Item 5 – Additional Compensation ............................................................................................................ vi
Item 6 – Supervision .................................................................................................................................. vi
James E. Salter ................................................................................................................................... vii
Item 2 – Educational Background and Business Experience ...................................................................... vii
Item 3 – Disciplinary Information ............................................................................................................. viii
Item 5 – Additional Compensation .............................................................................................................ix
Item 6 – Supervision ...................................................................................................................................ix
Craig Braemer ...................................................................................................................................... x
Item 2 – Educational Background and Business Experience ....................................................................... x
Item 3 – Disciplinary Information ...............................................................................................................xi
Item 5 – Additional Compensation .............................................................................................................xi
Item 6 – Supervision ...................................................................................................................................xi
PRIVACY INFORMATION ...................................................................................................................... A
Blossom Wealth Management Brochure Revised November 17, 2023 5
Description of Advisory Firm
Blossom Wealth Management, LLC (“Blossom,” “BWM,” “Firm,” or “Adviser”) is a privately
owned limited liability company registered with the U.S. Securities and Exchange
Commission. Blossom’s principal place of business is in San Ramon, California. The firm's
principal shareholders - George A. Salter II, CEO, and James E. Salter, COO, co-founded the
firm in 2009.
Fiduciary Duty
Registered investment advisers are considered fiduciaries under federal law. Our fiduciary
duty carries with it an obligation to act in the best interest of our clients pursuant to a
relationship of trust and confidence. It encompasses a
duty of care and a
duty of loyalty.
Duty of Care
The duty of care includes, among other things,
1. the duty to provide advice that is in the best interest of the client;
2. the duty to seek best execution of a client’s transactions where the adviser has the
responsibility to select broker-dealers to execute client trades; and
3. the duty to provide advice and monitoring over the course of the relationship.
The duty to provide advice suitable to each client based on a reasonable understanding of
the client’s objectives is a critical component of the duty of care. Providing suitable advice
includes making a reasonable inquiry into the client’s financial situation, investment
experience, and financial goals and then updating this information as necessary throughout
the course of the relationship to reflect the client’s changing objectives over time and
adjusting the advice we provide to reflect any changed circumstances.
When BWM has the responsibility to select broker-dealers to execute client trades in
discretionary accounts, we seek to trade such that the client’s total cost or proceeds in each
transaction are the most favorable under the circumstances. In doing so, we consider the full
range and quality of a broker’s services and so the determinative factor is not necessarily the
lowest possible commission cost but whether the transaction represents the best qualitative
execution. Moreover, we periodically and systematically evaluate the execution we receive
on behalf of our clients.
Our duty of care includes an obligation to provide advice and monitoring at a frequency that
is in the best interest of the client, taking into account the scope of the agreed relationship.
This scope is indicated by the duration and nature of the services as outlined in each client’s
advisory arrangement and extends to all personalized advice provided to clients.
Duty of Loyalty
BWM adheres to a duty of loyalty where we seek to serve the best interests of our clients and
never subordinate the interests of our clients to our own. Simply put, BWM cannot place its
Blossom Wealth Management Brochure Revised November 17, 2023 6
own interests ahead of the interests of our clients. In observance of this duty, we must make
full and fair disclosure to clients of all material facts relating to the advisory relationship.
Further, we also seek to eliminate or at least expose through full and fair disclosure all
conflicts of interest which might incline BWM, consciously or unconsciously, to render advice
that is not disinterested. We believe that in order for disclosure to be full and fair, it should
be sufficiently specific so that each client is able to understand the material fact or conflict of
interest and make an informed decision whether to provide consent. Consequently, we
provide this ADV 2A brochure to all prospective clients at or before entering into a contract
so that they can use the information within to decide whether or not to enter into an advisory
relationship.
Blossom offers the following advisory services to its clients:
Investment Management Services
Blossom provides discretionary or non-discretionary investment supervisory services. Each
portfolio is designed in an effort to meet the client’s particular investment goals, objectives,
circumstances, and risk tolerance while also providing clients with access to personal
advisory services. Because investments involve varying degrees of risk, they will only be
implemented or recommended when we deem them to be consistent with the client's stated
investment objectives, tolerance for risk, liquidity, and suitability.
