View Document Text
Item 1: Cover Page
Part 2A of Form ADV: Firm Brochure
March 2025
11421 W Bernardo Court
San Diego, CA 92127
www.BetaWealthGroup.com
Firm Contact:
Romy Brown
Chief Compliance Officer
This brochure provides information about the qualifications and business practices of Beta
Wealth Group, Inc. If you have any questions about the contents of this brochure, please
contact us by telephone at 858‐207‐3377 or email romy@betawealthgroup.com. The
information in this brochure has not been approved or verified by the United States Securities
and Exchange Commission or by any State Securities Authority. Additional information about
Beta Wealth Group, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov by
searching CRD # 165224.
Please note that the use of the term “registered investment adviser” and description of Beta
Wealth Group, Inc., and/or our associates as “registered” does not imply a certain level of skill
or training. You are encouraged to review this Brochure and Brochure Supplements for our
firm’s associates who advise you for more information on the qualifications of our firm and
our employees.
Item 2: Material Changes
Beta Wealth Group, Inc is required to notify clients of any information that has changed since the last
annual update of the Firm Brochure (“Brochure”) that may be important to them. Clients can request
a full copy of our Brochure or contact us with any questions that they may have about the changes.
Since the last annual amendment filed on 03/26/2024, the following changes have been made:
We updated our Regulatory Assets Under Management in Item 4.
We updated the Comprehensive Portfolio Management Section of Item 5 Fees & Compensation.
o The Comprehensive Portfolio Management Section has been completely updated.
o A few of the material changes to the Comprehensive Portfolio Management Fee Schedule
are as follows:
Added an Asset Under Management minimum of $250,000
Added to the Assets Under Management Tiers
Adjusted the Annual Fee Percentages for Assets Under Management under
$400,000 and over $8,000,000.
ADV Part 2A – Firm Brochure
Page 2
Beta Wealth Group, Inc.
Item 3: Table of Contents
Item 1: Cover Page .................................................................................................................................... 1
Item 2: Material Changes ......................................................................................................................... 2
Item 3: Table of Contents ......................................................................................................................... 3
Item 4: Advisory Business ....................................................................................................................... 4
Item 5: Fees & Compensation ................................................................................................................. 7
Item 6: Performance‐Based Fees & Side‐By‐Side Management ..................................................... 10
Item 7: Types of Clients & Account Requirements ........................................................................... 10
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss .............................................. 10
Item 9: Disciplinary Information ......................................................................................................... 12
Item 10: Other Financial Industry Activities & Affiliations ............................................................ 12
Item 11: Code of Ethics, Participation or Interest in ........................................................................ 12
Client Transactions & Personal Trading ............................................................................................ 12
Item 12: Brokerage Practices ............................................................................................................... 13
Item 13: Review of Accounts or Financial Plans ............................................................................... 16
Item 14: Client Referrals & Other Compensation ............................................................................. 16
Item 15: Custody ...................................................................................................................................... 18
Item 16: Investment Discretion............................................................................................................ 19
Item 17: Voting Client Securities .......................................................................................................... 19
Item 18: Financial Information ............................................................................................................ 19
ADV Part 2A – Firm Brochure
Page 3
Beta Wealth Group, Inc.
Item 4: Advisory Business
We are dedicated to providing individuals and other types of clients with a wide array of investment
advisory services. Our firm is a corporation formed in the State of California. Our firm has been in
business since 2009 and an investment adviser since 2012. Our firm is owned by Jodi Vleck and
Michael Vleck.
The purpose of this Brochure is to disclose the conflicts of interest associated with the investment
transactions, compensation and any other matters related to investment decisions made by our firm
or its representatives. As a fiduciary, it is our duty to always act in the client’s best interest. This is
accomplished in part by knowing our client. Our firm has established a service-oriented advisory
practice with open lines of communication for many different types of clients to help meet their
financial goals while remaining sensitive to risk tolerance and time horizons. Working with clients to
understand their investment objectives while educating them about our process, facilitates the kind
of working relationship we value.
Types of Advisory Services We Offer
Comprehensive Portfolio Management:
Our Comprehensive Portfolio Management service encompasses asset management as well as
providing financial planning/financial consulting to clients. It is designed to assist clients in meeting
their financial goals through the use of financial investments. We conduct at least one, but sometimes
more than one meeting (in person, if possible, otherwise via telephone or digital video conference)
with clients in order to understand their current financial situation, existing resources, financial
goals, and tolerance for risk. Based on what we learn, we propose an investment approach to the
client. We may propose an investment portfolio, consisting of exchange traded funds, mutual funds,
individual stocks or bonds, or other securities. Upon the client’s agreement to the proposed
investment plan, we work with the client to establish or transfer investment accounts so that we can
manage the client’s portfolio. Once the relevant accounts are under our management, we review such
accounts on a regular basis and at least quarterly. We may periodically rebalance or adjust client
accounts under our management. If the client experiences any significant changes to his/her financial
or personal circumstances, the client must notify us so that we can consider such information in
managing the client’s investments.
