A. Dew Wealth Management (the “Registrant”) is a limited liability company formed on July
23, 1999 in the state of Arizona. The Registrant became registered as an Investment
Adviser Firm in November 1999. The Registrant is wholly owned by Dew Holdings, Inc.
B. As discussed below, the Registrant offers to its clients (individuals, high net worth
individuals, pension and profit-sharing plans, and charitable organizations, etc.) varying
levels of investment advisory services, in addition to financial planning and related
consulting services.
FAMILY OFFICE ASSESSMENT
Registrant’s Family Office Assessment is a multi-step processes designed to perform a
deep dive into a client’s current personal and/or professional wealth management situation,
in an effort to identify gaps and potential points of weakness and, ultimately, develop
recommendations for improvement. The Family Office Assessment may be performed as
a precursor to one or more of Registrant’s other advisory programs (described further
below) or may be purchased on a separate standalone basis.
The Family Office Assessment is designed to give clients a broad based review of their
current personal financial situation, in order to develop recommendations for closing the
wealth management gap. For clients who are business owners, the services rendered under
the Family Office Assessment may also be tailored to establish an approximate valuation
for the client’s business, identify key revenue drivers, and develop recommendations for
improving the value of the client’s business.
Registrant will first work with the client to gather relevant information about the client’s
wealth management situation from various sources, including the client, and the client’s
other engaged professionals, such as: CPA/Bookkeeper, estate attorney, personal insurance
agent, life/disability insurance agent, investment adviser, and/or banker. Once relevant data
has been collected, Registrant will coordinate for a one-hour discovery phone call, to cover
topics such as the client’s: values, goals, relationships, assets, advisors, and interests.
When the discovery call is complete, Registrant will take the collected information and use
it to review the client’s wealth management situation. Depending on the client’s
circumstances, this review will generally take approximately four weeks to complete and
can cover topics including: personal insurance, life insurance, disability insurance, estate
documents, asset protection plan, investments, and personal tax returns.
The Family Office Assessment process concludes with a one hour review call. In this call,
the Registrant will provide an approximate current business valuation and will advise the
client on potential recommendations intended to increase business revenues and,
ultimately, increase the valuation. For clients who are business owners, Registrant will
explain the identified gaps in the client’s wealth management situation and will advise the
client on potential recommendations for closing such wealth management gaps.
WEALTH BUILDER
The Registrant’s Wealth Builder service is a two-year program in which the client will be
expected to participate in a bi-monthly, learning management system-driven curriculum to
take point in the build out of their own Virtual Family Office.
Upon engagement for Wealth Builder services, clients will gain immediate access to the
following resources:
• Bi-monthly one on one calls with Registrant
• Access to The Entrepreneur’s Virtual Family Office ™ System
• Monthly Wealth Acceleration Group Calls
• The Entrepreneur’s Rolodex and Forum
• Access to a Personalized Online Net Worth Dashboard
In addition to the above, over the course of the two-year program, Wealth Builder clients
will also receive, to the extent applicable:
• Tax Planning Strategies and Projections
• Personal Liability and Income Insurance Review
• Business Liability and Income Insurance Review
• Estate Planning Review
• Billionaire Investment Allocation and Glidepath
• Third-Party Investment Management Review and In House Management
• Entity and Corporate Governance Review
WEALTH ACCELERATOR
In Wealth Accelerator engagements, Registrant will generally work alongside the client’s
other engaged professionals in an effort to coordinate all aspects of the client’s financial
profile. Registrant may be asked to evaluate the client’s other engaged professionals and,
if needed, find and recommend replacement professional service providers. Registrant, as
needed, may also be asked to identify experts for consultation in the event the client’s
current team of engaged professionals are unable to adequately address a client’s needs in
various niche disciplines.
