Westwood Advisors, LLC (“Westwood Advisors,” “Westwood,” “Advisor”, “we” or “us”)
(formerly known as McCarthy Group Advisors, LLC) is an investment advisory firm that has been
in business since 1986. In November 2010, Westwood Advisors was acquired by Westwood
Holdings Group, Inc. (“WHG”), a publicly held company listed on the New York Stock Exchange
since July 1, 2002. WHG is also the owner of Westwood Management Corp. (“Westwood
Management”), a registered investment advisor that has been in business since 1983; Salient
Advisors, LP, a registered investment advisor and Westwood Trust, a Texas-chartered Trust
company headquartered in Dallas, Texas. Westwood Advisors, Westwood Management, Salient
Advisors, LP, and Westwood Trust are wholly owned by WHG.
On November 18, 2022, Westwood Holdings Group, Inc. completed its acquisition of the business
of Salient Partners, LP (“Salient”) and its subsidiaries (“Westwood Salient Transaction”). Pursuant
to the Westwood Salient Transaction, oversight and management of the Salient MLP Total Return
Fund, L.P. and Salient MLP Total Return TE Fund, LP was transferred to Westwood through the
approval of the limited partners of the funds of WHG PF Holdco, LLC as the General Partner for
the funds and the assignment of the advisory agreement to Westwood Advisors. Westwood
Advisors has delegated investment management responsibilities of the Salient MLP Total Return
Fund, LP and the Salient MLP Total Return TE Fund, LP to its affiliate, Westwood Management.
Salient, based in Houston, Texas, with an office in San Francisco, California, provided investment
advisory services through Salient Capital Advisors, LP and Forward Securities, LLC (“Forward”),
both SEC-registered investment advisors. Pursuant to the Westwood Salient Transaction, WHG
and its subsidiaries acquired substantially all of the assets of Salient and its subsidiaries. Generally,
investment advisory agreements with Salient Capital Advisors, LLC, and Forward were assigned
to Westwood Management upon client notice and consent. In addition, WHG purchased all equity
ownership in Salient Capital Advisors, LLC, Salient Capital, LP, and Forward, as well as Salient’s
equity ownership in The Salient Zarvona Energy Fund GP, LP. Forward ceased substantially all
operations shortly after the Westwood Salient Transaction. Forward was subsequently deregistered
in June of 2023 and officially dissolved in August of 2023.
As a result of the Westwood Salient Transaction, WHG purchased all of Salient’s minority interest
in Broadmark Asset Management, LLC. WHG purchased additional equity ownership in January
2023, giving WHG a majority ownership stake in Broadmark Asset Management LLC.
As of December 31, 2023, Westwood Advisors managed approximately 336 accounts on a
discretionary basis with an approximate total value of $433,271,448.
We market our services as Westwood Wealth Management. Westwood Wealth Management is a
division of WHG, which offers trust and fiduciary services through Westwood Trust and investment
advisory services through Westwood Advisors.
Westwood WealthCoach™
The Westwood WealthCoach program (the “Program”) is an advisory service offered by WHG’s
Wealth Management division. WHG’s Wealth Management division offers trust and fiduciary
services through Westwood Trust, a Texas trust company, and investment advisory services
through Westwood Advisors. Westwood Trust and Westwood Advisors are both wholly owned
subsidiaries of WHG.
The Program is primarily offered to individual clients who sign up through the Westwood
WealthCoach website portal (“WealthCoach Portal”). Certain existing trust and fiduciary clients
of Westwood Trust may initially enroll in the Program in coordination with their Westwood Trust
representative.
Each account managed in the Program is a custodial account established by the Client at an
approved custodian. Currently, the only approved custodian for the Program is Charles Schwab.
Additional custodians may be added in the future.
Allocation Models
Allocation models are limited to mutual funds and ETFs. The asset allocation models may use
Westwood Funds mutual funds which are managed by Westwood Management, an affiliate of
Westwood Advisors.
