A. Describe your advisory firm, including how long you have been in business. Identify your principal owner(s).
WBH Advisory, Inc. (“WBH”) is a registered investment adviser with the Securities and Exchange Commission. WBH’s
principal office is located at 1829 Reisterstown Road, Suite 225, Baltimore, Maryland 21208. The phone number is 410-
653-7979. The facsimile number is 410-653-8142. Marc Hertzberg is the principal owner of WBH.
B. Describe the types of advisory services you offer. If you hold yourself out as specializing in a particular type of
advisory service, such as financial planning, quantitative analysis, or market timing, explain the nature of that
service in greater detail. If you provide investment advice only with respect to limited types of investments,
explain the type of investment advice you offer, and disclose that your advice is limited to those types of
investments.
WBH offers to provide investment management, financial planning, estate planning and income tax planning. WBH
does not hold itself out as specializing in a particular type of advisory service. WBH maintains two service offerings
that are dependent on the client’s level of assets and need for financial planning services. Each of these offerings is
discussed below.
Wealth Management
WBH’s Wealth Management offering is intended for clients with more assets and more complex financial pictures.
This service provides ongoing portfolio management services, and clients can notify WBH to receive financial
planning, estate planning, tax planning, college planning, and risk management. In the Wealth Management
offering, clients receive customized investment management based on their unique needs and circumstances and risk
tolerance.
Portfolio Management + Financial Planning
WBH’s Portfolio Management + Financial Planning offering is for clients that hire WBH on or after October 1, 2019
who have not yet reached the asset level necessary for the Wealth Management offering. This offering makes
available portfolio management. In addition, WBH is available to provide financial planning, estate planning, tax
planning, college planning, and risk management. However, clients may pay additional fees for financial planning
services, which are described further in Item 5 below.
To commence the investment advisory process, WBH will ascertain each client’s investment objective(s) and then
allocate the client’s assets consistent with the client’s designated investment objective(s). Once allocated, WBH
provides ongoing supervision of the account(s). Before engaging WBH to provide investment advisory services, clients
are required to enter into an Investment Advisory Agreement with WBH setting forth the terms and conditions of the
engagement (including termination), describing the scope of the services to be provided, and the fee that is due from
the client. To the extent that clients seek to engage WBH for financial planning services, clients will execute a
Financial Planning and Consulting Agreement.
WBH believes that it is important for the client to address financial planning issues on an ongoing basis. WBH’s
advisory fee, as set forth at Item 5 below, will remain the same regardless of whether or not the client determines to
address financial planning issues with WBH. It remains each client’s responsibility to promptly notify WBH if there is
ever any change in his/her/its financial situation or investment objectives for the purpose of
reviewing/evaluating/revising our previous recommendations and/or services.
Stand-Alone Financial Planning and Non-Investment Consulting Services. WBH may also provide financial planning
and related consulting services regarding matters such as tax and estate planning, insurance, etc. on a stand-alone
basis per the terms and conditions of a separate written agreement and fee, the fee for which shall generally be based
upon the individual providing the service and the scope of the services to be provided. Prior to engaging WBH to provide
planning or consulting services, clients are generally required to enter into a Financial Planning and Consulting
Agreement with WBH 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 WBH commencing
services.
C. Explain whether (and, if so, how) you tailor your advisory services to the individual needs of clients. Explain
whether clients may impose restrictions on investing in certain securities or types of securities.
WBH manages each client’s portfolio based on unique factors that are specific to each client. These factors include
the client’s investment objectives, risk tolerance, investment time horizon, withdrawal requirements, and other
special circumstances. Clients may impose restrictions on investing in certain securities or types of securities.
D. If you participate in wrap fee programs by providing portfolio management services, (1) describe the
differences, if any, between how you manage wrap fee accounts and how you manage other accounts, and (2)
explain that you receive a portion of the wrap fee for your services.
Not applicable
E. If you manage client assets, disclose the amount of client assets you manage on a discretionary basis and the
amount of client assets you manage on a non-discretionary basis. Disclose the date “as of” which you calculated
the amounts.
As of December 31, 2023, WBH managed $1,294,477,358 on a discretionary basis . WBH does not manage client assets
on a non-discretionary basis.
F. Miscellaneous
Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. To the extent generally
engaged by a client to do so per the terms and conditions of a written agreement, WBH may provide financial
planning and related consulting services regarding non-investment related matters, such as estate, tax, and insurance
planning. WBH does not serve as a law firm, accounting firm, or insurance agency, and no portion of our services
should be construed as legal or accounting services. Accordingly, WBH does not prepare estate planning documents,
tax returns, or sell insurance products. To the extent requested by a client, we may recommend the services of other
professionals for certain non-investment implementation purpose (e.g., attorneys, accountants, insurance agents)
including WBH’s representative in his individual capacity. For example Marc Hertzberg is an attorney and CPA. See
disclosure at Item 10 below. A client is under no obligation to engage the services of any recommended professional.
