A. Description of the Advisory Firm
B. Types of Advisory Services
fees, brokerage fees, accounting/audit fees, administration fees, etc.). Those fees are
separate and distinct from the fees and expenses charged by WWM.
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.
Services Limited to Specific Types of Investments
WWM generally limits its investment advice to mutual funds, fixed income securities, real
estate funds (including REITs), hedge funds, insurance products including annuities,
equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation
protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds
and private placements, although WWM primarily recommends equities. WWM may use
other securities as well to help diversify a portfolio when applicable.
WWM offers the same suite of services to all of its clients. However, specific client
investment strategies and their implementation are dependent upon the client Investment
Policy Statement which outlines each client’s current situation (income, tax levels, and risk
tolerance levels). Clients
may impose restrictions in investing in certain securities or types
of securities in accordance with their values or beliefs. However, if the restrictions prevent
WWM from properly servicing the client account, or if the restrictions would require
WWM to deviate from its standard suite of services, WWM reserves the right to end the
relationship.
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees, transaction costs, fund expenses, and other administrative
fees. WWM does not participate in any wrap fee programs.
C. Client Tailored Services and Client Imposed Restrictions
D. Wrap Fee Programs
WWM has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$ 185,026,361.09 $ 0.00 December 2023
Lower fees for comparable services may be available from other sources.
Portfolio Management Fees
Total Assets Under Management Annual Fees
All Assets 1.50%
WWM uses the value of the account as of the last business day of the billing period, after
taking into account deposits and withdrawals, for purposes of determining the market
value of the assets upon which the advisory fee is based.
These fees are generally negotiable and the final fee schedule is attached as Exhibit II of
the Investment Advisory Contract. Clients may terminate the agreement without penalty
for a full refund of WWM's fees within five business days of signing the Investment
Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract
generally with 30 days' written notice.
Payment of Portfolio Management Fees
Asset-based portfolio management fees are withdrawn directly from the client's accounts
with client's written authorization on a quarterly basis. Fees are paid in arrears.
Clients are responsible for the payment of all third party fees (i.e. custodian fees,
brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and
distinct from the fees and expenses charged by WWM. Please see Item 12 of this brochure
regarding broker-dealer/custodian.
E. Assets Under Management