A. DESCRIPTION OF THE ADVISORY FIRM.
Braeburn Wealth Management, LLC (“Braeburn Wealth Management”, “BWM” or
“Adviser”) is an independently owned fee-based Registered Investment Adviser.
The Adviser initially registered with the United States Securities and Exchange
Commission in 2011 and transitioned its registration to the State of Michigan in 2012. In
August 2016 the firm reached the level of assets under management which allows the
firm to return to registration with the Unlisted States Securities and exchange
commission.
Michael Poland, CFA®, is the Adviser’s Managing Member, Chief Compliance Officer
and 100% owner of the Adviser. Michael Poland, CFA® has been in the financial and
investment business since 1989.
Braeburn Wealth Management’s headquarters are located in Norton Shores, Michigan.
The Adviser is not affiliated with any other entities.
B. TYPES OF ADVISORY SERVICES
As described in the preceding section, Braeburn Wealth Management, LLC, (“Braeburn
Wealth Management”, “BWM” or the “Adviser”), is a fee based independent Registered
Investment Adviser. The term “fee based” as it applies to this Adviser means the
Adviser and its Advisory Representatives will not accept commissions in connection
with securities recommendations. Braeburn Wealth Management is only compensated
for advisory services via a percentage of assets under management; hourly fees or
project-based fees depending upon the services requested and scope of the
engagement.
“Advisory Representatives” are those persons authorized by the firm to deliver financial
and investment advisory services on behalf of the Adviser. Advisory Representatives of
Braeburn Wealth Management are not registered representatives of any broker/dealer
firm. While not the primary focus of their business, Representatives of the Adviser are
separately engaged as independently licensed insurance and annuity representatives.
As disclosed in this Brochure, these independently licensed persons may accept normal
commissions paid by insurance companies when clients purchase products through
them. Clients are welcome but are never obligated to purchase products from Advisory
Representatives.
You will be provided under separate cover an ADV Part 2B Brochure (an Advisory
Representative’s “Biography”) for each Advisory Representative who will directly provide
investment or financial advice to you, or who may assist in the management of your
investment portfolio.
Braeburn Wealth Management is not a broker/dealer or custodial firm. Any transactions
in securities will be executed and held by an unaffiliated custodial firm of clients’
choosing.
Braeburn Wealth Management may offer a complimentary general consultation to
discuss the services available, to give a prospective client time to review services
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desired, and to determine the possibility of a potential Client-Adviser relationship.
Services begin only after the client and Adviser formalize the relationship with a properly
executed Client Agreement.
After the formal engagement and depending upon the scope of the engagement, the
Adviser and client will share in a more intensive data gathering and discovery process in
an effort to determine the client’s stated needs, goals, intentions, time horizons, risk
tolerance and investment objectives, based upon information provided by the client and
the nature of services requested.
Braeburn Wealth Management offers Investment Management Services, Financial
Planning or Consultation Services, a Complimentary Newsletter and General
Education Workshops.
1. Investment Management Services focus solely on portfolio management. The
Adviser’s services are continuous in nature and thus are ongoing until terminated by
either party.
After the formal engagement, the Adviser and client will share in a data gathering and
discovery process in an effort to determine the client’s stated needs, goals, intentions,
time horizons, risk tolerance, and investment objectives, based upon information
provided by the client and the nature of services requested. The Adviser will request
input and information from the client which may include: Financial information including
past financial history, prior year income tax returns, present financial condition, and the
Client’s investment goals. These may include planning for short-term goals (such as
college funding) or for long-term goals (such as retirement planning) or other segments
of an investment plan that may be desired.
The information gathered for review and assessment may vary, depending upon the
individual needs and objectives of the client. Information presented by the client will be
deemed reliable and current and the Adviser is under no obligation to verify the data
provided. The Adviser may request the names and relationships of other Advisers (e.g.,
attorney, accountant, banker, etc.), family background and makeup, and anything else
which may affect the client economically, based upon what information is reported by
the client. The client may complete risk-tolerance and investment policy data or similar
documentation.