We may utilize Independent Money Managers, where we may design an investment portfolio and
provide ongoing corresponding comprehensive portfolio management services on a fee-only basis
for a percentage of assets in conjunction with another investment advisory firm. Before selecting
other advisers, we make sure that the other advisers are properly licensed or registered. Client may
grant our firm full discretionary authority and authorization to select and appoint one or more Money
Managers to provide investment advisory services with or without prior consultation. Such advisory
services will be as determined by our firm. These Money Managers shall have all of the same authority
relating to the management of Client’s investment accounts as is granted to our firm. In addition, at
our firm’s discretion, our firm may grant such Advisors full authority to further delegate such
discretionary investment authority to additional Money Managers.
ADV Part 2A – Firm Brochure
Page 4
Beta Wealth Group, Inc.
Financial Planning & Consulting:
We provide a variety of financial planning and consulting services to individuals, families and other
clients regarding the management of their financial resources based upon an analysis of the client’s
current situation, goals, and objectives. Generally, such financial planning services will involve
preparing a financial plan or rendering a financial consultation for clients based on the client’s
financial goals and objectives. This planning or consulting may encompass one or more of the
following areas: Investment Planning, Retirement Planning, Estate Planning, Charitable Planning,
Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study, Corporate
Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit
Evaluation, Business and Personal Financial Planning.
Our written financial plans or financial consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the clients. For example,
recommendations may be made that the clients begin or revise investment programs, create or revise
wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or
establish education or charitable giving programs. It should also be noted that we refer clients to an
accountant, attorney or other specialist, as necessary for non-advisory related services. For written
financial planning engagements, we provide our clients with a written summary of their financial
situation, observations, and recommendations. For financial consulting engagements, we usually do
not provide our clients with a written summary of our observations and recommendations as the
process is less formal than our planning service. Plans or consultations are typically completed within
6 months of the client signing a contract with us, assuming that all the information and documents
we request from the client are provided to us promptly. Implementation of the recommendations
will be at the discretion of the client.
Retirement Plan Consulting:
Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing
basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing,
monitoring and reviewing their company's participant-directed retirement plan. As the needs of the
plan sponsor dictate, areas of advising may include:
Establishing an Investment Policy Statement – Our firm will assist in the development of a
statement that summarizes the investment goals and objectives along with the broad
strategies to be employed to meet the objectives.
Investment Options – Our firm will work with the Plan Sponsor to evaluate existing
investment options and make recommendations for appropriate changes.
Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation
models to aid Participants in developing strategies to meet their investment objectives, time
horizon, financial situation and tolerance for risk.
Investment Monitoring – Our firm will monitor the performance of the investments and
notify the client in the event of over/underperformance and in times of market volatility.
Participant Education – Our firm will provide opportunities to educate plan participants
about their retirement plan offerings, different investment options, and general guidance on
allocation strategies.
In providing services for retirement plan consulting, our firm does not provide any advisory services
with respect to the following types of assets: employer securities, real estate (excluding real estate
funds and publicly traded REITS), participant loans, non-publicly traded securities or assets, other
ADV Part 2A – Firm Brochure
Page 5
Beta Wealth Group, Inc.
illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement
plan consulting services shall be in compliance with the applicable state laws regulating retirement
consulting services. This applies to client accounts that are retirement or other employee benefit
plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended
(“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to provide
services to such accounts, our firm acknowledges its fiduciary standard within the meaning of Section
3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to
the provision of services described therein.
Beta Wealth Group DBA Beta Asset Management – Institutional Advisory Services:
Advisory Programs
We provide asset management and consulting services to institutional clients based on our
proprietary investment strategies offered through Beta Wealth Group, Inc. dba Beta Asset
Management.
Beta Asset Management will act as the Advisor on those assets specified in the signed advisory
agreement. Beta Asset Management will construct a customized strategy using the Client’s assets
specified in the signed advisory agreement. Beta Asset Management will be responsible for
discretionary investment and reinvestment of those assets indicated in the customized strategy.
Sub‐Advisory Programs
We provide sub-management and consulting services to Clients of certain institutional clients based
on our proprietary investment strategies offered through Beta Wealth Group, Inc. dba Beta Asset
Management.
Beta Asset Management will act as the Sub-Investment Advisor on those assets specified in the signed
advisory agreement. Beta Asset Management will construct a customized strategy using the Client’s
assets specified in the signed advisory agreement. Beta Asset Management will be responsible for
discretionary investment and reinvestment of those assets indicated in the customized strategy.
Tailoring of Advisory Services
Our firm offers individualized investment advice to our Comprehensive Portfolio Management
clients. General investment advice will be offered to our Financial Planning & Consulting clients. Each
Comprehensive Portfolio Management client has the opportunity to place reasonable restrictions on
the types of investments to be held in the portfolio. Restrictions on investments in certain securities or
types of securities may not be possible due to the level of difficulty this would entail in managing the
account.
Participation in Wrap Fee Programs
Our firm offers and sponsors a wrap fee program, as further described in Part 2A, Appendix 1 (the
“Wrap Fee Program Brochure”). Our firm does not manage wrap fee accounts in a different fashion
than non-wrap fee accounts. All accounts are managed on an individualized basis according to the
client’s investment objectives, financial goals, risk tolerance, etc.
ADV Part 2A – Firm Brochure
Page 6
Beta Wealth Group, Inc.
Regulatory Assets Under Management
As of December 31, 2024, we manage $428,982,018 on a discretionary basis.