Within each type of investment strategy, Westwood Advisors manages accounts using an
allocation model which corresponds to one of five risk levels:
• Conservative
• Moderate
• Enhanced Balanced®
• Growth
• Aggressive
Asset Allocation Committee
The allocation models are subject to review and oversight by the Westwood Wealth Management
Asset Allocation Committee (“Allocation Committee”). The purpose of the Allocation Committee
is to prepare a Strategic Asset Allocation Model from which multiple investment models will be
derived. The Allocation Committee meets on at least a quarterly basis. The Allocation Committee
reviews and recommends changes to the Enhanced Balance® model based on investment time
horizons, risk tolerance and other factors. Upon approval, the Westwood Advisors investment
team translates the Enhanced Balanced® allocation model updates to the Conservative, Moderate,
Growth and Aggressive allocation models to reflect the weighting changes. The Allocation
Committee is comprised of Westwood Advisors representatives, other Westwood related members
and independent members.
Investment Oversight Committee
The purpose of the Investment Oversight Committee (the “Oversight Committee”) is to select the
appropriate mutual funds or exchange traded funds (“ETFs”) for each asset class represented in
the allocation models. The Oversight Committee meets on at least a quarterly basis. The Oversight
Committee is comprised of Westwood Advisors representatives and other Westwood related
members.
Enrolling in the Program
Clients enrolling in the Program use the online WealthCoach Portal to determine whether
participating in the Program is appropriate for them, to select the client’s preferred type of
allocation strategy and to obtain a recommended allocation model based on each client’s risk
profile. To establish an account in the Program, clients must use the WealthCoach Portal to
complete their client profile and answer the risk tolerance questionnaire. Based on the information
provided in the risk tolerance questionnaire, the WealthCoach Portal generates an allocation
proposal.
Clients are generally restricted to the allocation model corresponding to their risk profile. Clients
can change their allocation model by updating their risk profile information. However, Westwood
Advisors may permit clients to invest in another allocation model after consultation with a
representative of Westwood Advisors. In rare cases, Westwood Advisors may create a custom
allocation for a client upon request or may refer clients to participate in another advisory program
of Westwood Advisors or an affiliate, if appropriate.
A client can impose restrictions on specific mutual funds or ETFs. To do so, client should contact
a Westwood Advisors representative. If the restriction request cannot be accommodated,
Westwood Advisors may establish an account in another advisory program of Westwood Advisors
or an affiliate, if appropriate.
Investment advice in the Program is tailored to the individual needs of clients through the use of
each client’s risk profile as generated through the WealthCoach Portal, each client’s selected
allocation strategy and any input or customization provided by a Westwood Advisors
representative upon request.
As a condition of participating in the Program, clients must agree to receive documents and
disclosures electronically and to use the electronic signature features of the WealthCoach Portal.
Clients are responsible for ensuring that they maintain access to the email address used to
communicate about the Program and to ensure that clients can access the WealthCoach Portal and
download and read any documents or disclosures.
Westwood Advisors may add additional allocation strategies, allocation models or investment
strategy types available in the Program or modify the existing ones at any time without prior notice
to clients. The Westwood WealthCoach Program utilizes a flat, asset-based fee (“WealthCoach
Advisory Fee”) that covers investment advice, portfolio management, administration, custodial
and brokerage delivered by the Program, its technology service providers and its other designees
as part of the Program. Client is charged the same Advisory Fee Rate regardless of the allocation
model selected.
The WealthCoach Advisory Fee does not cover transaction fees imposed by the Custodian related
to the purchase or sale of securities, which will be incurred when an account is rebalanced.
Transaction fees will vary depending on the nature of the security being transacted. Transaction
fees will be deducted by the Custodian at the time of the transaction. Westwood does not receive
any portion of the transaction fees.
Westwood Advisors launched the Westwood WealthCoach Program in September 2017. As of
December 31, 2023, the Westwood WealthCoach Program had approximately 78 accounts and
$10,256,261in assets under management.