The client retains absolute discretion over all implementation decisions and is free to accept or reject any
recommendation that we make. It remains the client’s responsibility to promptly notify WBH if there is ever any change
in their financial situation or investment objectives so that WBH can review, and if necessary, revise its previous
recommendations. If the client engages any unaffiliated recommended professional, and a dispute arises, the client
agrees to seek recourse exclusively from the engaged professional. At all times, the engaged licensed professional(s)
(i.e. attorney, accountant, insurance agent, etc.), and not WBH, shall be responsible for the quality and competency
of the services provided. The recommendation by WBH that a client engage a WBH representative for legal or
accounting service presents a conflict of interest, as the receipt of legal or accounting fees provides an incentive to
recommend their services based on fees to be received, rather than on a particular client’s need. No client is under
any obligation to engage Mr. Hertzberg to provide any legal or accounting services. Clients are reminded that they
may obtain legal and accounting services from unaffiliated lawyers and accounting firms. WBH’s Chief Compliance
Officer, Marc Hertzberg, remains available to address any questions that a client or prospective client may have
regarding this conflict of interest. If the client engages any unaffiliated professional, and a dispute arises thereafter
relative to such engagement, the engaged professional (and not Registrant) shall remain exclusively responsible for
resolving any such dispute with the client.
Custodian Charges-Additional Fees. As discussed below at Item 12 below, when requested to recommend a broker-
dealer/custodian for client accounts, WBH generally recommends that Schwab or Fidelity serve as the broker-
dealer/custodian for client investment management assets. Broker-dealers such as Schwab and Fidelity charge
brokerage commissions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e.,
including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income
transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as
the amount of those fees) shall differ depending upon the broker-dealer/custodian (while certain custodians,
including Schwab and Fidelity, do not currently charge fees on individual equity or ETF transactions, others do. While
Schwab and Fidelity charge transactions fees on certain mutual funds, the funds and/or amount of the transaction
fee may differ). When beneficial to the client, individual fixed-income and/or equity transactions may be effected
through broker-dealers with whom WBH and/or the client have entered into arrangements for prime brokerage
clearing services, including effecting certain client transactions through other SEC registered and FINRA member
broker-dealers (in which event, the client generally will incur both the transaction fee charged by the executing
broker-dealer and a “trade-away” fee charged by Schwab and/or Fidelity). These fees/charges are in addition to
WBH’s investment advisory fee at Item 5 below. WBH does not receive any portion of these fees/charges. ANY
QUESTIONS: WBH’s Chief Compliance Officer, Marc Hertzberg, remains available to address any questions that a
client or prospective client may have regarding the above.
Use of Mutual Funds and Exchange Traded Funds. WBH recommends and invests in publicly available mutual funds
and exchange traded funds that clients can purchase without engaging WBH as an investment adviser. However, if
a client or prospective client determines to invest in these mutual funds or exchange traded funds without engaging
WBH as an investment adviser, the client or prospective client would not receive the benefit of WBH’s initial and
ongoing investment advisory services.
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 WBH recommends that a client roll over their
retirement plan assets into an account to be managed by WBH, such a recommendation creates a conflict of interest
if WBH will earn new (or increase its current) compensation as a result of the rollover. When acting in such capacity,
WBH serves as a fiduciary under the Employee Retirement Income Security Act (ERISA), or the Internal Revenue Code,
or both, which are laws governing retirement accounts. No client is under any obligation to roll over retirement plan
assets to an account managed by WBH, whether it is from an employer’s plan or an existing IRA. WBH’s Chief
Compliance Officer, Marc Hertzberg, is available to address any questions that a client or prospective client may have
regarding the conflict of interest presented by rollover recommendations.
Emoney/MoneyGuidePro. WBH may use emoney or MoneyGuidePro to provide periodic comprehensive reporting
services, which can incorporate all of the client’s investment assets, including those investment assets that are not part
of the assets that WBH manages (the “Excluded Assets”). The client and/or their other advisors that maintain trading
authority, and not WBH, shall be exclusively responsible for the investment performance of the Excluded Assets.
WBH’s service relative to the Excluded Assets is limited to reporting only, which does not include investment
monitoring or implementation. The client may engage WBH to manage the Excluded Assets pursuant to the terms
and conditions of a written agreement between WBH and the client. In the event that WBH provides the client with
access to an unaffiliated vendor’s website such as emoney or MoneyGuidePro and the site provides access to
information and/or concepts, including financial planning, the client, should not, in any manner whatsoever, infer
that
such access is a substitute for services provided by WBH. Rather, if the client utilizes any such content, the client
does so separate and independent of WBH.