Item 5: Fees & Compensation
How We Are Compensated for Our Advisory Services
Comprehensive Portfolio Management:
We require clients to have a minimum of $250,000 in assets under management with our firm.
However, we reserve the right to waive this minimum at any time and have waived it in the past for
clients grandfathered under legacy fee schedules.
Assets Under Management Annual Fee %
Up to $300,000
$300,001 to $400,000
$400,001 to $1,000,000
$1,000,001 to $3,000,000
$3,000,001 to $8,000,000
$8,000,001 to $12,000,000
Over $12,000,000
2.00%
1.50%
1.25%
1.00%
0.90%
0.75%
Negotiable
Client specific account(s) utilizing puts and covered calls to generate additional yield will be subject
to the following fee schedule:
Assets Under Management Annual Fee %
Any Assets
1.85%
Annualized fees are billed on a pro-rata basis quarterly in advance based on the value of the account
on the last day of the previous quarter and will be deducted from your managed account(s). As part
of this process, the client is made aware of the following:
We do not serve as the qualified custodian for your account. However, our firm is deemed to
have custody of clients’ funds and securities because we have our advisory fees debited from
client accounts with written client permission. You will receive statements from the
independent custodian that holds your investment account on at least a quarterly basis.
We urge you to carefully review these statements and compare them to the account
statements that we may provide. You should verify that the transactions in your account,
including all account disbursements and the amount of the advisory fees paid to our firm, are
consistent with your investment goals and the objectives for your account. We also encourage
you to contact your advisory representative or our Chief Compliance Officer should you have
any questions or concerns regarding your account.
ADV Part 2A – Firm Brochure
Page 7
Beta Wealth Group, Inc.
Financial Planning & Consulting:
We charge on an hourly or flat fee basis for financial planning and consulting services. The total
estimated fee, as well as the ultimate fee that we charge you, is based on the scope and complexity of
our engagement with you. Our hourly fee is up to $450. Flat fees generally range from $1,500 to
$10,000. We require a retainer of 50% of the ultimate financial planning or consulting fee with the
remainder of the fee directly billed to you and due to us within 30 days of your financial plan being
delivered or consultation rendered to you. In all cases, we will not require a retainer exceeding
$1,200 when services cannot be rendered within 6 months.
Retirement Plan Consulting:
Our Retirement Plan Consulting services are billed on an hourly or flat fee basis or a fee based on the
percentage of Plan assets under management. The total estimated fee, as well as the ultimate fee
charged, is based on the scope and complexity of our engagement with the client. The maximum
hourly fee to be charged will not exceed $450. Our flat fees range from $750 to $10,000. Fees based
on a percentage of managed Plan assets will not exceed 0.50%. The fee-paying arrangements will be
determined on a case-by-case basis and will be detailed in the signed consulting agreement.
Beta Wealth Group DBA Beta Asset Management – Institutional Advisory Services:
Adviser Compensation:
Assets Under Management
Up to $4,999,999
$5,000,000 - $9,999,999
$10,000,000 - $19,999,999
Over $20,000,000
Over $50,000,000
Annual Fee %
1.00%
0.90%
0.80%
0.70%
0.60%
The total annual fee charged by Beta Asset Management is calculated based on the Client assets
specified in a signed advisory agreement. Annualized fees are billed on a pro-rata basis quarterly in
advance based on the value of the accounts(s), as of the last day of the prior quarter.
Fees are generally deducted from the managed account(s). As part of this process, the client is made
aware of the following:
a) The client’s independent custodian sends statements at least quarterly showing the market
values for each security included in the Assets and all account disbursements, including the
amount of the advisory fees paid to our firm; and
b) Clients will provide authorization permitting our firm to be directly paid by the custodian.
Our firm will send an invoice directly to the custodian.
Sub-Adviser Compensation:
Assets Under Management
$1,000,000 - $4,999,999
$5,000,000 - $9,999,999
$10,000,000 - $19,999,999
Over $20,000,000
Over $50,000,000
Annual Fee %
1.00%
0.90%
0.80%
0.70%
0.60%
ADV Part 2A – Firm Brochure
Page 8
Beta Wealth Group, Inc.
The annual fee charged by Beta Asset Management is calculated based on the Client assets in the Sub-
Advisor’s strategy specified in a signed advisory agreement. Annualized fees are billed on a pro-rata
basis quarterly in advance based on the value of the accounts(s), within the Beta Asset Management
Strategy, as of the last day of the prior quarter.
Fees are generally deducted from the managed account(s). As part of this process, the client is made
aware of the following:
a) The client’s independent custodian sends statements at least quarterly showing the market
values for each security included in the Assets and all account disbursements, including the
amount of the advisory fees paid to our firm; and
b) Clients will provide authorization permitting our firm to be directly paid by the custodian.
Our firm will send an invoice directly to the custodian.
