Since 2004, Wealthstream has been in business as a registered investment adviser, which
specializes in providing financial planning and investment management services to individuals,
and high net worth clients Wealthstream is driven by its mission to meet the high standard of
quality and service that its clients deserve and expect.
Wealthstream is owned by a select group of its employees including Michael Goodman,
President who owns greater than 25% of the Firm.
Financial Planning Services
Wealthstream may provide its clients with a broad range of financial planning services, which
may include advice on non-investment related matters. Wealthstream crafts a personal
financial profile for its clients, illustrating their financial goals and assets. Generally, these
financial plans address a broad range of personal matters, including cash flow needs,
investment growth, savings strategies, personal investment preferences, individual risk
tolerance, as well as retirement, estate, tax, debt, educational and insurance planning.
While certain of Wealthstream’s financial planning services may be rendered as part of a wealth
management arrangement (in conjunction with portfolio management, as explained below),
Wealthstream may also provide financial plans as a standalone service offering.
In performing its services, Wealthstream is not required to verify any information received from
the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is
expressly authorized to rely on such information. Wealthstream may recommend the services
of itself and/or other professionals to implement its recommendations. Clients are advised that
a conflict of interest exists if Wealthstream recommends its own services. The client is under no
obligation to act upon any of the recommendations made by Wealthstream under a financial
planning engagement or to engage the services of any such recommended professional,
including Wealthstream itself. The client retains absolute discretion over all such
implementation decisions and is free to accept or reject any of Wealthstream’s
recommendations. Clients are advised that it remains their responsibility to promptly notify
Wealthstream if there is ever any change in their financial situation or investment objectives for
the purpose of reviewing, evaluating, or revising the firm’s previous recommendations and/or
services.
Investment Management and Wealth Management Services
Clients can engage Wealthstream to manage all or a portion of their assets on a discretionary
basis, which may include a broad range of financial planning services.
Wealthstream primarily allocates clients’ investment management assets among Independent
Managers (as defined below), mutual funds, exchange-traded funds (“ETFs”), exchange-traded
notes (“ETNs”), individual debt and equity securities and/or options, as well as the securities
components of variable annuities in accordance with the investment objectives of the client.
In addition, Wealthstream may render investment management services to clients relative to
variable life/annuity products that they may own, their individual employer-sponsored
retirement plans, and/or 529 plans or other products that may not be held by the client’s
primary custodian. In so doing, Wealthstream either directs or recommends the allocation of
client assets among the various investment options that are available with the product. Client
assets are maintained at the specific insurance company or custodian designated by the
product.
Tailored Relationships
Wealthstream tailors its advisory services to the individual needs of clients. Wealthstream
consults with clients initially and on an ongoing basis to determine risk tolerance, time horizon
and other factors that may impact the clients’ investment needs.
Clients are advised to promptly notify Wealthstream if there are changes in their financial
situation or investment objectives or if they wish to impose any reasonable restrictions upon
Wealthstream’s management services. Clients may impose reasonable restrictions or mandates
on the management of their account (e.g., require that a portion of their assets are invested in
sustainable funds) if, in Wealthstream’s sole discretion, such conditions would not materially
impact the performance of a portfolio strategy or prove overly burdensome to its management
efforts.
Retirement Rollovers-Potential for Conflict of Interest
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 Wealthstream recommends that a client
roll over their retirement plan assets into an account to be managed by Wealthstream, such a
recommendation creates a conflict of interest if Wealthstream will earn an advisory fee on the
rolled over assets. No client is under any obligation to rollover retirement plan assets to an
account managed by Wealthstream. Wealthstream Advisory team remains available to address
any questions that a client or prospective client may
have regarding the potential for conflict of
interest presented by such rollover recommendation.
Retirement Plans
Wealthstream will provide consulting services to qualified retirement plans and their fiduciaries
based upon an analysis of the needs of the plan. In general, these services may include an
existing plan review, assistance in the development of a retirement plan, evaluation of
retirement plan vendors, asset allocation advice, communication, and education services to
plan participants, investment performance monitoring, and/or ongoing consulting.
Wealthstream will provide consulting services to the plan fiduciaries as described above.
Typically, the named plan fiduciary must make the ultimate decision as to retaining the services
of such investment advisers as Wealthstream recommends. The plan fiduciary is free to seek
independent advice about the appropriateness of any recommended services for the plan.
Use of Independent Managers
As mentioned above, Wealthstream recommends that certain clients authorize the active
discretionary management of a portion of their assets by and/or among certain independent
investment managers (“Independent Managers”), based upon the stated investment objectives
of the client. The terms, compensation, and conditions under which the client engages the
Independent Managers are set forth in a separate written agreement between the client and
the designated Independent Managers.
Wealthstream renders services to the client relative to the discretionary and/or non-
discretionary selection or recommendation of Independent Managers. Wealthstream also
monitors and reviews the account performance and the client’s investment objectives.
When recommending or selecting an Independent Manager for a client, Wealthstream reviews
information about the Independent Manager such as its disclosure statement and/or material
supplied by the Independent Manager or independent third parties for a description of the
Independent Manager’s investment strategies, past performance and risk results to the extent
available. Factors that Wealthstream considers in selecting or recommending an Independent
Manager include the client’s stated investment objectives, management style, performance,
reputation, reporting, pricing, and research. The investment management fees charged by the
designated Independent Managers, together with the fees charged by the corresponding
designated broker-dealer/custodian of the client’s assets, may be exclusive of, and in addition
to, Wealthstream’s investment advisory fee.
In addition to Wealthstream’s written disclosure brochure, the client also receives the written
disclosure brochure of the designated Independent Managers. Certain Independent Managers
may impose more restrictive account requirements and varying billing practices than
Wealthstream. In such instances, Wealthstream may alter its corresponding account
requirements and/or billing practices to accommodate those of the Independent Managers.
Fiduciary Statement
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment
advice to you regarding your retirement plan account or individual retirement account, we are
also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act,
(“ERISA”) and/or the Internal Revenue Code, (“IRC”), as applicable, which are laws governing
retirement accounts.
We have to act in your best interest and not put our interest ahead of yours. At the same time,
the way we make money creates some conflicts with your interests. We must take into
consideration each client’s objectives and act in the best interests of the client. We are
prohibited from engaging in any activity that is in conflict with the interests of the client. We
have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial
circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented
in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to
provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably.
Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material
fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as
fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client.
We will act with competence, dignity, integrity, and in an ethical manner, when working with
clients. We will use reasonable care and exercise independent professional judgement when
conducting investment analysis, making investment recommendations, trading, promoting our
services, and engaging in other professional activities.
Wrap Fee Programs
Wealthstream does not participate in a Wrap Fee Program.
Client Assets
As of December 31, 2023, Wealthstream had $1,347,237,878 in assets under management, all
of which are managed on a discretionary basis.