Blossom primarily utilizes Exchange traded funds (ETFs) when making investment
selections/recommendations in client accounts. Additionally, Blossom’s investment
selections/recommendations, depending on the individual investment objectives and needs
of the client may include:
● Exchange-listed equity securities
● Mutual fund shares (including Dimensional Fund Advisors)
● Securities traded over-the-counter (unlisted)
● Corporate debt securities (other than commercial paper)
● Money market funds and cash
● Certificates of deposit
● Municipal securities
● United States governmental securities
On rare occasions, we also transact in options contracts in client accounts.
Blossom occasionally offers advice regarding additional types of investments if they are
appropriate to address the individual needs, goals, and objectives of the client or in response
to client inquiry. Blossom may offer investment advice on any investment held by the client
at the start of the advisory relationship. We describe the material investment risks for many
of the securities that we select/recommend under the heading
Specific Security Risks in
Item 8 below.
We discuss our discretionary authority below under
Item 16 - Investment Discretion. For
more information about the restrictions clients can put on their accounts, see
Tailored
Services and Client Imposed Restrictions in this item below. We describe the fees charged
for investment management services below under
Item 5 - Fees and Compensation.
Blossom Wealth Management Brochure Revised November 17, 2023 7
THRIVE
BWM previously offered and still utilizes on a legacy basis only, an automated investment
program (the “Program”) through which clients are invested in a range of investment
strategies we have constructed and manage, each consisting of a portfolio of exchange-
traded funds, mutual funds, and a cash allocation. The client’s portfolio is held in a brokerage
account opened by the client at Charles Schwab & Co., Inc. (“CS&Co”). We use the Institutional
Intelligent Portfolios® platform (“Platform”), offered by Schwab Performance Technologies
(“SPT”), a software provider to independent investment advisors and an affiliate of CS&Co.,
to operate the Program. We are independent of and not owned by, affiliated with, or
sponsored or supervised by SPT, CS&Co., or their affiliates (together, “Schwab”). We, and not
Schwab, are the client’s investment advisor and primary point of contact with respect to the
Program.
Financial Planning and Financial Consulting Services
BWM provides a variety of financial planning services, pursuant to a written agreement, to
individuals, families, and other clients regarding the management of their financial resources
based upon an analysis of the client’s current situation, goals, and objectives. Generally, such
financial planning services will involve preparing a financial plan or rendering a financial
consultation for clients based on the client’s financial goals and objectives. This planning or
consulting typically encompasses one or more of the following areas: investment planning,
retirement planning, estate planning, charitable giving, education planning, and business
planning.
The plan developed or financial consultation rendered to the client will usually include
general recommendations for a course of activity or specific actions to be taken by the clients.
For example, recommendations may be made that the clients begin or revise investment
programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or
alter retirement savings, or establish education or charitable giving programs. BWM may
also refer clients to an accountant, attorney, or other specialist. For planning engagements,
Adviser will generally provide a written summary of Client’s financial situation,
observations, and recommendations. However, on some occasions, plans are delivered
verbally. For consulting engagements, Adviser generally does not provide a written
summary. Plans or consultations are typically completed within six months of contract date,
assuming all information and documents requested are provided promptly.
Should a client choose to implement the recommendations contained in the plan, Blossom
suggests the client work closely with his/her attorney, accountant, insurance agent,
mortgage broker, and/or investment advisor. Implementation of financial plan
recommendations is entirely at the client’s discretion. Clients may choose but are not
required to have Blossom assist with financial plan implementation, including investment
management services, for which Blossom receives additional
compensation, as described
below in Item 5 – Fees and Compensation.
