This brochure describes the investment services all-inclusive wrap fee program (“Program”) offered by JDM Financial Group, LLC (“JDM”) and information about JDM. Clients who wish to retain such services will enter into an investment advisory agreement with JDM (“Client Agreement”) under which JDM provides discretionary investment advisory services. If the client enters into a Client Agreement, JDM will, and is authorized by the client to, manage and rebalance client assets without prior consultation with the client. As of December 31, 2023, we manage total assets of $245.2 million on a discretionary basis. JDM does not manage assets on a non-discretionary basis.
The Client Agreement sets forth services that the client will receive and any fee that the client will pay.
Under the Client Agreement, all of client’s assets will be managed by JDM directly.
JDM will have full discretionary authority with respect to the investment and reinvestment of client assets in accordance with, and subject to, the information provided in the Investment Guidelines.
JDM constructs client portfolios by first determining the appropriate asset allocation across major assets classes, such as but not limited to stocks, real estate, bonds and cash, based on conversations with clients and information collected from them. JDM determines the appropriate the appropriate asset allocation by considering factors such as the client’s current and anticipated cash flow needs, psychological and financial risk tolerance, time horizon for accomplishing stated goals and the relative attractiveness of the markets for various types of assets. Once selecting an appropriate asset allocation, JDM selects or recommends mutual funds or exchange traded funds to represent various asset sub categories within each asset class (For example, an international stock fund to represent the international exposure within the stock market portion of the portfolio) . JDM generally selects mutual funds or exchange traded funds that create, either alone or collectively, an acceptable level of diversification within a given asset class given the size of a client portfolio. This diversification generally includes exposure to specific economic sectors, regions or countries and JDM may also consider the tax or tax deferred nature of an account when making investment selections.
JDM will typically invest client assets in various open-end funds, including mutual funds or exchange- traded funds (“Funds”).
JDM has contracted with First Ascent Asset Management, LLC ("First Ascent"), a SEC-registered investment advisor to provide subadvisory services. First Ascent primarily invests using ETFs and mutual funds.First Ascent implements the recommendations made by JDM, and JDM retains full discretion about which assets are placed at First Ascent. First Ascent Asset Management, when used as a sub-advisor by JDM for select clients, will not have the discretionary authority to select investments or determine the asset allocation for portfolios. These remain the sole discretion of JDM. First Ascent's authority is restricted to executing trades at JDM's request.
For the asset management services described in the Client Agreement, each client will be charged an asset-based fee each calendar quarter. The fee that may be charged to a client depends on the amount of client assets under management, and is determined according to the following schedule: Assets Under ManagementMaximum Annual Fee $0 - $499,9991.50% $500,000 - $999,9991.25% $1,000,000 - $9,999,9991.00% $10,000,000 and above0.90% Notwithstanding the above, the asset-based fee to be paid each quarter shall be no less than $1,000 for clients with an inception date after January 1, 2016. These fees are negotiable at JDM's sole discretion based on the scope and complexity of services to be rendered and account size. The rate used each quarter will be approximately one-fourth of the annual rate based on the number of days in the quarter.
The asset-based fee will be payable quarterly in advance. The initial fee (“Initial Fee”) will be calculated as of the date the applicable Client Agreement is accepted by JDM (“Commencement Date”). The Initial Fee will cover the period from the Commencement Date until the last day of the initial calendar quarter.
The Initial Fee will be calculated proportionately with respect to the number of days in the initial quarterly billing period, and will be based on the market value of the client’s assets on the last business day of the quarter for which the fee is due and will be due at the end of such quarter. Thereafter, the quarterly fee will be calculated based on the market value of the client’s assets as of the close of business on the last day of the preceding calendar quarter and will be due on the first business day of the quarter for which the fee is due. First Ascent receives an asset-based fee for its services, which is paid by JDM.
Charles Schwab & Co., Inc. ("Schwab") currently maintains custody of client assets and will receive and credit to the account(s) all interest, dividends, and other distributions that it receives on the assets in the account(s). The quarterly fees will be deducted from the client’s account at Schwab as they become due and payable.
Fees will generally include an asset-based fee as compensation for the discretionary investment management services provided by JDM, fees associated with JDM’s use of any Platform, and fees for custodial services performed by, and transaction charges for transactions executed at, Schwab or another custodian or registered broker, respectively, with which JDM may establish contractual arrangements.
JDM has the authority to negotiate fee arrangements. As a result, one client may pay a higher fee to JDM than a second client for whom JDM is providing substantially similar services. The actual fee rate(s) paid by the client will be set forth in the Client Agreement. Fees paid by the client to JDM may be higher or lower than the cost of similar services offered through other financial firms. The fees charged to the client will not be affected by the number of transactions executed on behalf of a client.