Other Types of Fees & Expenses
Non-Wrap clients will incur transaction charges for trades executed in their accounts by their chosen
custodian either based on a percentage of the dollar amount of assets in the account(s) or via
individual transaction charges. These transaction fees are separate from our firm’s advisory fees and
will be disclosed by the chosen custodian. Clients may also pay holdings charges imposed by the
chosen custodian for certain investments, charges imposed directly by a mutual fund, index fund, or
exchange traded fund, which shall be disclosed in the fund’s prospectus (i.e., fund management fees,
initial or deferred sales charges, mutual fund sales loads, 12b-1 fees, surrender charges, variable
annuity fees, IRA and qualified retirement plan fees, and other fund expenses), mark-ups and mark-
downs, spreads paid to market makers, fees for trades executed away from custodian, wire transfer
fees and other fees and taxes on brokerage accounts and securities transactions. Our firm does not
receive a portion of these fees.
Wrap fee clients will receive our Form ADV, Part 2A, Appendix 1 (the “Wrap Fee Program Brochure”).
Wrap fee clients will not incur transaction costs for trades. More information about this is disclosed
in our separate Wrap Fee Program Brochure.
Legacy Clients may be held to a different fee structure but will not exceed what is disclosed above.
Refunds Following Termination
Either party may terminate the advisory agreement signed with our firm for Comprehensive
Portfolio Management and Retirement Plan Consulting services in writing at any time. Upon notice
of termination our firm will process a pro-rata refund of the unearned portion of the advisory fees
charged in advance at the beginning of the quarter.
Financial Planning & Consulting clients may terminate their agreement at any time before the
delivery of a financial plan by providing written notice. For purposes of calculating refunds, all work
performed by us up to the point of termination shall be calculated at the hourly fee currently in effect.
Clients will receive a pro-rata refund of unearned fees based on the time and effort expended by our
firm.
Commissionable Securities Sales
Our firm and representatives do not sell securities for a commission in advisory accounts.
ADV Part 2A – Firm Brochure
Page 9
Beta Wealth Group, Inc.
Item 6: Performance‐Based Fees & Side‐By‐Side Management
Our firm does not charge performance-based fees.
Item 7: Types of Clients & Account Requirements
Our clients typically consist of individuals, high net worth individuals and institutional clients. We do
not have requirements for opening and maintaining accounts or otherwise engaging us.
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
The following methods of analysis and investment strategies may be utilized in formulating our
investment advice and/or managing client assets, provided that such methods and/or strategies are
appropriate to the needs of the client and consistent with the client's investment objectives, risk
tolerance, and time horizons, among other considerations.
General Risks of Owning Securities
The prices of securities held in client accounts and the income they generate may decline in response
to certain events taking place around the world. These include events directly involving the issuers
of securities held as underlying assets of mutual funds in a client’s account, conditions affecting the
general economy, and overall market changes. Other contributing factors include local, regional, or
global political, social, or economic instability and governmental or governmental agency responses
to economic conditions. Finally, currency, interest rate, and commodity price fluctuations may also
affect security prices and income.
The prices of, and the income generated by, most debt securities held by a client’s account may be
affected by changing interest rates and by changes in the effective maturities and credit ratings of
these securities. For example, the prices of debt securities in the client’s account generally will decline
when interest rates rise and increase when interest rates fall. In addition, falling interest rates may
cause an issuer to redeem, “call” or refinance a security before its stated maturity, which may result
in our firm having to reinvest the proceeds in lower yielding securities. Longer maturity debt
securities generally have higher rates of interest and may be subject to greater price fluctuations than
shorter maturity debt securities. Debt securities are also subject to credit risk, which is the possibility
that the credit strength of an issuer will weaken and/or an issuer of a debt security will fail to make
timely payments of principal or interest and the security will go into default.
The guarantee of a security backed by the U.S. Treasury or the full faith and credit of the U.S.
government only covers the timely payment of interest and principal when held to maturity. This
means that the current market values for these securities will fluctuate with changes in interest rates.
Investments in securities issued by entities based outside the United States may be subject to
increased levels of the risks described above. Currency fluctuations and controls, different
accounting, auditing, financial reporting, disclosure, regulatory and legal standards and practices
ADV Part 2A – Firm Brochure
Page 10
Beta Wealth Group, Inc.
could also affect investments in securities of foreign issuers. Additional factors may include
expropriation, changes in tax policy, greater market volatility, different securities market structures,
and higher transaction costs.
Finally, various administrative difficulties, such as delays in clearing and settling portfolio
transactions, or in receiving payment of dividends can increase risk. Finally, investments in securities
issued by entities domiciled in the United States may also be subject to many of these risks.
Securities analysis methods rely on the assumption that the companies whose securities are
purchased and/or sold, the rating agencies that review these securities, and other publicly available
sources of information about these securities, are providing accurate and unbiased data. While our
firm is alert to indications that data may be incorrect, there is always a risk that our firm’s analysis
may be compromised by inaccurate or misleading information.
Asset Allocation: Rather than focusing primarily on securities selection, we attempt to identify an
appropriate ratio of securities, fixed income, and cash suitable to the client’s investment goals and
risk tolerance. A risk of asset allocation is that the client may not participate in sharp increases in a
particular security, industry or market sector. Another risk is that the ratio of securities, fixed income,
and cash will change over time due to stock and market movements and, if not corrected, will no
longer be appropriate for the client’s goals.
Long‐Term Purchases: When utilizing this strategy, we may purchase securities with the idea of
holding them for a relatively long time (typically held for at least a year). A risk in a long-term
purchase strategy is that by holding the security for this length of time, we may not take advantages
of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a
security may decline sharply in value before we make the decision to sell.