The Adviser will analyze the client’s information and thereafter will prepare
recommendations and advice for creation of a new investment plan or may suggest
updates to an existing portfolio along with strategies designed to help clients meet their
stated objectives. Based upon the collected information and with the client’s input, the
Adviser can prepare an investment policy statement or similar document.
Recommended investments may include short-term instruments (i.e. T-Bills), stocks,
bonds, mutual funds, exchange traded funds (ETFs) or other investment vehicles.
Investment Management fees are based upon assets under management as outlined
in the Client Agreement or Client Agreement’s Addendum.
Clients engaging investment advisory services are expected to play an active role. The
Adviser requires the client to participate in the formation of the investment plan, advice
and recommendations. Braeburn Wealth Management strongly encourages clients to
maintain contact with the Adviser and requests client reviews via meetings or
telephonically, not less than annually in order to review and update the investment
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policy/plan and address ongoing needs as may be applicable. Clients may call the
office at any time during normal business hours to discuss their portfolio with their
Advisory Representative or to ask questions. However, clients are obligated to
immediately inform the Adviser of any changes in their financial situation to provide the
Adviser an opportunity to review the client’s new data to help ensure the portfolio and
the investment strategies continue to be structured to help meet the client’s changing
needs and objectives.
Depending on the nature of services to be provided, Braeburn Wealth Management
generally develops and utilizes a personalized asset allocation profile that is consistent
with the client’s desired rate of return, time horizon and risk tolerance based upon the
client’s input. Braeburn Wealth Management can then design and implement portfolio
recommendations (with client authorization). Where an existing portfolio has been
designed by the client or another party, Braeburn Wealth Management can provide
recommendations for re-design, adjustments or re-balancing.
Unless otherwise directed by the client, Braeburn Wealth Management will generally
seek to allocate a client’s assets among various types of investments, taking into
consideration the strategic portfolio framework developed with the client. In each case,
the stated individual needs, goals and desires of clients are taken into consideration.
Braeburn Wealth Management primarily allocates its client’s investment management
assets, on a discretionary and/or non-discretionary basis among low cost mutual funds,
exchange traded funds (ETFs), closed-end funds, individual debt and equity securities,
bonds, and at times options, in accordance with the investment objectives of the client.
The Adviser may also provide advice about and/or recommend real estate investment
trusts (REITs),
The Adviser may also consider other types of investments or may remain available to
consult with clients on U.S. government securities, fixed-income securities or existing
holdings in variable products, commercial paper, warrants, and various other types of
investments held in a client’s portfolio at the beginning of the advisory relationship.
Once the portfolio has been implemented or transferred for services, Braeburn Wealth
Management can provide continuous monitoring, recommendations and investment
advice as outlined in the engagement for services. The ongoing Investment
Management Services are based upon the investment strategy or policy agreed upon
between Braeburn Wealth Management and the client. In providing ongoing Investment
Management Services, the Adviser will manage investor funds in accordance with an
investment plan or strategy as designated by the client and the Adviser will remain
available for ongoing advice and recommendations. The Adviser will monitor the
portfolio in accordance with the directives provided.
Certain clients may desire to place or keep certain assets within their account(s) that
are selected by the client and are not the subject of investment advice by the Adviser.
These are “self-directed” assets. In such cases, the Adviser has/will not pass on the
suitability of self-directed assets. Should the Advisor ever assist clients with self-
directed implementation it may do so only as a value-added service at the client’s
request. The Adviser will have no responsibility to manage any “self-directed” assets in
client accounts and the Adviser accepts no liability to those clients in connection with
any loss relating to “self-directed” assets.
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Services and investment recommendations in connection to assets invested in
corporate retirement plans are limited to those offered within the plan and via the plan’s
contracted service providers.
If services desired go outside the scope of Investment Management Services during the
engagement, the Adviser may be available to provide Consultation Services. In such
cases, the Adviser may request a new or amended Client Agreement and additional fees
may apply. The Adviser will not engage in additional services that will result in additional
fees without the client’s direction.