The WealthCoach Portal
Westwood Advisors has integrated software and other technology services from AdvisorEngine,
Inc. (“AdvisorEngine”) into the WealthCoach Portal to facilitate the new account documentation
process, risk tolerance questionnaire responses and investment allocation proposals.
AdvisorEngine’s technology is provided to Westwood Advisors by AdvisorEngine pursuant to an
agreement with Westwood Advisors.
The questions on the risk tolerance questionnaire are determined by Westwood Advisors, and the
parameters for creating an allocation proposal based on a client’s risk profile are implemented on
the WealthCoach Portal based on Westwood Advisors’ direction.
Management of WealthCoach Accounts
Clients use the WealthCoach Portal to review and update their profile as well as their risk profile.
Client requests for certain changes to their account profiles (such as contact information) or
requests for transferring funds are monitored by Westwood Advisors personnel and may require
approval by Westwood Advisors.
The risk tolerance responses are reconfirmed by the client each year through the WealthCoach
portal or in consultation with a Westwood Advisors representative.
The ongoing management of the accounts in the Program and client reporting is conducted using
software and services from AdvisorEngine pursuant to an agreement between AdvisorEngine and
Westwood Advisors. These services have been implemented by Westwood Advisors to facilitate
management of accounts in the Program (the “WealthCoach Account Platform”). AdvisorEngine’s
sole role in the Program is as a technology service provider to Westwood Advisors. AdvisorEngine
does not provide any investment advisory services to Westwood Advisors or clients participating
in the Program. The software that Westwood Advisors uses from AdvisorEngine is licensed by
Westwood but is owned by AdvisorEngine. Certain functionality of the AdvisorEngine software
has been incorporated into the WealthCoach Portal to provide clients with information and reports
about their account, including portfolio value, performance reports, custodial statements and
billing information.
The WealthCoach account platform is used by Westwood Advisors for trade order management,
monitoring the investment allocations, performance calculations and reporting, and generating the
billing information for the custodians. Westwood Advisors monitors investment allocations in
each account using the WealthCoach account platform and generates trades to maintain proper
asset allocation. Westwood Advisors personnel review trades at an aggregate level and, once
approved, trades are sent to the custodian for execution.
The Platform will monitor client’s account daily on an automated basis, while Westwood
Advisors will typically cause a rebalancing of the account either quarterly or on a more frequent
basis to achieve the Program’s target
allocation in an effort to optimize returns for the intended
level of risk. The rebalancing threshold may differ for certain custom portfolios. At least on a
quarterly basis, or more frequently if requested by Client, a Westwood Advisors representative
will review client’s Account, to verify that the investment allocations are in line with the asset
allocation model targets, that client’s risk tolerance responses are still valid and that all reporting
(e.g., performance, statements and tax documents) has been generated and provided to Client.
Westwood Advisors personnel periodically review accounts, individually and at the aggregate
level, to ensure that the investment allocations are in line with their targets, that the risk tolerance
responses are still valid and that all reporting (performance, statements and tax documents) have
been completed.
Updating Client Information
Clients should review their investment goals and objectives at least quarterly. Clients should
update their information whenever their investment goals and objectives change significantly.
Clients will be asked to update or confirm their investment goals and objectives and other personal
information at least annually. Generally, clients will be directed to update information through the
WealthCoach Portal. Clients may also contact a Westwood Advisors representative to discuss or
to update any information.
Reporting
Westwood Advisors creates reports for WealthCoach clients, which include a summary of the asset
allocation, performance by account and by asset class, and a summary of account activity.
WealthCoach account reports are available quarterly by default or monthly upon the request of a
client. These reports are available to clients through the WealthCoach Portal and may be made
available through custodians as well. Clients should compare their WealthCoach statement with
their custodial statements.