Family Office Services
Blossom approaches investment management with multiple generations in mind. We strive
to apply the same concepts as larger family offices to families who can potentially benefit
from similar advice but at a smaller scale. Our Family Office Services are based on the scope
Blossom Wealth Management Brochure Revised November 17, 2023 8
and complexity of the client’s financial picture. Services typically include but are not limited
to investment management, philanthropic management, life management and budgeting,
business advisory, liquidity & succession planning, estate planning and wealth transfer,
training and education, reporting and record keeping, administrative/back-office services,
tax and legal advisory, and risk management and insurance services.
Services provided may be directly executed by Blossom, which creates a conflict where
affiliated persons of Blossom recommend themselves for services where they will earn
additional compensation (see Item 10 – Other Financial Industry Activities and
Affiliations for additional information). These services may also be executed by an
unaffiliated third party, generally when the service requires special licensing licensed
personnel or unique experience (e.g., accounting & legal services). In those circumstances,
Blossom will assist in identifying the need for such services and will connect the client with
recommended third party services. Blossom will sometimes act as a liaison between the
Client and the third party.
Types of Family Offices
We classify family offices into three distinct categories:
● SFO or Single Family Office
As the name suggests, this is a private company that deals with the management of
finances for a single family. The functions of a single family office include managing
part or all of the family’s investments, trusts, estates, and acting as fiduciary. Often, the
SFO also offers concierge services to the family.
● MFO or Multi-Family Office
This is a company that offers investment, trust, estate, and fiduciary management
services to multiple families. MFOs can be private (i.e., only offering services to a few
families and not available to others), but most are commercial and available for many
families to hire. The families may or may not be connected, and a successful SFO can
potentially transition into a multi-family office over time.
● VFO or Virtual Family Office
Designed for families seeking the benefits of a family office without setting up a
company to facilitate it. A virtual family office allows families to outsource financial
services and other functions to professionals. Through the use of external consultants
and service providers, a VFO offers families many of the same benefits of a traditional
family office.
Fees for BWM’s Family Office Services are described below under Item 5 – Fees and
Compensation.
Retirement Plan Consulting Services
Our firm provides retirement plan consulting services to employer plan sponsors on an
ongoing basis. Generally, such consulting services consist of assisting employer plan
sponsors in establishing, monitoring, and reviewing their company's participant-directed
retirement plan. As the needs of the plan sponsor dictate, areas of advising may include:
Blossom Wealth Management Brochure Revised November 17, 2023 9
• Establishing an Investment Policy Statement – Our firm will assist in the development
of a statement on behalf of the Plan that summarizes the investment goals and objectives
along with the broad strategies to be employed to meet the objectives.
• Investment Options – Our firm will work with the Plan Sponsor to evaluate existing
investment options and make recommendations for appropriate changes.
• Investment Monitoring – Our firm will monitor the performance of the investments and
notify the client in the event of a change in investment lineup is warranted.
• Participant Education – Our firm will provide opportunities to educate plan participants
about their retirement plan offerings, different investment options, and general
guidance on allocation strategies at least annually.
In providing services for retirement plan consulting, our firm does not provide any advisory
services with respect to the following types of assets: employer securities, real estate
(excluding real estate funds and publicly traded REITS), participant loans, non-publicly
traded securities or assets, other illiquid investments, or brokerage window programs
(collectively, “Excluded Assets”). All retirement plan consulting services shall be in
compliance with the applicable state laws regulating retirement consulting services. This
applies to client accounts that are retirement or other employee benefit plans (“Plan”)
governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”).
If the client accounts are part of a Plan, and our firm accepts appointment to provide services
to such accounts, our firm acknowledges its fiduciary standard within the meaning of Section
3(21) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to
the provision of services described therein.
Fees for BWM’s Retirement Plan Consulting Services are described below under Item 5 –
Fees and Compensation.
Participant Account Management
BWM utilizes a third-party platform to facilitate discretionary management of the accounts
of retirement plan participants, including but not limited to 401(k) and defined contribution
plan participant accounts (collectively, “held-away accounts”). These held-away accounts
are not maintained with the custodian(s) we recommend but rather custodied at an
institution selected by the client and/or their employer. A link will be provided to the client
allowing them to connect the held-away account(s) to the platform.