Margin Transactions: We will purchase stocks for your portfolio with money borrowed from your
brokerage account. This allows you to purchase more stock than you would be able to with your
available cash and allows us to purchase stock without selling other holdings.
Mutual Fund and/or ETF Analysis: We look at the experience and track record of the manager of
the mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability to
invest over a period of time and in different economic conditions. We also look at the underlying
assets in a mutual fund or ETF in an attempt to determine if there is significant overlap in the
underlying investments held in another fund(s) in the client’s portfolio. We also monitor the funds
or ETFs in an attempt to determine if they are continuing to follow their stated investment strategy.
The risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance
does not guarantee future results. A manager who has been successful may not be able to replicate
that success in the future. In addition, as we do not control the underlying investments in a fund or
ETF, managers of different funds held by the client may purchase the same security, increasing the
risk to the client if that security were to fall in value. There is also a risk that a manager may deviate
from the stated investment mandate or strategy of the fund or ETF, which could make the holding(s)
less suitable for the client’s portfolio.
Option Writing: We may use options as an investment strategy for certain clients. Options are not
suitable for all investors, as the risks inherent to options trading may expose investors to potentially
rapid and substantial losses. Spreads and other multiple-leg option strategies can entail substantial
transaction costs, including multiple commissions, which may impact any potential return. A covered
call strategy can limit the upside potential of the underlying stock position, as the stock would likely
ADV Part 2A – Firm Brochure
Page 11
Beta Wealth Group, Inc.
be called away in the event of substantial stock price increase. Additionally, any downside protection
provided to the related stock position is limited to the premium received. The cash secured put
strategy risks purchasing the corresponding stock at the strike price when the market price of the
stock will likely be lower.
Short‐Term Purchases: When utilizing this strategy, we may also purchase securities with the idea
of selling them within a relatively short time (typically a year or less). We do this in an attempt to
take advantage of conditions that we believe will soon result in a price swing in the securities we
purchase.
Please Note: Securities investments are not guaranteed, and you may lose money on your
investments. We ask that you work with us to help us understand your tolerance for risk. Investing
in securities involves risk of loss that clients should be prepared to bear. While the stock market may
increase and your account(s) could enjoy a gain, it is also possible that the stock market may
decrease, and your account(s) could suffer a loss. It is important that you understand the risks
associated with investing in the stock market, are appropriately diversified in your investments, and
ask us any questions you may have.
Item 9: Disciplinary Information
There are no legal or disciplinary events that are material to a client’s or prospective client’s
evaluation of our advisory business or the integrity of our management.
Item 10: Other Financial Industry Activities & Affiliations
Representatives of our firm may also be licensed insurance agents and conduct insurance business
outside of their duties at our firm. These representatives may receive normal and customary
commissions associated with insurance products. The purchase of insurance is separate from the
services of our firm. Clients interested in insurance products will be referred to an unaffiliated
insurance company. Our firm will not receive any kind of compensation for this referral.
Item 11: Code of Ethics, Participation or Interest in
Client Transactions & Personal Trading
We recognize that the personal investment transactions of members and employees of our firm demand
the application of a high Code of Ethics and require that all such transactions be carried out in a way that
does not endanger the interest of any client. At the same time, we believe that if investment goals are
similar for clients and for members and employees of our firm, it is logical and even desirable that there
be common ownership of some securities.
Therefore, in order to prevent conflicts of interest, we have in place a set of procedures (including a pre-
clearing procedure) with respect to transactions affected by our members, officers and employees for
ADV Part 2A – Firm Brochure
Page 12
Beta Wealth Group, Inc.
their personal accounts1. In order to monitor compliance with our personal trading policy, we have a
quarterly securities transaction reporting system for all of our associates.
Furthermore, our firm has established a Code of Ethics which applies to all of our associated persons. An
investment adviser is considered a fiduciary. As a fiduciary, it is an investment adviser’s responsibility
to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our
clients at all times. We have a fiduciary duty to all clients. Our fiduciary duty is considered the core
underlying principle for our Code of Ethics which also includes Insider Trading and Personal Securities
Transactions Policies and Procedures. We require all of our supervised persons to conduct business with
the highest level of ethical standards and to comply with all federal and state securities laws at all times.
Upon employment or affiliation and at least annually thereafter, all supervised persons will sign an
acknowledgement that they have read, understand, and agree to comply with our Code of Ethics. Our
firm and supervised persons must conduct business in an honest, ethical, and fair manner and avoid all
circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients.
This disclosure is provided to give all clients a summary of our Code of Ethics. However, if a client or a
potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon
request.
Neither our firm nor a related person recommends, buys or sells for client accounts, securities in
which our firm or a related person has a material financial interest without prior disclosure to the
client.
Related persons of our firm may buy or sell securities and other investments that are also
recommended to clients. In order to minimize this conflict of interest, our related persons will place
client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which
is available upon request.
Likewise, related persons of our firm buy or sell securities for themselves at or about the same time they
buy or sell the same securities for client accounts. In order to minimize this conflict of interest, our
related persons will place client interests ahead of their own interests and adhere to our firm’s Code of
Ethics, a copy of which is available upon request. Further, our related persons will refrain from buying
or selling the same securities prior to buying or selling for our clients on the same day unless included
in a block trade.