Generally, clients may add assets to, or withdraw assets from, their account at any time. Clients seeking to withdraw assets from their account must provide at least seven (7) days’ written notice to JDM prior to such withdrawal. Generally,

fees will not be adjusted for intra-quarter withdrawals or additions.
Generally, the client or JDM may terminate the Client Agreement upon providing thirty (30) days’ prior written notice to the other party.
If a Client Agreement is terminated by either party within five (5) business days after the Client Agreement is executed by both parties and dated executed copies are received by both parties, the client will receive a full refund of any fee paid. If a Client Agreement is terminated by either party more than five (5) business days after the Client Agreement is executed by both parties and dated executed copies are received by both parties, the client will receive a pro-rata refund of any fees paid, based on the number of days remaining in the calendar quarter after the date upon which notice of termination is received by JDM or the client, as applicable.
Fees paid by the client under the Program may be higher or lower than the fees that JDM and Schwab would charge a client if the client had purchased the services separately and not as part of the Program.
This will depend on various factors, including the level of the fees charged, the amount of portfolio activity in the client’s account and the value of services provided under the program.Schwab has eliminated commissions for online trades of U.S. equities, ETFs and options (subject to a per contract fee). We encourage you to review Schwab’s pricing to compare the total costs of entering into a wrap fee arrangement versus a non-wrap arrangement. To see what you would pay for transactions in a non-wrap account please refer to Schwab’s most recent pricing schedules available on their website.
Fees charged to the client may not include fees for custodial services that are performed by custodians other than Schwab, or any brokerage commissions or charges on transactions ordered by client, or brokerage commissions or other charges resulting from transactions executed by a broker other than Schwab or another registered broker with which JDM may establish contractual arrangements. Generally, any costs charged by such other custodian or broker will be borne by the client.
Fees charged by JDM to the client do not include the amount of any costs, expenses or commissions incurred by a client with respect to transactions placed by the client at Schwab independently of JDM.
Fees also do not include the fees and expenses a client may incur as a shareholder of a Fund, or certain costs or charges that may be imposed by Schwab or third parties, including margin interest, costs associated with exchanging foreign currencies, odd lot differentials, Securities and Exchange Commission fees, transfer taxes, exchange fees, wire transfer fees, postage fees, auction fees, foreign clearing, settlement and custodial fees, and other fees or taxes required by law. In addition, the fees charged by JDM to the client do not cover “mark-ups” and “mark-downs” that other broker-dealers may receive or “dealer spreads” that Schwab or other broker-dealers may receive when acting as principal in certain transactions, or the amount of any annual fee that Schwab may charge on an Individual Retirement Account (IRA) or certain other retirement plans.
The amount of compensation JDM receives from a client in the Program may be more than what JDM would have received if the client engaged JDM without participating in the Program, thereby paying separate expenses relating to investment advice, brokerage and custodial services. As a result, JDM may have a financial incentive to recommend that a client participate in the Program instead of engaging JDM independently of the Program. Because JDM pays trading costs for client trades, there is an incentive to reduce costs by minimizing the number of trades made.
JDM does not aggregate orders for client accounts. The majority of investments are open-end mutual funds which price daily and exchange traded funds.
JDM is authorized and directed to effect transactions for client account(s) directly through Schwab and transactions ordinarily will be effected through Schwab. All transactions are subject to any Schwab internal policies or procedures. In no event is Schwab obligated to effect any transaction that Schwab believes would violate applicable federal or state law, or the regulations of any regulatory or self- regulatory body or would otherwise present an unacceptable risk to Schwab.
When a transaction is executed through a broker or dealer other than Schwab, clients may incur a transaction fee, commission, or other charges. Such fees, commissions or other charges will be in addition to the fees charged to the client by JDM. Such broker or dealer shall be solely responsible for the execution and clearance of these transactions.
Clients may authorize Schwab (or another registered broker with which JDM may establish contractual arrangements) to the extent permitted by applicable law, to invest cash balances in one or more money market funds, which may or may not be affiliated with Schwab or such other broker. Clients are to receive from the broker that executed the relevant transaction a current prospectus for each money market fund in which the client assets are invested. Clients should refer to each prospectus for information about the money market fund and any applicable fees associated with investment in such fund. Assets held in such funds are subject to various fees and expenses, which are paid by such funds but ultimately borne by clients.
When calculating the net value of assets in a client account under the Program, JDM generally uses information provided by Schwab, which in turn uses recognized independent quotation and valuation services. Currently, JDM reasonably believes this information to be reliable. As such, JDM does not, and has no duty to, verify the accuracy of the information provided by these services. If any information provided by these services is unavailable or is believed to be unreliable, JDM will value assets in a manner JDM determines in good faith to reflect fair market value. JDM may use different valuation sources for different purposes. As a result, the determination of account asset values may differ for various reasons.