Westwood Advisors participates as an advisor on certain brokerage platforms through which
Westwood Advisors offers the separate account strategies of its affiliate, Westwood Management,
using model portfolios provided by Westwood Management. Westwood Advisors provides an
additional layer of advisory services to help clients select one or more Westwood strategies, to
periodically review client accounts and consult with clients about the Westwood strategies.
Investment advisory services in the Retail Account Program are individually tailored to the needs
of clients through the initial and ongoing consultation between a Westwood Advisors
representative and the client and through coordination and customization in the sub-advisory
relationship with Westwood Management.
Westwood Advisors typically implements and monitors a client’s guidelines by entering
restrictions in our electronic guideline monitoring tool that interfaces with our trade order
management system. The system is used by Westwood Advisors’ and Westwood Management’s
trading and compliance teams to perform daily and real-time monitoring. Restrictions may also be
monitored manually if needed. In addition, Westwood Advisors reviews all accounts annually to
ensure that the investment guidelines are current and correctly entered in the guideline monitoring
tool. A client can impose restrictions on specific equities. To do so, client should contact a
Westwood Advisors representative.
Westwood Advisors commenced offering advisory services through the Retail Account Program
(previously referred to as the Direct Advisory Program) starting in August 2017. As of December
31, 2023, the Retail Account Program had approximately 295 accounts and $202,022,179in assets
under management.
Client online access and reporting is made available through the custodians’ platforms. Westwood
Advisors is responsible for monitoring and rebalancing the accounts and providing performance
reporting to the client at least quarterly. The onboarding process for this program requires
communication with the client, manual preparation of the new account documents and approval of
the proposed investment allocation.
Trading in Multi-Asset SMA Accounts: Income Opportunity SMA, High Income SMA and
Total Return SMA Accounts
Westwood generally updates and trades accounts assigned to the following multi-assets strategies
once a month: Income Opportunity SMA, High Income SMA and Total Return SMA. These Multi-
Asset SMA strategies are traded as separate strategies from their respective institutional strategies
and trades for the same security are not typically subject to aggregation or rotation with
institutional accounts.
Financial Planning and Consultative Services
In addition to investment advisory services, Westwood Advisors may provide financial planning
services to some of its clients. These services seek to develop long-term strategies tailored to the
needs of the individual client, requiring client meetings to conduct a comprehensive review of the
client’s current financial situation. A review of the client’s current investment statements,
insurance products, estate planning documents, budget and employee benefit packages is necessary
to understand the client’s financial situation and provide financial planning services.
The goal of financial planning services is to determine the adequacy of existing trust and estate
planning, retirement planning, charitable giving, and business succession planning. If appropriate
for the individual client, recommendations are made to further the client’s financial goals and
objectives. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) may be engaged
by Westwood Advisors under the direction of the client on an as-needed basis for the purpose of
carrying out the client’s objectives.
Financial advisory consultative services and consulting recommendations may pose a potential
conflict of interest between Westwood Advisors and the client. For example, a recommendation
to engage Westwood Advisors for investment management services or a recommendation to
increase the level of investment assets with Westwood Advisors would pose a conflict of interest
as it would increase the advisory fees paid to Westwood Advisors. Westwood Advisors has sought
to address these potential conflicts through disclosure - by making it clear to clients that they are
under no obligation to implement any recommendations made by Westwood Advisors. If clients
elect to act on any of the recommendations made by Westwood Advisors, clients are under no
obligation to execute the transaction through or invest additional assets with Westwood Advisors.
Employer Sponsored Retirement Plan Services
Westwood Advisors generally acts as a 3(21) or 3(38) fiduciary to employer sponsored retirement
plans. Westwood Advisors provides services to employer sponsored retirement plans (the “Plan”)
including defined benefit pension plans, 401(k), and profit-sharing plans, and the Plan’s
management personnel (the “Plan Client”), with a range of discretionary and non-discretionary
services, including:
• Discretionary selection of the investment options available to the Plan participants in
accordance with the Plan’s investment policies and objectives, including the
accommodation of restricting specific equities at a Plan Client’s request, and consistent
with the Employee Retirement Income Security Act of 1974 (“ERISA”) Section 404(c)
and the regulations thereunder.
