. stock markets have experienced periods of substantial price volatility in the past and may do so again in the future. In addition, investments in small-capitalization, mid-capitalization and financially distressed companies may be subject to more abrupt or erratic price movements and may lack sufficient market liquidity, and these issuers often face greater business risks. Fixed Income Securities While the Firm emphasizes risk-averse management and capital preservation in its fixed-income bond portfolios, clients who invest in this product can lose money, including losing a portion of their original investment. The prices of the securities in our portfolios fluctuate. The Firm does not guarantee any particular level of performance. Below is a representative list of the types of risks clients should consider before investing in this product. Disclosure Brochure
Page | 13 Interest rate risk. Prices of bonds tend to move in the opposite direction to interest rate changes. Typically, a rise in interest rates will negatively affect bond prices. The longer the duration and
average maturity of a portfolio, the greater the likely reaction to interest rate moves. Credit (or default) risk. A bond’s price will generally fall if the issuer fails to make a scheduled interest or principal payment, if the credit rating of the security is downgraded, or if the perceived creditworthiness of the issuer deteriorates. Liquidity risk. Sectors of the bond market can experience a sudden downturn in trading activity. When there is little or no trading activity in a security, it can be difficult to sell the security at or near its perceived value. In such a market, bond prices may fall. Call risk. Some bonds give the issuer the option to call or redeem the bond before the maturity date. If an issuer calls a bond when interest rates are declining, the proceeds may have to be reinvested at a lower yield. During periods of market illiquidity or rising rates, prices of callable securities may be subject to increased volatility. Prepayment risk. When interest rates fall, the principal of mortgage-backed securities may be
prepaid. These prepayments can reduce the portfolio’s yield because proceeds may have to be reinvested at a lower yield. Extension risk. When interest rates rise or there is a lack of refinancing opportunities, prepayments of mortgage-backed securities or callable bonds may be less than expected. This would lengthen the portfolio’s duration and average maturity and increase its sensitivity to rising rates and its potential for price declines. Mutual Funds and ETFs An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETFshareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains,
as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for a profit that cannot be offset by a corresponding loss. Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees, redemption fees). The per share NAV of a mutual fund is calculated at the end of each business day, although the actual
NAV fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a mutual fund’s shares may differ from the NAV during periods of market volatility, which may, among other factors, lead to the mutual fund’s shares trading at a premium or discount to actual NAV. Disclosure Brochure Page | 14 Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily for index-based ETFs and potentially more frequently for actively managed ETFs. However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 20,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may have no way to dispose of such shares. Finally, some mutual funds and ETFs may have lock-up periods that restrict an investor from selling their position for a period of time. Other mutual funds and ETFs could also have early redemption fees that are taken if the investor sells their position before a certain amount of time.
Use of Independent Managers As stated above, LWMG selects certain Independent Managers to manage a portion of its clients’ assets. In these situations, LWMG continues to conduct ongoing due diligence of such managers, but such recommendations rely to a great extent on the Independent Managers’ ability to successfully implement their investment strategies. In addition, LWMG does not have the ability to supervise the Independent Managers on a day-to-day basis. Tax Considerations The Firm’s strategies and investments may have unique and significant tax implications. However, unless
the Firm specifically agrees otherwise, and in writing, tax efficiency is not the primary consideration in the management of client assets. Regardless of a client’s account size or any other factors, the Firm strongly recommend that clients consult with a tax professional regarding the investing of their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Each client’s custodian will default to the First-In First-Out ("FIFO") accounting method for calculating the cost basis of investments. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If the client’s tax advisor believes another accounting method is more advantageous, the client should provide written notice to the Firm immediately and the Firm will alert the account custodian of the individually selected accounting method. Decisions about cost basis accounting methods will need to be made before trades settle, as the cost basis method cannot be changed after settlement. Interest Rate Risks Interest rates may fluctuate significantly, causing price volatility with respect to securities or instruments held by clients.Disclosure Brochure Page | 15 Item 9. Disciplinary Information LWMG has not been involved in any legal or disciplinary events that are material to a client’s evaluation of its advisory business or the integrity of its management.Item 10. Other Financial Industry Activities and Affiliations This item requires investment advisers to disclose certain financial industry activities and affiliations.