2. Financial Planning Services or Consultation Services. Braeburn Wealth
Management is available to provide advice through Financial Planning Services or
general Consultation Services. These services are offered at an hourly rate or via a
project fee.
Financial Planning Services may be comprehensive in nature or may focus on specific
components of overall planning needs. Services can focus on income, cash flow,
retirement preparation and planning, IRA reviews, education funding, estate planning,
risk management issues, non-securities investments, financial issues in connection with
marriage or divorce, and various other components of Financial Planning that may be
identified by the client.
Financial Planning Services generally utilize long-term strategies so that continuous
monitoring is not required. Services can be tailored and can focus on various
components of planning or services can be comprehensive in nature, as desired by the
client. However, when Financial Planning Services only focus on certain areas of client
interests, needs, or is otherwise limited, clients must understand that a client’s overall
financial and investment needs and objectives may not be considered as a result of
time and/or service restraints placed on the Advisor’s services.
The Adviser’s Consultation Services are available to address general or specific issues
of interest to the client. Advisory services are available for issues relating to securities
investments, asset allocation issues, investment research, business owner issues, and
various other issues of interest that may be identified by the client.
As with the Adviser’s Financial Planning Services, Consultation Services can be tailored
and can focus on various components or can be comprehensive in nature, as desired
by the client. However, when advisory services only focus on certain areas of client
interests, needs, or is otherwise limited, clients must understand that a client’s overall
financial and/or investment needs and objectives may not be considered as a result of
time and/or service restraints placed on the Adviser’s services.
Clients requiring assistance on issues relating to matters outside of financial or
investment advisory topics should consult their personal tax adviser, legal counsel, or
other professionals for expert opinions.
The Adviser’s Financial Planning and Consultation Services do not include any portfolio
monitoring, reviews, follow-ups, or other services unless specifically agreed to in writing.
The advice provided by the Adviser may include recommendations for updates and
reviews. It is the client’s responsibility to follow-up and secure additional services, at the
client’s discretion, under a new or amended agreement for any services desired
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thereafter or at any time in the future.
Implementation of any advice or recommendations in connection with Financial
Planning Services and Consultation Services, in whole or in part, is entirely at the
client’s discretion via the service provider(s) of the client’s choice.
As is applicable with any of the Adviser’s services, when providing a review or advice in
connection with investments within retirement plans, the Adviser’s advice and
recommendations (if any) are based upon and limited to the investment offerings within
the plan and are limited to the service provider(s) selected by the plan providers.
3. General Newsletter Services. Braeburn Wealth Management offers a
complimentary general newsletter for prospective or current clients. The Adviser’s
newsletter may cover various topics pertaining to general financial, investment and
market issues.
The frequency of the newsletter may vary but will generally involve weekly or quarterly
issues. Clients and prospective clients are welcome to request to receive the Adviser’s
newsletter by contacting the Adviser or by directly responding to an offer from the
Adviser to receive the publications. Those receiving the newsletters are welcome to
request termination of this complimentary service at any time by contacting the Adviser
via phone, email or letter.
4. General Educational Workshops for Individuals and Corporations. Braeburn
Wealth Management may conduct complimentary general educational workshops for
individuals and corporations. The workshops can be designed to meet the unique
needs of participants and may include general presentations on Investment
Management, Financial Planning, various investment and insurance strategies,
education funding, estate and retirement options, business owner issues, and topics
associated with plan investments. Attendees are always welcome, but are never
obligated to engage Braeburn Wealth Management for individualized services.