Use of Pontera Platform. WBH uses the Pontera platform made available by Pontera Solutions, Inc. (“Pontera”), a
third party online platform, to assist with management of clients’ “held away” accounts, including 401(k)s, 403(b)s,
annuities, and 529 education savings plans, and as an order management system for such accounts where WBH may
implement tax-efficient asset location and opportunistic rebalancing strategies on behalf of the client. Once the
client’s account(s) is connected to the platform, WBH will review the client’s current account allocations. Registrant
will rebalance the connected outside accounts consistent with the client’s investment goals and risk tolerance. Client
account(s) will be reviewed at least quarterly. The specific fee schedule charged by WBH for account management of
held away assets is established in the client’s written agreement with WBH. To facilitate use of the Pontera platform,
the client securely logs into the Pontera site and entitles WBH to manage the assets. Pontera charges WBH 25 bps
for each managed account. Clients do not pay any additional fee to Pontera or to WBH in connection with platform
participation. WBH is not affiliated with the Pontera platform in any way and receives no compensation from them
for using their platform.
Please Note: Socially Responsible Investing Limitations. Socially Responsible Investing involves the incorporation of
Environmental, Social and Governance considerations into the investment due diligence process (“ESG”). ESG investing
incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e., considers how a
company safeguards the environment); Social (i.e., the manner in which a company manages relationships with its
employees, customers, and the communities in which it operates); and Governance (i.e., company management
considerations). The number of companies that meet an acceptable ESG mandate can be limited when compared to
those that do not, and could underperform broad market indices. Investors must accept these limitations, including
potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange-traded funds are
limited when compared to those that do not maintain such a mandate. As with any type of investment (including any
investment and/or investment strategies recommended and/or undertaken by WBH), there can be no assurance that
investment in ESG securities or funds will be profitable, or prove successful. WBH does not maintain or advocate an
ESG investment strategy, but will seek to employ ESG if directed by a client to do so. If implemented, WBH shall rely
upon the assessments undertaken by the unaffiliated mutual fund, exchange traded fund or separate account portfolio
manager to determine that the fund’s or portfolio’s underlying company securities meet a socially responsible
mandate. WBH does not maintain or advocate an ESG investment strategy, but will seek to employ ESG if directed by
a client to do so.
Borrowing Against Assets/Risks. A client who has a need to borrow money could determine to do so by using:
Pledged Assets Loans- In consideration for a lender (i.e., a bank, etc.) to make a loan to the client, the client pledges
its investment assets held at the account custodian as collateral. These above-described collateralized loans are
generally utilized because they typically provide more favorable interest rates than standard commercial loans. These
types of collateralized loans can assist with a pending home purchase, permit the retirement of more expensive debt,
or enable borrowing in lieu of liquidating existing account positions and incurring capital gains taxes. However, such
loans are not without potential material risk to the client’s investment assets. The lender (i.e. custodian, bank, etc.) will
have recourse against the client’s investment assets in the event of loan default or if the assets fall below a certain
level. For this reason, WBH does not recommend such borrowing unless it is for specific short-term purposes (i.e. a
bridge loan to purchase a new residence). WBH does not recommend such borrowing for investment purposes (i.e. to
invest borrowed funds in the market). Regardless, if the client was to determine to utilize margin or a pledged assets
loan, the following economic benefits would inure to WBH:
• by taking the loan rather than liquidating assets in the client’s account, WBH continues to earn a fee on
such Account assets; and,
• if the client invests any portion of the loan proceeds in an account to be managed by WBH, WBH will receive
an advisory fee on the invested amount
Please Note: The Client must accept the above risks and potential corresponding consequences associated with the
use of pledged assets loans.
Client Obligations. In performing our services, WBH shall not be required to verify any information received from the
client or from the client’s other professionals, and is expressly authorized to rely on that information. Each client is
responsible for promptly notifying us if the is ever any change in their financial situation or investment objectives so
that we can review, and if necessary, revise our previous recommendations.
Portfolio Activity. WBH has a fiduciary duty to provide services consistent with the client’s best interest. WBH 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, market conditions, fund manager tenure, style drift, account
additions/withdrawals, and/or a change in the client’s investment objective(s). Based upon these factors, there may
be extended periods of time when WBH determines that changes to a client’s portfolio are neither necessary, nor
prudent. Clients remain subject to the fees described in Item 5 below during periods of account inactivity. Of course,
as indicated below, there can be no assurance that investment decisions made by WBH will be profitable or equal
any specific performance level(s).