Item 12: Brokerage Practices
Selecting a Brokerage Firm
We seek to recommend a custodian/broker who will hold your assets and execute transactions on
terms that are overall most advantageous when compared to other available providers and their
services. We consider a wide range of factors, including, among others, these:
Ability to maintain the confidentiality of trading intentions
Timeliness of execution
Timeliness and accuracy of trade confirmations
1 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate,
his/her spouse, his/her minor children or other dependents residing in the same household, (b) for which our associate is a
trustee or executor, or (c) which our associate controls, including our client accounts which our associate controls and/or a
member of his/her household has a direct or indirect beneficial interest in.
ADV Part 2A – Firm Brochure
Page 13
Beta Wealth Group, Inc.
Liquidity of the securities traded
Willingness to commit capital
Ability to place trades in difficult market environments
Research services provided
Ability to provide investment ideas
Execution facilitation services provided
Record keeping services provided
Custody services provided
Frequency and correction of trading errors
Ability to access a variety of market venues
Expertise as it relates to specific securities
Financial condition
Business reputation
With this in consideration, our firm has an arrangement with Charles Schwab & Co., Inc. (“Schwab”) and
Fidelity Brokerage Services LLC (“Fidelity”) (collectively “Recommended Custodians”). Fidelity and
Schwab offer to independent investment advisers non-soft dollar services which include custody of
securities, trade execution, clearance and settlement of transactions. Please see the disclosure under
Item 14 of this Brochure.
The Recommended Custodians may make certain research and brokerage services available at no
additional cost to our firm. These services may be directly from independent research companies, as
selected by our firm (within specific parameters). Research products and services provided by the
Recommended Custodians may include research reports on recommendations or other information
about, particular companies or industries; economic surveys, data and analyses; financial publications;
portfolio evaluation services; financial database software and services; computerized news and pricing
services; quotation equipment for use in running software used in investment decision-making; and
other products or services that provide lawful and appropriate assistance by the Recommended
Custodians to our firm in the performance of our investment decision-making responsibilities.
We do not use client brokerage commissions to obtain research or other products or services. The
aforementioned research and brokerage services are used by our firm to manage accounts for which
we have investment discretion. Without this arrangement, our firm might be compelled to purchase
the same or similar services at our own expense.
As a result of receiving the services, we may have an incentive to continue to use or expand the use of
the Recommended Custodians’ services. Our firm examined this potential conflict of interest when we
chose to enter into the relationship with the Recommended Custodians and we have determined that
the relationship is in the best interest of our firm’s clients and satisfies our client obligations, including
our duty to seek best execution.
The Recommended Custodians charge brokerage commissions and transaction fees for effecting
certain securities transactions (i.e., transaction fees are charged for certain no-load mutual funds,
commissions are charged for individual equity and debt securities transactions). The Recommended
Custodians enable us to obtain many no-load mutual funds without transaction charges and other no-
load funds at nominal transaction charges. The Recommended Custodians’ commission rates are
generally discounted from customary retail commission rates. The commission and transaction fees
charged by the Recommended Custodians may be higher or lower than those charged by other
custodians and broker-dealers.
ADV Part 2A – Firm Brochure
Page 14
Beta Wealth Group, Inc.
Our non-wrap fee program clients may pay a commission to the Recommended Custodians that is
higher than another qualified broker dealer might charge to effect the same transaction where we
determine in good faith that the commission is reasonable in relation to the value of the brokerage
and research services received. In seeking best execution, the determinative factor is not the lowest
possible cost, but whether the transaction represents the best qualitative execution, taking into
consideration the full range of a broker-dealer’s services, including the value of research provided,
execution capability, commission rates, and responsiveness. Accordingly, although we will seek
competitive rates, to the benefit of all clients, we may not necessarily obtain the lowest possible
commission rates for specific client account transactions.
Soft Dollars
Our firm does not accept products or services that do not qualify for Safe Harbor outlined in Section
28(e) of the Securities Exchange Act of 1934, such as those services that do not aid in investment
decision-making or trade execution.
Client Brokerage Commissions
We do not acquire client brokerage commissions (or markups or markdowns). We do not direct client
transactions to a particular broker-dealer in return for soft dollar benefits. Our firm does not receive
brokerage for client referrals.
Directed Brokerage
In certain instances, clients may seek to limit or restrict our discretionary authority in making the
determination of the brokers with whom orders for the purchase or sale of securities are placed for
execution, and the commission rates at which such securities transactions are effected. Clients may
seek to limit our authority in this area by directing those transactions (or some specified percentage
of transactions) be executed through specified brokers in return for portfolio evaluation or other
services deemed by the client to be of value. Any such client direction must be in writing (often
through our advisory agreement) and may contain a representation from the client that the
arrangement is permissible under its governing laws and documents, if this is relevant.
We provide appropriate disclosure in writing to clients who direct trades to particular brokers, that
with respect to their directed trades, they will be treated as if they have retained the investment
discretion that we otherwise would have in selecting brokers to effect transactions and in negotiating
commissions and that such direction may adversely affect our ability to obtain best price and
execution. In addition, we will inform you in writing that your trade orders may not be aggregated
with other clients’ orders and that direction of brokerage may hinder best execution.