5. Conflict of Interest – IRA Rollover Recommendations. When recommending
that a client rollover his or her account from current retirement plan to an IRA,
Braeburn Wealth Management and its investment adviser representatives have a
conflict of interest. Braeburn Wealth Management and its representatives can earn
investment advisory fees by recommending that a client rollover his or her account at
the retirement plan to an IRA; however, Braeburn Wealth Management and its
investment adviser representatives will not earn any investment advisory fee if client
does not rollover the funds in the retirement plan (unless a client retained Braeburn
Wealth Management to provide advice about my retirement plan account). Thus,
Braeburn Wealth Management and its investment adviser representatives have an
economic incentive to recommend a rollover of my retirement plan account, which is
a conflict of interest. Braeburn Wealth Management has taken steps to manage this
conflict of interest arising from rolling over funds from an ERISA covered retirement
plan to an IRA and a client has adopted an impartial conduct standard through its
code of ethics whereby Braeburn Wealth Management and its investment adviser
representatives will (i) provide investment advice to ERISA covered retirement plan
participant regarding a rollover of funds from the ERISA covered retirement plan in
accordance with the fiduciary status described below,
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(ii) not recommend investments which result in Braeburn Wealth Management
receiving unreasonable compensation related to the rollover of funds from the
ERISA covered retirement plan to an IRA, and (iii) fully disclose compensation
received by Braeburn Wealth Management and its supervised persons and any
material conflicts of interest related to Braeburn Wealth Management
recommending the rollover of funds from the ERISA covered retirement plan to an
IRA and refrain from making any materially misleading statements regarding such
rollover.
To the extent Braeburn Wealth Management provides investment advice to a
participant in a retirement plan under Employee Retirement Income Security Act of
1974 as amended ("ERISA") regarding whether to maintain investments and/or
proceeds in an ERISA retirement plan, rollover such investment/proceeds from the
ERISA retirement plan to an individual retirement account (“Rollover IRA account”)
or make a distribution from the ERISA retirement plan, Braeburn Wealth
Management hereby acknowledges its fiduciary obligations with regard to its
investment advice about whether to maintain, rollover or distribute proceeds from
those ERISA retirement plans, and as such a fiduciary with respect to its
investment advice about whether to maintain, rollover or distribute proceeds from
those ERISA retirement plans, Braeburn Wealth Management and its
representatives shall act with the care, skill, prudence, and diligence under the
circumstances then prevailing that a prudent person acting in a like capacity and
familiar with such matters would use in the conduct of an enterprise of a like
character and with like aims, based on the investment objectives, risk, tolerance,
financial circumstances, and a client’s needs, without regard to the financial or
other interests of Braeburn Wealth Management or its affiliates.
6. Written Acknowledgement of Fiduciary Status
When we provide investment advice to you regarding your retirement plan account or
individual retirement account, we are fiduciaries 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 we make money
creates some conflicts with your interests, so we operate under a special rule that
requires us to act in your best interest and not put our interest ahead of yours. Under
this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations
(give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give
loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your
best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
C. CLIENT TAILORED SERVICES AND CLIENT IMPOSED RESTRICTIONS
Braeburn Wealth Management focuses on providing individualized services. The
Adviser can tailor services to focus only on certain portfolio components, depending
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upon the client’s wishes and/or the nature of the engagement. However, where
client services or information are limited, clients must understand that
comprehensive financial and/or investment needs and objectives may not be fully
considered due to the client’s option to receive limited services, the lack of
information received, and/or client disclosure.
Clients may impose restrictions in investing in certain securities or types of securities
in accordance with their values or beliefs if agreed by the Adviser in writing (i.e., no
tobacco, alcohol, etc). Clients are welcome to set parameters in writing as to the
Adviser’s limited discretionary authority in connection with types of investments and
amounts purchased or sold.
Where clients retain authority to implement recommendations, they are welcome to do
so in whole or in part via the financial services provider(s) of their choice.
D. WRAP FEE PROGRAMS
Braeburn Wealth Management does not sponsor or manage a wrap fee program.
E. AMOUNTS OF ASSETS UNDER MANAGEMENT
As of December, 2022, Braeburn Wealth Management managed $239,018,392.00
with $194,492,457.00 managed in 971 discretionary accounts, and $44,525,935.00
managed in 27 non-discretionary accounts.
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