Registered Representatives of a Broker-Dealer Certain of the Firm’s Supervised Persons are registered representatives of PKS and provide clients with securities brokerage services under a separate commission-based arrangement. This arrangement is described at length in Item 5. Licensed Insurance Agency LWMG is a duly licensed insurance agency. Additionally, a number of the Firm’s Supervised Persons are licensed insurance agents and offer certain insurance products on a fully-disclosed commissionable basis. A conflict of interest exists to the extent that LWMG recommends the purchase of insurance products where its Supervised Persons are entitled to insurance commissions or other additional compensation. The Firm
has procedures in place whereby it seeks to ensure that all recommendations are made in its clients’ best interest regardless of any such affiliations. Item 11. Code of Ethics LWMG has adopted a code of ethics in compliance with applicable securities laws (“Code of Ethics”) that sets forth the standards of conduct expected of its Supervised Persons. LWMG’s Code of Ethics contains written policies reasonably designed to prevent certain unlawful practices such as the use of material nonpublic information by the Firm or any of its Supervised Persons and the trading by the same of securities
ahead of clients in order to take advantage of pending orders. The Code of Ethics also requires certain of LWMG’s personnel to report their personal securities holdings and transactions and obtain pre-approval of certain investments (e.g., initial public offerings, limited offerings). However, the Firm’s Supervised Persons are permitted to buy or sell securities that it also Disclosure Brochure
Page | 16 recommends to clients if done in a fair and equitable manner that is consistent with the Firm’s policies and procedures. This Code of Ethics has been established recognizing that some securities trade in sufficiently broad markets to permit transactions by certain personnel to be completed without any appreciable impact on the markets of such securities. Therefore, under limited circumstances, exceptions may be made to the policies stated below. When the Firm is engaging in or considering a transaction in any security on behalf of a client, no Supervised Person with access to this information may knowingly effect for themselves or for their immediate family (i.e., spouse, minor children and adults living in the same household) a transaction in that security unless: • the transaction has been completed; • the transaction for the Supervised Person is completed as part of a batch trade with clients; or • a decision has been made not to engage in the transaction for the client.
These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii) money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper, repurchase agreements and other high quality short-term debt instruments, including repurchase agreements; (iii) shares issued by money market funds; and iv) shares issued by other unaffiliated open-end mutual funds. Clients and prospective clients may contact LWMG to request a copy of its Code of Ethics by contacting the Firm at the phone number on the cover page of this brochure.
Item 12. Brokerage Practices Recommendation of Broker-Dealers for Client Transactions LWMG recommends that clients utilize the custody, brokerage and clearing services of National Financial
Services LLC and Fidelity Brokerage Services LLC (together with affiliates, “Fidelity”) for investment management accounts. The final decision to custody assets with Fidelity is at the discretion of the client, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA accountholder. LWMG is independently owned and operated and not affiliated with Fidelity. Fidelity provides LWMG with access to its institutional trading and custody services, which are typically not available to retail investors. Factors which LWMG considers in recommending Fidelity or any other broker-dealer to clients include their respective financial strength, reputation, execution, pricing, research and service. Fidelity enables the
Disclosure Brochure Page | 17 Firm to obtain many mutual funds without transaction charges and other securities at nominal transaction charges. The commissions and/or transaction fees charged by Fidelity may be higher or lower than those charged by other Financial Institutions. The commissions paid by LWMG’s clients to Fidelity comply with the Firm’s duty to obtain “best execution.” Clients may pay commissions that are higher than another qualified Financial Institution might charge to effect the same transaction where LWMG determines that the commissions are reasonable in
relation to the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best
qualitative execution, taking into consideration the full range of a Financial Institution’s services, including among others, the value of research provided, execution capability, commission rates and responsiveness. LWMG seeks competitive rates but may not necessarily obtain the lowest possible commission rates for client transactions. Consistent with obtaining best execution, brokerage transactions are directed to certain broker-dealers in return for investment research products and/or services which assist LWMG in its investment decisionmaking process. Such research will be used to service all of the Firm’s clients, but brokerage commissions paid by one client may be used to pay for research that is not used in managing that client’s portfolio. The receipt of investment research products and/or services as well as the allocation of the benefit of such investment research products and/or services poses a conflict of interest because LWMG does not have to
produce or pay for the products or services. LWMG periodically and systematically reviews its policies and procedures regarding its recommendation of Financial Institutions in light of its duty to obtain best execution. Software and Support Provided by Financial Institutions LWMG receives without cost from Fidelity administrative support, computer software, related systems