Bitcoin, Cryptocurrency, and Digital Assets: For clients who want exposure to cryptocurrencies and digital assets,
including Bitcoin, WBH will advise the client to consider a potential investment in corresponding exchange traded
securities.. Cryptocurrencies are digital assets that can be used to buy goods and services and use an online ledger
with strong cryptography (i.e., a method of protecting information and communications through the use of codes) to
secure online transactions. Unlike conventional currencies issued by a monetary authority, cryptocurrencies are
generally not controlled or regulated, and their price is determined by the supply and demand of their market.
Because cryptocurrency is currently considered to be a speculative investment WBH will not exercise discretionary
authority to purchase a cryptocurrency investment for client accounts. Rather, a client must expressly authorize the
purchase of the cryptocurrency investment. Please Note: WBH does not recommend or advocate the purchase of, or
investment in, cryptocurrencies. The Registrant considers such an investment to be speculative
ERISA PLAN and 401(k) INDIVIDUAL ENGAGEMENTS:
• Trustee Directed Plans. WBH may be engaged to provide discretionary investment advisory services to ERISA
retirement plans, whereby the Firm shall manage Plan assets consistent with the investment objective
designated by the Plan trustees. In such engagements, WBH will serve as an investment fiduciary as that term
is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”). WBH will generally provide
services on an “assets under management” fee basis per the terms and conditions of an Investment Advisory
Agreement between the Plan and the Firm.
• Participant Directed Retirement Plans. WBH may also provide investment advisory and consulting services to
participant directed retirement plans per the terms and conditions of a Retirement Plan Services Agreement
between WBH and the plan. For such engagements, WBH shall assist the Plan sponsor with the selection of an
investment platform from which Plan participants shall make their respective investment choices (which may
include investment strategies devised and managed by WBH), and, to the extent engaged to do so, may also
provide corresponding education to assist the participants with their decision making process.
• Client Retirement Plan Assets. If requested to do so, WBH shall provide investment advisory services relative
to 401(k) plan assets maintained by the client in conjunction with the retirement plan established by the client’s
employer. In such event, WBH shall allocate (or recommend that the client allocate) the retirement account
assets among the investment options available on the 401(k) platform. WBH’s ability shall be limited to the
allocation of the assets among the investment alternatives available through the plan. WBH will not receive
any communications from the plan sponsor or custodian, and it shall remain the client’s exclusive obligation to
notify WBH of any changes in investment alternatives, restrictions, etc. pertaining to the retirement account.
WBH does not maintain client 401(k) account passwords.
Please Note: Cash Positions. WBH continues to treat cash as an asset class. As such, unless determined to the
contrary by WBH, all cash positions (money markets, etc.) shall continue to be included as part of assets under
management for purposes of calculating WBH’s advisory fee. At any specific point in time, depending upon perceived
or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events
will occur), WBH may maintain cash positions for defensive purposes. In addition, while assets are maintained in
cash, such amounts could miss market advances. Depending upon current yields, at any point in time, WBH’s advisory
fee could exceed the interest paid by the client’s money market fund. In certain instances, as negotiated BY WBH and
the client, and where cash is not part of the managed portfolio, WBH may waive this portion of the client’s fee. ANY
QUESTIONS: WBH’s Chief Compliance Officer, Marc Hertzberg, remains available to address any questions that a
client or prospective may have regarding the above fee billing practice
Schwab Cash Sweep Accounts.
Account custodian, such as Schwab, generally require that cash proceeds from account transactions or cash deposits
be swept into and/or initially maintained in the custodian’s sweep account. The yield on the sweep account is
generally lower than those available in money market accounts. To help mitigate this issue, Registrant shall generally
purchase a higher yielding money market fund available on the custodian’s platform with cash proceeds or deposits,
unless WBH reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to
purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with
respect to all or a portion of the cash balances for various reasons, including, but not limited to, the amount of
dispersion between the sweep account and a money market fund, the size of the cash balance, an indication from
the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the
account.
Please Note: The above does not apply to the cash component maintained within WBH’s actively managed
investment strategy (the cash balances for which shall generally remain in the custodian designated cash sweep
account), an indication from the client of a need for access to such cash, assets allocated to an unaffiliated investment
manager, and cash balances maintained for fee billing purposes. Please also Note: The client shall remain exclusively
responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained
in any of the Registrant’s unmanaged accounts.
ANY QUESTIONS: WBH’s Chief Compliance Officer, Marc Hertzberg, remains available to address any questions that
a client or prospective client may have regarding the above.
Disclosure Statement
A copy of the Registrant’s written Brochure as set forth on Part 2A of Form ADV, along with Form CRS, shall be
provided to each client prior to, or contemporaneously with, the execution of the Investment Advisory Agreement or
Financial Planning and Consulting Agreement.
Please Note: Investment Risk. Different types of investments involve varying degrees of risk, and it should not be
assumed that future performance of any specific investment or investment strategy (including the investments
and/or investment strategies recommended or undertaken by Registrant) will be profitable or equal any specific
performance level(s).