Special Considerations for ERISA Clients:
A retirement or ERISA plan client may direct all or part of portfolio transactions for its account
through a specific broker or dealer in order to obtain goods or services on behalf of the plan. Such
direction is permitted provided that the goods and services provided are reasonable expenses of the
plan incurred in the ordinary course of its business for which it otherwise would be obligated and
empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services
purchased are not for the exclusive benefit of the plan. Consequently, we will request that plan
sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will
be for the exclusive benefit of the plan.
ADV Part 2A – Firm Brochure
Page 15
Beta Wealth Group, Inc.
Aggregation of Purchase or Sale
We perform investment management services for various clients. There are occasions on which
portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same
security for numerous accounts served by our firm, which involve accounts with similar investment
objectives. Although such concurrent authorizations potentially could be either advantageous or
disadvantageous to any one or more particular accounts, they are affected only when we believe that to
do so will be in the best interest of the effected accounts. When such concurrent authorizations occur,
the objective is to allocate the executions in a manner which is deemed equitable to the accounts
involved. In any given situation, we attempt to allocate trade executions in the most equitable manner
possible, taking into consideration client objectives, current asset allocation and availability of funds
using price averaging, proration and consistently non-arbitrary methods of allocation.
Item 13: Review of Accounts or Financial Plans
Our management personnel or financial advisors review accounts on at least an annual basis for our
Comprehensive Portfolio Management clients. The nature of these reviews is to learn whether client
accounts are in line with their investment objectives, appropriately positioned based on market
conditions, and investment policies, if applicable. Our firm does not provide written reports to clients,
unless asked to do so. Verbal reports to clients take place on at least an annual basis when our
Comprehensive Portfolio Management clients are contacted.
Financial Planning clients do not receive reviews of their written plans unless they take action to
schedule a financial consultation with us. Our firm does not provide ongoing services to financial
planning clients, but are willing to meet with such clients upon their request to discuss updates to
their plans, changes in their circumstances, etc. Financial Planning clients do not receive written or
verbal updated reports regarding their financial plans unless they separately engage our firm for a
post-financial plan meeting or update to their initial written financial plan.
Item 14: Client Referrals & Other Compensation
Charles Schwab & Co., Inc.
Our firm may recommend that clients establish brokerage accounts with Schwab to maintain custody
of Clients’ assets and to effect trades for their accounts. Our firm is independently owned and
operated and not affiliated with Schwab. Our firm may also recommend that Clients establish
accounts with firms other than Schwab.
Our firm places trades for its Clients' accounts subject to its duty to seek best execution and its other
fiduciary duties. Our firm may use broker-dealers other than Schwab to execute trades for client
accounts maintained at Schwab, but this practice may result in additional costs to clients so that we
are more likely to place trades through Schwab rather than other broker-dealers. Schwab's execution
quality may be different than other broker-dealers. For our client accounts maintained in its custody,
Schwab generally does not charge separately for custody services but is compensated by account
holders through commissions or other transaction-related or asset-based fees for securities trades
that are executed through Schwab or that settle into Schwab accounts.
ADV Part 2A – Firm Brochure
Page 16
Beta Wealth Group, Inc.
Some of the products, services and other benefits provided by Schwab benefit us and may not benefit
our firm's client accounts. Our recommendation that a client place assets in Schwab's custody may
be based in part on benefits Schwab provides to us, and not solely on the nature, cost or quality of
custody and execution services provided by Schwab.
Schwab also makes available to our firm other products and services that benefit us but may not
benefit clients’ accounts. These benefits may include national, regional or specific to our firm,
educational events organized and/or sponsored by Schwab Institutional. Other potential benefits
may include occasional business entertainment of personnel of our firm by Schwab Institutional
personnel, including meals, invitations to sporting events, including golf tournaments, and other
forms of entertainment, some of which may accompany educational opportunities. Other of these
products and services assist us in managing and administering clients’ accounts. These include
software and other technology (and related technological training) that provide access to client
account data (such as trade confirmations and account statements), facilitate trade execution (and
allocation of aggregated trade orders for multiple client accounts), provide research, pricing
information and other market data, facilitate payment of our fees from its clients’ accounts, and assist
with back-office training and support functions, recordkeeping and client reporting. Many of these
services generally may be used to service all or some substantial number of our firm’s accounts,
including accounts not maintained at Schwab Institutional. Schwab Institutional also makes available
to us other services intended to help our firm manage and further develop its business enterprise.
These services may include professional compliance, legal and business consulting, publications and
conferences on practice management, information technology, business succession, regulatory
compliance, employee benefits providers, human capital consultants, insurance and marketing. In
addition, Schwab may make available, arrange and/or pay vendors for these types of services
rendered to our firm by independent third parties. Schwab Institutional may discount or waive fees
it would otherwise charge for some of these services or pay all or a part of the fees of a third-party
providing these services to us. While, as a fiduciary, our firm endeavors to act in its clients’ best
interests, our recommendation that clients maintain their assets in accounts at Schwab may be based
in part on the benefit to our firm of the availability of some of the foregoing products and services
and other arrangements and not solely on the nature, cost or quality of custody and brokerage
services provided by Schwab, which may create a potential conflict of interest. But for soft dollar
arrangements, we would have to obtain the aforementioned services and products for cash. As a
result of receiving such products and services at no cost, we may have an incentive to continue to
place Client trades through broker-dealers that offer soft dollar arrangements. This interest conflicts
with the Clients' interest of obtaining the lowest commission rate available. Therefore, our firm must
determine in good faith, based on the “best execution” policy stated above that such commissions are
reasonable in relation to the value of the services provided by such executing broker-dealers.