• Provide non-discretionary investment advice to the Plan Client about asset classes,
benchmarks, asset allocations, investment option fees and investment alternatives available
to the Plan in accordance with the Plan’s investment policies and objectives.
• Assist the Plan Client in the development of an investment policy statement (“IPS”).
• Assist in monitoring investment options by preparing quarterly investment reports that
document investment performance, consistency of fund management and conformance to
the guidelines set forth in the IPS and make recommendations to maintain or remove and
replace investment options.
• Meet or consult with the Plan Client at least annually to discuss investment reports,
investment options or other services.
• Provide non-discretionary investment advice to the Plan sponsor with respect to the
selection of a qualified investment alternative (“QDIA”) for participants who are
automatically enrolled in the Plan or who otherwise fail to make an investment election.
Employer sponsored retirement plan services are specific to each client and are based on the Plan
Client’s objectives, strategy for the Plan, investment committee involvement and participant needs
and preferences, as well as other factors.
Custody of all Plan assets will be maintained with a third party custodian selected by the Plan’s
sponsor, and Plan recordkeeping will be provided by a third party recordkeeper selected by the
Plan’s sponsor. The Plan’s sponsor is responsible for paying all fees or charges of the custodian
and recordkeeper. Westwood Advisors does not monitor or oversee recommendations or services
rendered by third party service providers or the third party service providers’ compliance with
applicable laws.
The Plan’s custodian, recordkeeper or sponsor is responsible for arranging for the execution of
securities transactions through a broker-dealer it believes can provide best execution. Sponsor
acknowledges that, in the performance of employer sponsored retirement plan services, Westwood
Advisors will not have any discretionary authority or responsibility over the administration of the
Plan or for the interpretation of Plan documents, the determination of participant eligibility,
benefits, vesting, or the approval of the distributions to be made by the Plan.
Westwood Advisors does not provide any services to the Plan or Plan sponsor other than the
services expressly agreed to in the executed investment advisory agreement.
Westwood Advisors does not provide the services as a fiduciary to an investment contract, product
or entity that holds the Plan assets; nor does it perform recordkeeping or brokerage services to the
Plan. Westwood Advisors will not and cannot provide legal or tax advice to the Plan sponsor and/or
the Plan (or any Plan participant or beneficiary).
Westwood Advisors’ affiliate, Westwood Management, manages the Westwood Funds family of
mutual funds. Westwood Advisors may cause ERISA accounts to become invested in the
Westwood Funds. If ERISA accounts are invested in Westwood Funds, Westwood Advisors will
not charge ERISA accounts a fee for investment management or other fiduciary services provided
to the ERISA accounts on the potion of the assets in the ERISA accounts that are so invested. For
ERISA accounts to be eligible to invest in Westwood Funds, clients are required to execute the
Affiliated Funds Addendum to the Investment Advisory Agreement.
Private Investment Funds
When appropriate, Westwood Advisors may recommend that qualified clients consider allocating
a portion of their investment assets to certain affiliated or unaffiliated private investment funds
and other opportunistic investments. Westwood Advisors’ role relative to the private investment
funds is typically limited to its sourcing of private investment opportunities, initial and ongoing
due diligence and investment monitoring services. The terms and conditions for participation in
these funds, including fund management fees, minimum investment, conflicts of interest, and
specific risk factors to consider, are set forth in each fund’s offering documents. Westwood
Advisors currently provides advisory services on private investment funds offered through a Series
LLC structure, partnerships, directly to the Salient MLP Total Return TE Fund, LP, and the Salient
MLP Total Return Fund, LP (“MLP Funds”), as well as indirectly through third party funds.
Before investing in private investment funds, clients should carefully review Westwood Advisors’
Private Funds Advisory Services Brochure and all relevant offering documents.