support, as well as other third party support as further described below (together "Support") which allow LWMG to better monitor client accounts maintained at Fidelity and otherwise conduct its business. LWMG receives the Support without cost because the Firm renders investment management services to clients that maintain assets at Fidelity. The Support is not provided in connection with securities transactions of clients (i.e., not “soft dollars”). The Support benefits LWMG, but not its clients directly. Clients should be aware that LWMG’s receipt of economic benefits such as the Support from a broker-dealer creates a conflict of interest since these benefits will influence the Firm’s choice of broker-dealer over another that does not furnish similar software, systems support or services. In fulfilling its duties to its clients, LWMG endeavors at all times to put the interests of its clients first and has determined that the recommendation of Fidelity is in the best interest of clients and satisfies the Firm's duty to seek best execution. Disclosure Brochure Page | 18 Specifically, LWMG receives the following benefits from Fidelity: i) receipt of duplicate client confirmations and bundled duplicate statements; ii) access to a trading desk that exclusively services its institutional traders; iii) access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts; and iv) access to an electronic communication network for client order entry and account information. Fidelity also makes available to the Firm, at no additional charge, certain research and brokerage services, including research services obtained by Fidelity directly from independent research companies, as selected by LWMG (within specified parameters). These research and brokerage services are used by the Firm to manage accounts for which it has investment discretion. LWMG also receives additional services from Fidelity. Without this arrangement, the Firm might be compelled to purchase the same or similar services at its own expense. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to them so long as a certain amount of the advisor’s clients’ assets are maintained in accounts at Fidelity. Fidelity’s services include brokerage services that are related to the execution of securities
transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For client accounts maintained in its custody, Fidelity generally does not charge separately for custody
services but is compensated by account holders through commissions or other transaction-related or assetbased fees for securities trades that are executed through Fidelity or that settle into Fidelity accounts. Fidelity also makes available to the Firm other products and services that benefit the Firm but may notbenefit its clients’ accounts. These benefits may include national, regional or Firm specific educational events organized and/or sponsored by Fidelity. Other potential benefits may include occasional business entertainment of personnel of LWMG by Fidelity personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist LWMG in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide research, pricing information and other market data, facilitate payment of the Firm's fees from its clients’ accounts, and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of the Firm’s accounts, including accounts not maintained at Fidelity. Fidelity also makes available to LWMG other services intended to help the Firm manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital Disclosure Brochure Page | 19 consultants, insurance and marketing. In addition, Fidelity may make available, arrange and/or pay vendors for these types of services rendered to the Firm by independent third parties. Fidelity may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third- party providing these services to the Firm. While, as a fiduciary, LWMG endeavors to act in its clients’ best interests, the Firm's recommendation that clients maintain their assets in accounts at Fidelity may be based in part on the benefits received and not solely on the nature, cost or quality of custody and brokerage services provided by Fidelity, which creates a potential conflict of interest. Brokerage for Client Referrals LWMG does not consider, in selecting or recommending broker-dealers, whether the Firm receives client referrals from the Financial Institutions or other third party.
Directed Brokerage The client may direct LWMG in writing to use a particular Financial Institution to execute some or all transactions for the client. In that case, the client will negotiate terms and arrangements for the account with that Financial Institution and the Firm will not seek better execution services or prices from other Financial Institutions or be able to “batch” client transactions for execution through other Financial Institutions with orders for other accounts managed by LWMG (as described above). As a result, the client may pay higher commissions or other transaction costs, greater spreads or may receive less favorable net prices, on transactions for the account than would otherwise be the case. Subject to its duty of best execution, LWMG may decline a client’s request to direct brokerage if, in the Firm’s sole discretion, such directed brokerage arrangements would result in additional operational difficulties or violate restrictions imposed by other broker-dealers (as further discussed below). Commissions or Sales Charges for Recommendations of Securities As discussed above, certain Supervised Persons in their respective individual capacities are registered
representatives of PKS. These Supervised Persons are subject to FINRA Rule 3280 which restricts registered representatives from conducting securities transactions away from their broker-dealer unless the registered representatives give prior notice of such transactions to PKS and, in most circumstances, PKS provides written consent. Therefore, clients are advised that certain Supervised Persons are restricted to conducting securities transactions through PKS if they have not secured written consent from PKS to execute securities transactions though a different broker-dealer. Absent such written consent or separation from PKS, these Supervised Persons are generally prohibited from executing securities transactions through any broker-dealer other than PKS under its internal supervisory policies. The Firm is cognizant of its duty to obtain best execution and has implemented policies and procedures reasonably designed in such pursuit.