From time-to-time our firm may make an error in submitting a trade order on a client’s behalf. When
this occurs, we may place a correcting trade with the broker-dealer which has custody of the client’s
account. If an investment gain results from the correcting trade, the gain will remain in the client’s
account unless the same error involved other client account(s) that should have received the gain, it
is not permissible for the client to retain the gain, or our firm confers with the client and the client
decides to forego the gain (e.g., due to tax reasons). If the gain does not remain in the client’s account
and Schwab is the custodian, Schwab will donate the amount of any gain $100 and over to charity. If
a loss occurs greater than $100, we will pay for the loss. Schwab will maintain the loss or gain (if such
gain is not retained in the client’s account) if it is under $100 to minimize and offset its administrative
time and expense. Generally, if related trade errors result in both gains and losses in the client’s
account, they may be netted.
ADV Part 2A – Firm Brochure
Page 17
Beta Wealth Group, Inc.
Fidelity Brokerage Services, LLC
Except for the arrangements outlined in Item 12 of this brochure, we have no additional
arrangements to disclose.
Financial Institution Consulting Services
Beta Wealth Group Inc may contract directly with and receive payments from broker/dealers,
insurance companies, investment companies, and other registered investment advisors to provide
investment advisory consulting services to the clients of those contracted financial institutions. Such
contractual engagements do not include assuming discretionary authority over brokerage accounts
or the monitoring of securities positions. Services offered to financial institution clients may include
a general review of client investment holdings, which may or may not result in a Beta Wealth Group
investment advisor representative making specific securities recommendations or offering general
investment advice.
Referral Fees
We do not pay referral fees (non-commission based) to independent endorsers (non-registered
representatives) for the referral of their clients to our firm in accordance with Rule 206 (4)-1 of the
Investment Advisers Act of 1940.
Item 15: Custody
All of our clients receive account statements directly from their qualified custodians at least quarterly
upon opening of an account. If our firm decides to also send account statements to clients, such notice
and account statements include a legend that recommends that the client compare the account
statements received from the qualified custodian with those received from our firm. Clients are
encouraged to raise any questions with us about the custody, safety or security of their assets and
our custodial recommendations.
Third Party Money Movement:
The SEC issued a no-action letter (“Letter”) with respect to the Rule 206(4)-2 (“Custody Rule”) under
the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody
Rule as well as clarified that an adviser who has the power to disburse client funds to a third party
under a standing letter of instruction (SLOA”) is deemed to have custody. As such, our firm has
adopted the following safeguards in conjunction with the account custodian:
The client provides an instruction to the qualified custodian, in writing, that includes the
client’s signature, the third party’s name, and either the third party’s address or the third
party’s account number at a custodian to which the transfer should be directed.
The client authorizes the investment adviser, in writing, either on the qualified custodian’s
form or separately, to direct transfers to the third party either on a specified schedule or from
time to time.
The client’s qualified custodian performs appropriate verification of the instruction, such as
a signature review or other method to verify the client’s authorization, and provides a
transfer of funds notice to the client promptly after each transfer.
The client has the ability to terminate or change the instruction to the client’s qualified
custodian.
ADV Part 2A – Firm Brochure
Page 18
Beta Wealth Group, Inc.
The investment adviser has no authority or ability to designate or change the identity of the
third party, the address, or any other information about the third party contained in the
client’s instruction.
The investment adviser maintains records showing that the third party is not a related party
of the investment adviser or located at the same address as the investment adviser.
The client’s qualified custodian sends the client, in writing, an initial notice confirming the
instruction and an annual notice reconfirming the instruction.
Item 16: Investment Discretion
Clients have the option of providing our firm with investment discretion on their behalf, pursuant to
an executed investment advisory client agreement. By granting investment discretion, we are
authorized to execute securities transactions, which securities are bought and sold, and the total
amount to be bought and sold. Limitations may be imposed by the client in the form of specific
constraints on any of these areas of discretion with our firm’s written acknowledgement.
Item 17: Voting Client Securities
Our firm does not accept the proxy authority to vote client securities. Clients will receive proxies or
other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent
to our firm, our firm will forward them to the appropriate client and ask the party who sent them to
mail them directly to the client in the future. Clients may call, write, or email us to discuss questions
they may have about particular proxy votes or other solicitations.
Item 18: Financial Information
Our firm is not required to provide financial information in this Brochure because:
Our firm does not require the prepayment of more than $1,200 in fees when services cannot
be rendered within 6 months.
Our firm does not take custody of client funds or securities.
Our firm does not have a financial condition or commitment that impairs our ability to meet
contractual and fiduciary obligations to clients.
Our firm has never been the subject of bankruptcy proceedings.
ADV Part 2A – Firm Brochure
Page 19
Beta Wealth Group, Inc.