In addition to the above, to the extent specifically requested by the client, the Wealth
Accelerator program can also provide:
• Access to The Entrepreneur’s Virtual Family Office ™ System
• Monthly Wealth Acceleration Group Calls
• The Entrepreneur’s Rolodex and Forum
• Tax Planning Strategies and Projections
• Personal Liability and Income Insurance Review
• Business Liability and Income Insurance Review
• Estate Planning Review
• Billionaire Investment Allocation and Glidepath
• Third-Party Investment Management Review and In House Management
• Entity and Corporate Governance Review
• Access to a Personalized Online Net Worth Dashboard
• Advanced Tax Planning and Projections
• Business Valuation and Enterprise Value Optimization
• Financial Statement Review and KPI Benchmarking
• Private Deal Reviews (2/quarter)
• Cash Flow Management
• Time/Energy Shield
• Advanced Entity Optimization and Corporate Governance
• Ad hoc meetings and consultations on an as-needed basis, with up to three days
lead time
VIRTUAL FAMILY OFFICE
The Virtual Family Office is generally designed for clients who run successful businesses,
generate a high level of cash flow, and have a need for advanced financial planning and
coordination with outside professionals. In such engagements, Registrant will generally
work alongside the client’s other engaged professionals in an effort to coordinate all aspects
of the client’s financial profile. Registrant may be asked to evaluate the client’s other
engaged professionals and, if needed, find and recommend replacement professional
service providers. Registrant, as needed, may also be asked to identify experts for
consultation in the event the client’s current team of engaged professionals are unable to
adequately address a client’s needs in various niche disciplines.
In addition to the above, to the extent specifically requested by the client, the Virtual
Family Office program can also provide:
• Access to The Entrepreneur’s Virtual Family Office ™ System
• Monthly Wealth Acceleration Group Calls
• The Entrepreneur’s Rolodex and Forum
• Tax Planning Strategies and Projections
• Personal Liability and Income Insurance Review
• Business Liability and Income Insurance Review
• Estate Planning Review
• Billionaire Investment Allocation and Glidepath
• 3rd Party Investment Management Review and In House Management
• Entity and Corporate Governance Review
• Access to a Personalized Online Net Worth Dashboard
• Advanced Tax Planning and Projections
• Business Valuation and Enterprise Value Optimization
• Financial Statement Review and KPI Benchmarking
• Private Deal Reviews (2/quarter)
• Cash Flow Management
• Time/Energy Shield
• Advanced Entity Optimization and Corporate Governance
• Family Office Subject Matter Expert Support
• Advanced Life Insurance and Liquidity Planning
• Domestic and Foreign Asset Protection Trusts
• Irrevocable Family Dynasty Trust Planning
• Advanced Charitable Designs
• Second Generation Education
• Advanced M&A Planning and Teambuilding
• Post-Exit Estate, Cash Flow and Investment Allocation Planning
• Proactive Deal Flow
• Access to The Inner Circle
• Ad hoc meetings and consultations on an as-needed basis, with up to three days
lead time
MAINTENANCE MODE
The Maintenance Mode service is designed primarily for clients who have established a
functional Virtual Family Office setup and who need ongoing assistance in coordinating
and administering their Virtual Family Office.
Upon engagement for Maintenance Mode services, clients will gain immediate access to
the following resources:
• Quarterly one on one calls with Registrant
• Access to The Entrepreneur’s Virtual Family Office ™ System
• Monthly Wealth Acceleration Group Calls
• The Entrepreneur’s Rolodex and Forum
• Access to a Personalized Online Net Worth Dashboard
In addition to the above, to the extent specifically requested by the client, the Maintenance
Mode program can also provide:
• Tax Planning Strategies and Projections
• Personal Liability and Income Insurance Review
• Business Liability and Income Insurance Review
• Estate Planning Review
• Billionaire Investment Allocation and Glidepath
• Third-Party Investment Management Review and In House Management
• Entity and Corporate Governance Review
INVESTMENT MANAGEMENT
Registrant’s various other service offerings may also be combined with Registrant’s
discretionary or non-discretionary investment management services, for an additional
asset-based fee.