Disclosure Brochure Page | 20 Trade Aggregation Transactions for each client will be effected independently, unless LWMG decides to purchase or sell thesame securities for several clients at approximately the same time. LWMG may (but is not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates or
to allocate equitably among the Firm’s clients differences in prices and commissions or other transaction costs that might not have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and allocated among LWMG’s clients pro rata to the purchase and sale orders placed for each client on any given day. To the extent that the Firm determines to aggregate client orders for the purchase or sale of securities, including securities in which LWMG’s Supervised Persons may invest, the Firm does so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the U.S. Securities and Exchange Commission. LWMG does not receive any additional compensation or remuneration as a result of the aggregation. In the event that the Firm determines that a prorated allocation is not appropriate under the particular circumstances, the allocation will be made based upon other relevant factors, which include: (i) when only a small percentage of the order is executed, shares may be allocated to the account with the smallest order or the smallest position or to an account that is out of line with respect to security or sector weightings relative to other portfolios, with similar mandates; (ii) allocations may be given to one account when one account has limitations in its investment guidelines which prohibit it from purchasing other securities which are expected to produce similar investment results and can be purchased by other accounts; (iii) if an account reaches an investment guideline limit and cannot participate in an allocation, shares may be reallocated to other accounts (this may be due to unforeseen changes in an account’s assets after an order is placed); (iv) with respect to sale allocations, allocations may be given to accounts low in cash; (v) in cases when a pro rata allocation of a potential execution would result in a de minimis allocation in one or more accounts, the
Firm may exclude the account(s) from the allocation; the transactions may be executed on a pro rata basis among the remaining accounts; or (vi) in cases where a small proportion of an order is executed in all accounts, shares may be allocated to one or more accounts on a random basis. Item 13. Review of Accounts Account Reviews LWMG monitors client portfolios on a continuous and ongoing basis and regular account reviews are conducted on at least an annual basis. Such reviews are conducted by the Firm’s Investment Committee. All investment advisory clients are encouraged to discuss their needs, goals and objectives with LWMG and to keep the Firm informed of any changes thereto. Disclosure Brochure Page | 21 Account Statements and Reports Clients are provided with transaction confirmation notices and regular summary account statements directly from the Financial Institutions where their assets are custodied. Clients should compare the account statements they receive from their custodian with any documents or reports they receive from LWMG or an outside service provider. Item 14. Client Referrals and Other Compensation Client Referrals LWMG seeks to enter into agreements with individuals and organizations, some of whom may be affiliated or unaffiliated with LWMG for the referral of clients to us. All such agreements will be in writing and comply with the applicable state and federal regulations. If a client is introduced to LWMG by a solicitor, LWMG will pay that solicitor a fee in accordance with the applicable federal and state securities law requirements.
While the specific terms of each agreement may differ, generally, the compensation will be based upon LWMG’s engagement of new clients and the retention of those clients and would be calculated using a varying percentage of the fees paid to LWMG by such clients until the account is closed by written authorization from the client. Any such fee shall be paid solely from LWMG’s fees, and shall not result in any additional charge to the client. Each prospective client who is referred to LWMG by a solicitor who is not affiliated with LWMG will receive a written disclosure document disclosing whether the solicitor is or is not a current client of LWMG the compensation that will be paid by us to the third party, and a description of any material conflicts of interest on the part of the solicitor in light of LWMG’s relationship with the solicitor. In any case, applicable state laws may require these persons to become licensed either as representatives of LWMG or as an independent investment adviser.
Other Compensation The Firm receives economic benefits from Fidelity. The benefits, conflicts of interest and how they are addressed are discussed above in response to Item 12. Item 15. Custody
LWMG is deemed to have custody of client funds and securities because the Firm is given the ability to debit client accounts for payment of the Firm’s fees. As such, client funds and securities are maintained at Disclosure Brochure Page | 22 one or more Financial Institutions that serve as the qualified custodian with respect to such assets. Such qualified custodians will send account statements to clients at least once per calendar quarter that typically detail any transactions in such account for the relevant period. In addition, as discussed in Item 13, LWMG will also send, or otherwise make available, periodic supplemental reports to clients. Clients should carefully review the statements sent directly by the Financial Institutions and compare them to those received from LWMG. Any other custody disclosures can be found in the Firm’s Form ADV Part 1. Item 16. Investment Discretion LWMG is given the authority to exercise discretion on behalf of clients. LWMG is considered to exercise
investment discretion over a client’s account if it can effect and/or direct transactions in client accounts without first seeking their consent. LWMG is given this authority through a power-of-attorney included in the agreement between LWMG and the client. Clients may request a limitation on this authority (such as certain securities not to be bought or sold). LWMG takes discretion over the following activities: • The securities to be purchased or sold; • The amount of securities to be purchased or sold; • When transactions are made; and • The Independent Managers to be hired or fired. Item 17. Voting Client Securities Declination of Proxy Voting Authority LWMG does not accept the authority to vote a client’s securities (i.e., proxies) on their behalf. Clients receive proxies directly from the Financial Institutions where their assets are custodied and may contact the Firm at the contact information on the cover of this brochure with questions about any such issuer solicitations. The Firm may engage a third party to vote client proxies in the future, in which case the Firm will provide clients with a description of the proxy voting policies and procedures of the Firm. Disclosure Brochure Page | 23 Item 18. Financial Information LWMG is not required to disclose any financial information listed in the instructions to Item 18 because: • The Firm does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance of services rendered; • The Firm does not have a financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients; and • The Firm has not been the subject of a bankruptcy petition at any time during the past ten years.