Once accounts are connected to the platform, BWM will regularly review the available
investment options in these accounts, monitor them, and rebalance them, though using
different tools, as necessary.
Limitations on Investments
In some circumstances, Blossom’s advice may be limited to certain types of securities.
Limitation by Plan Sponsor/Employer
In the event Blossom is managing assets within a retirement plan such as 401(k), 403(b), or
other employer plan, Blossom is limited to those investment providers and investment
options chosen by the plan administrator. Similarly, when we provide services to
participants in an employer-sponsored plan, the participant may be limited to investing in
Blossom Wealth Management Brochure Revised November 17, 2023 10
securities included in the plan’s investment options. Therefore, Blossom can only make
recommendations to the client from among the available options and will not recommend or
invest the client’s account in other securities, even if there may be more suitable options
elsewhere.
Limitation by Client
Blossom may also limit advice based on certain client-imposed restrictions. For more
information about the restrictions clients can put on their accounts, see Tailored Services
and Client Imposed Restrictions in this Item below.
Non-Managed Assets
At its discretion, Blossom may offer securities trading activities for cash and securities in a
client’s non-managed account, acting as an intermediary between the client and the
custodian of the non-managed account. We do not provide investment advice regarding a
client’s non-managed assets or provide opinions as to the merits of any securities in non-
managed accounts. We also do not make any judgments as to the appropriateness of
assumed risk or suitability of any non-managed investment given the client’s situation. At
our discretion, Blossom offers this service in consideration of the client’s other accounts that
we manage.
Tailored Services and Client Imposed Restrictions
Blossom manages client accounts based on the investment strategy the client chooses, as
discussed below under Item 8 - Methods of Analysis, Investment Strategies, and Risk of
Loss. Blossom applies the strategy for each client, based on the client’s individual
circumstances and financial situation. We make investment decisions for clients based on
information the client supplies about their financial situation, goals, and risk tolerance. Our
recommendations/investment selections may not be suitable if the client does not provide
us with accurate and complete information. It is the client’s responsibility to keep Blossom
informed of any changes to their investment objectives or restrictions.
Clients may also request other restrictions on the account, such as when a client needs to
keep a minimum level of cash in the account or does not want Blossom to buy or sell certain
specific securities or security types in the account. Blossom reserves the right to not accept
and/or terminate management of a client’s account if we feel that the client-imposed
restrictions would limit or prevent us from meeting or maintaining the client’s investment
strategy.
Wrap Fee Programs
While we do not sponsor or provide portfolio management services to a wrap fee program,
we do facilitate an automated investment program (on a legacy basis only), as described
under the THRIVE service above, through which participating clients do not pay brokerage
commissions or any other fees to CS&Co. as part of the program.
Assets Under Management
Blossom manages client assets in both discretionary and non-discretionary accounts on a
Blossom Wealth Management Brochure Revised November 17, 2023 11
continuous and regular basis. As of January 25, 2023, the total amount of assets under our
management was:
Discretionary Assets $ 177,143,530
Non-Discretionary Assets $ 26,030,592
Total Assets $203,174,122
Publication of Periodicals
Blossom utilizes a third-party service provider to issue a monthly newsletter providing
general information on various financial topics including, but not limited to, estate and
retirement planning, market trends, etc. No specific investment recommendations are
provided in this newsletter and the information provided does not purport to meet the
objective or needs of any individual. This newsletter is distributed free of charge.
Research Reports
Blossom Wealth Management provides a research product consisting of portfolio offerings
similar to those we manage for our clients. The service includes the following:
● Monthly/quarterly list and weightings of names in the Strategy portfolio;
● Research reports of original stock recommendations are shared upon request of
existing portfolio names. Subscribers are notified of new purchase ideas and the
company report around the date of addition; and
● Notification by email of portfolio changes on the day of the portfolio changes.
Portfolios are designed to follow a specific strategy among several offered, including multiple
individual stock strategies and an ETF based asset allocation model. The service is provided
through a subscription-based model and limited to representatives of unaffiliated
investment advisers and broker-dealers that would like to bring in an outside research
service to help manage their clients’ money.