FINANCIAL PLANNING AND CONSULTING (STAND-ALONE)
To the extent requested by a client, the Registrant may determine to provide financial
planning and/or consulting services (including investment and non-investment related
matters, including estate planning, insurance planning, etc.) either inclusive of the client’s
discretionary or non-discretionary investment management services or on a stand-alone
separate fee basis. For standalone engagements, Registrant’s planning and consulting fees
are negotiable, but generally range from $1,000 to $20,000 on a fixed fee basis, and from
$300 to $750 on an hourly rate basis, depending upon the level and scope of the service(s)
required and the professional(s) rendering the service(s). Prior to engaging the Registrant
to provide standalone planning or consulting services, clients are generally required to enter
into an agreement with Registrant setting forth the terms and conditions of the engagement
(including termination), describing the scope of the services to be provided, and the portion
of the fee that is due from the client prior to Registrant commencing services.
If requested by the client, Registrant may recommend the services of other professionals
for rendering additional services or implementing Registrant’s recommendations. The
client is under no obligation to engage the services of any such recommended professional.
The client retains absolute discretion over all such decisions and is free to accept or reject
any recommendation from the Registrant. If the client engages any such recommended
professional, and a dispute arises thereafter relative to such engagement, the client agrees
to seek recourse exclusively from and against the engaged professional. It remains the
client’s responsibility to promptly notify the Registrant if there is ever any change in
his/her/its financial situation or investment objectives for the purpose of
reviewing/evaluating/revising Registrant’s previous recommendations and/or services.
RETIREMENT CONSULTING
The Registrant also provides non-discretionary pension consulting services, pursuant to
which it assists sponsors of self-directed retirement plans with the selection and/or
monitoring of investment alternatives (generally open-end mutual funds) from which plan
participants shall choose in self-directing the investments for their individual plan
retirement accounts. In addition, to the extent requested by the plan sponsor, the Registrant
shall also provide participant education designed to assist participants in identifying the
appropriate investment strategy for their retirement plan accounts. The terms and
conditions of the engagement shall generally be set forth in a Retirement Plan Consulting
Agreement between the Registrant and the plan sponsor.
EDUCATIONAL WORKSHOPS AND SEMINARS
Registrant offers two-day workshops in which attendees can learn about financial and
investment concepts to help guide them in their financial journey. These workshops are not
tailored to any attendee’s circumstances and are not intended to constitute individualized
advice. Attendees who sign up for Registrant’s Wealth Builder service while attending a
Registrant-sponsored workshop will be eligible to receive a one month
Wealth Builder fee
waiver. Please see Item 5 below for additional information.
Registrant may also participate in educational seminars/workshops sponsored by third-
parties that focus on investment and non-investment matters. These seminars are limited in
nature and are not intended to provide the participants with personalized investment advice.
Registrant typically does not receive compensation in connection with its participation in
such seminars/workshops and fees paid to attend these third-party seminars/workshops are
generally retained by the program’s sponsor.
Program attendees are often invited to engage the program sponsor and/or one or more
workshop/seminar presenters for the provision of additional services. For example,
attendees may be invited to purchase a bundle of additional services, a portion of which
bundle includes services to be rendered by Registrant. Although Registrant’s services
would be included in this bundle, Registrant would generally not receive any portion of the
compensation paid to receive such bundled services.
MISCELLANEOUS
Limitations of Family Office Assessments, Financial Planning and Non-Investment
Consulting/Implementation Services. As indicated above, to the extent requested by the
client, Registrant may provide Family Office Assessments, financial planning, and related
consulting services regarding non-investment related matters, such as estate planning, tax
planning, insurance, etc. Registrant does not serve as a law firm or accounting firm, and
no portion of its services should be construed as legal or accounting services. Accordingly,
Registrant does not prepare estate planning documents or tax returns. To the extent
requested by a client, Registrant may recommend the services of other professionals for
implementation purposes (e.g., attorneys, accountants, insurance agents, etc.). The client is
under no obligation to engage the services of any such recommended professional. The
client retains absolute discretion over all such implementation decisions and is free to
accept or reject any recommendation from Registrant and/or its representatives. If the client
engages any recommended unaffiliated professional, and a dispute arises thereafter relative
to such engagement, the client agrees to seek recourse exclusively from and against the
engaged professional.
Independent Managers. Registrant may allocate a portion of a client’s investment assets
among unaffiliated independent investment managers (“Independent Manager(s)”) in
accordance with the client’s designated investment objective(s). In such situations, the
Independent Manager(s) will have day-to-day responsibility for the active discretionary
management of the allocated assets. Registrant will continue to render investment
supervisory services to the client relative to the ongoing monitoring and review of account
performance, asset allocation and client investment objectives. The factors Registrant
considers in recommending Independent Manager(s) include the client’s designated
investment objective(s), management style, performance, reputation, financial strength,
reporting, pricing, and research. The investment management fee charged by the
Independent Manager(s) is separate from, and in addition to, Registrant’s advisory fee as
set forth in Item 5.
Non-Discretionary Service Limitations. Clients that determine to engage Registrant on a
non-discretionary basis must be willing to accept that Registrant cannot effect any account
transactions without obtaining prior consent to such transaction(s) from the client. Thus, in
the event that Registrant would like to make a transaction for a client’s account (including
in the event of an individual holding or general market correction), and the client is
unavailable, the Registrant will be unable to effect the account transaction(s) (as it would
for its discretionary clients) without first obtaining the client’s consent.
Retirement Rollovers: A client or prospective client leaving an employer typically has
four options regarding an existing retirement plan (and may engage in a combination of
these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over
the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii)
roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value
(which could, depending upon the client’s age, result in adverse tax consequences). If the
Registrant recommends that a client roll over their retirement plan assets into an account
to be managed by the Registrant, such a recommendation creates a conflict of interest if
the Registrant will earn a new (or increase its current) advisory fee as a result of the
rollover. No client is under any obligation to roll over retirement plan assets to an account
managed by Registrant.
ERISA / IRC Fiduciary Acknowledgment. When Registrant provides investment advice
to a client regarding the client’s retirement plan account or individual retirement account,
it does so as a fiduciary within the meaning of Title I of the Employee Retirement Income
Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which
are laws governing retirement accounts. The way Registrant makes money creates some
conflicts with client interests, so Registrant operates under a special rule that requires it to
act in the client’s best interest and not put its interests ahead of the client’s.
Under this special rule's provisions, Registrant must:
• Meet a professional standard of care when making investment recommendations
(give prudent advice);
• Never put its financial interests ahead of the client’s when making
recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that Registrant gives advice that
is in the client’s best interest;
• Charge no more than is reasonable for Registrant’s services; and
• Give the client basic information about conflicts of interest.
Use of Mutual Funds: Most mutual funds are available directly to the public. Thus, a
prospective client can obtain many of the mutual funds that may be recommended and/or
utilized by Registrant independent of engaging Registrant as an investment adviser.
However, if a prospective client determines to do so, he/she will not receive Registrant’s
initial and ongoing investment advisory services. Registrant utilizes mutual funds issued
by Dimensional Fund Advisors (“DFA”). DFA funds are generally only available through
certain approved registered investment advisers. Thus, if the client was to terminate
Registrant’s services, and not transition to another adviser who is approved to trade in DFA
funds, restrictions regarding additional purchases of, or reallocation among other, DFA
funds will generally apply.
Data Aggregation Platforms. Registrant may provide its clients with access to online data
aggregation platform(s). The platform(s) allows a client to view their complete asset
allocation, including those assets that Registrant does not manage (the “Excluded Assets”).
Registrant does not provide investment management, monitoring, or implementation
services for the Excluded Assets. Therefore, Registrant shall not be responsible for the
investment performance of the Excluded Assets. Rather, the client and/or their advisor(s)
that maintain management authority for the Excluded Assets, and not Registrant, shall be
exclusively responsible for such investment performance. The client may choose to engage
Registrant to manage some or all of the Excluded Assets pursuant to the terms and
conditions of a services agreement between Registrant and the client. The platform(s) also
provides access to other types of information, including financial planning concepts, which
should not, in any manner whatsoever, be construed as services, advice, or
recommendations provided by Registrant. Finally, Registrant shall not be held responsible
for any adverse results a client may experience if the client engages in financial planning
or other functions available on the platform(s) without Registrant’s assistance or oversight.
Cash Positions. Registrant considers cash and cash equivalents to be a material component
of a client’s asset allocation. Depending upon perceived or anticipated market
conditions/events (there being no guarantee that such anticipated market conditions/events
will occur), the Registrant may maintain cash and cash equivalent positions (such as money
market funds, etc.) for defensive, liquidity, or other purposes. Unless otherwise agreed in
writing, all such cash positions are included as part of assets under management for
purposes of calculating the Registrant’s advisory fee. Clients are advised that, at any given
time, Registrant’s annual fee may exceed the yield earned on cash and cash equivalent
positions.
Periods of Portfolio Inactivity. Registrant has a fiduciary duty to provide services
consistent with the client’s best interest. As part of its investment management services,
Registrant will review client portfolios on an ongoing basis to determine if any changes are
necessary based upon various factors, including, but not limited to, investment
performance, mutual fund manager tenure, style drift, and/or a change in the client’s
investment objective. Based upon these and other factors, there may be extended periods
of time when Registrant determines that changes to a client’s portfolio are neither necessary
nor prudent. Of course, as indicated below, there can be no assurance that investment
decisions made by Registrant will be profitable or equal any specific performance level(s).
Investment management clients remain subject to Registrant’s asset-based fees during such
periods of account inactivity.
Legacy Engagements. Certain of Registrant’s clients remain engaged with Registrant for
legacy services and/or fee arrangements, which services and/or fee arrangements are not
described in this Brochure and are no longer offered to new clients. Such legacy clients are
advised to consult their executed agreement(s) with Registrant for further details.
Trade Error Policy. Registrant shall reimburse accounts for losses resulting from the
Registrant’s trade errors, but shall not credit accounts for such errors resulting in market
gains, unless it is the policy of the respective custodian/broker-dealer. Where permitted by
the custodian/broker-dealer, the gains and losses are reconciled within the Registrant’s
custodian firm account and Registrant retains the net gains and losses. Certain
custodians/broker-dealers that the Registrant has relationship with may net trade gains with
losses and donate any proceeds to charity.
Client Obligations. In performing its services, Registrant shall not be required to verify
any information received from the client or from the client’s other designated professionals
and is expressly authorized to rely thereon. Moreover, each client is advised that it remains
their responsibility to promptly notify Registrant if there is ever any change in their
financial situation or investment objectives for the purpose of
reviewing/evaluating/revising Registrant’s previous recommendations and/or services.
C. The Registrant shall provide investment advisory services specific to the needs of each
client. Prior to providing investment advisory services, an investment adviser
representative will ascertain each client’s investment objective(s). Thereafter, the
Registrant shall allocate and/or recommend that the client allocate investment assets
consistent with the designated investment objective(s). The client may, at any time, impose
reasonable restrictions, in writing, on the Registrant’s services.
D. Unaffiliated Wrap Programs. Registrant does not offer a wrap fee program for its
investment management services. However, Registrant is a participating investment
adviser in certain unaffiliated wrap and managed account fee programs, including wrap fee
programs sponsored by AssetMark. With respect to the wrap-fee program in which
Registrant is a participating investment adviser, clients pay a separate and additional wrap
fee directly to the wrap fee program sponsor. Under a wrap program, the wrap program
sponsor arranges for the investor participant to receive investment advisory services, the
execution of securities brokerage transactions, custody and reporting services for a single
specified fee. Participation in a wrap program may cost the participant more or less than
purchasing such services separately.
E. As of December 31, 2023, the Registrant had $184,371,301 in assets under management
on a non-discretionary basis and $109,499,361 in assets under management on a
discretionary basis.