View Document Text
Item 1: Cover Page
Blue Barn Wealth, LLC
Registered Investment Adviser
CRD #107202
Form ADV Part 2A
Firm Brochure
March 31, 2025
Orem Office
370 West Center Street
Orem, UT 84057
Salt Lake Office
1308 South 1700 East, Suite 208
Salt Lake City, UT 84108
(801) 466-4101
info@bluebarnwealth.com
www.bluebarnwealth.com
This brochure provides information about the qualifications and business practices of Blue Barn Wealth,
LLC. If you have any questions about the contents of this brochure, please contact us at (801) 466-4101 or
by email at info@bluebarnwealth.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.
Registration as a registered investment adviser does not imply a certain level of skill or training.
Additional information about Blue Barn Wealth, LLC is also available on the SEC’s website at
www.adviserinfo.sec.gov. Blue Barn Wealth, LLC’s CRD number is: 107202.
Blue Barn Wealth, LLC
Form ADV Part 2A
Last Updated: March 31, 2025
Page 1 of 32
Item 2: Material Changes
Annual Update
The Material Changes section of this brochure will be updated annually or when material changes occur
since the previous release of the Firm Brochure.
Material Changes since the Last Update
This update is in accordance with the required annual update for Investment Advisors. In addition to minor
editorial revisions made in this brochure, Blue Barn Wealth has a made the following material changes since
its last update to its Form ADV Part 2A on March 29, 2024:
Item 4: Reflect an updated asset under management calculation.
Items 4 and 5: Remove services no longer offered and the corresponding fee schedule.
•
•
• The entire document has been updated for compliance reasons.
Full Brochure Available
This Firm Brochure being delivered is the complete brochure for the Firm.
This section of the brochure addresses only those material changes that have occurred since the firm’s last
annual update.
At any time, the firm may update this document and either send clients a copy of its updated brochure or
provide a summary of material changes to its brochure and offer to send an electronic or hard copy form of
the updated brochure. At any time, clients are also able to download this brochure from the SEC’s website
at www.adviserinfo.sec.gov, or they may contact our firm to request a copy.
As with all firm documents, clients and prospective clients are encouraged to review this brochure in its
entirety and are encouraged to ask questions at any time prior to or throughout the engagement.
Blue Barn Wealth, LLC
Form ADV Part 2A
Last Updated: March 31, 2025
Page 2 of 32
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 and Compensation ................................................................................................................................... 11
Item 6: Performance-Based Fees and Side-By-Side Management ....................................................................... 16
Item 7: Types of Clients ................................................................................................................................................. 17
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss ................................................................ 17
Item 9: Disciplinary Information ................................................................................................................................... 21
Item 10: Other Financial Industry Activities and Affiliations ................................................................................. 22
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................... 23
Item 12: Brokerage Practices ........................................................................................................................................ 24
Item 13: Review of Accounts ........................................................................................................................................ 27
Item 14: Client Referrals and Other Compensation ................................................................................................. 28
Item 15: Custody ............................................................................................................................................................. 30
Item 16: Investment Discretion .................................................................................................................................... 31
Item 17: Voting Client Securities ................................................................................................................................. 31
Item 18: Financial Information...................................................................................................................................... 31
Important Information
Throughout this document, Blue Barn Wealth, LLC may be referred to as “Blue Barn Wealth,” “the firm,”
“firm,” “our,” “we,” or “us.” A client or prospective client may be also referred to as “the client,” “client,” or
“you,” and refers to a client engagement involving a single person or two or more persons and may refer to
natural persons or legal entities. The term “advisor” and “adviser” are used interchangeably except where
accuracy in identification is necessary (e.g., an internet address, etc.).
Blue Barn Wealth, LLC
Form ADV Part 2A
Last Updated: March 31, 2025
Page 3 of 32
Item 4: Advisory Business
Description of the Firm
Blue Barn Wealth, LLC (also referred to as “Blue Barn Wealth®” or “BBW”) is a Utah domiciled limited liability
company. In March of 2019 Financial Planning Office, LLC was renamed Blue Barn Wealth, LLC, which
became registered to offer investment advisory services with the Securities and Exchange Commission in
2020. The firm has been registered to offer investment advisory services since 1994 through predecessor
firms. In Texas, we operate under the trade name My Blue Barn Wealth. Blue Barn Wealth, LLC is owned by
HJB Wealth Management, LLC which is co-owned by Hyrum L. Smith, LLC and Force For Good Financial,
LLC. Jeff Brimhall is the firm’s Chief Compliance Officer.
Types of Advisory Services
Wealth Management Services
Blue Barn Wealth offers Financial Planning Services and Portfolio Management Services, which are outlined
below. We call the combination of these services, Wealth Management Services. Blue Barn Wealth offers
these services at three different levels (Essential, Full-Service, and Premium), based on your individual needs
and level of assets.
Essential has a minimum assets under management (AUM) of $5,000 and includes our goal discovery
process, aggregated financial accounts, ongoing phone and email access to an advisor regarding covered
services, tax-efficient retirement savings and distribution strategies, comprehensive financial planning
depending on your unique needs, ongoing access and updates to your financial plan, secure online vault,
email updates, personalized investment management, integrated portfolio statements, quality low-cost
investments, and tax-loss harvesting (for accounts with at least $50,000), and an annual review meeting with
your advisor.
Full-Service has a minimum AUM of $300,000 and includes all the Essential offerings plus assistance with
implementing tax-efficient retirement savings and distribution strategies, household-level portfolio
management, access to additional investment platforms and sub-advisors, and assistance with tax-efficient
charitable giving.
Premium has a minimum AUM of $10,000,000 and includes all the Full-Service offerings plus estate plan
analysis, legacy planning, access to qualified alternative investments, management, and oversight of a
personalized portfolio of alternative investments, coordination with attorney and accountant on investment
strategies.
Financial Planning Services
The core of our Financial Planning Services is to provide our clients with a financial plan. Details about the
Financial Planning Services are described below and agreed to in the client agreement.
Your financial plan may include the following items that are described in greater detail later in this section:
cash flow analysis, debt management, risk management, employee benefits, retirement planning, education
planning, tax projections and planning, investment consultation, charitable giving, and business consultation.
Your plan may be as broad-based or narrowly focused as you desire. Client will select and agree to the topics
included in the scope of their plan on the client agreement. The incorporation of most or all the following
components allow for not only a thorough analysis but also a refined focus of your goals and objectives.
Note that when these services focus only on areas of your interest, your overall situation or needs may not
Blue Barn Wealth, LLC
Form ADV Part 2A
Last Updated: March 31, 2025
Page 4 of 32
be fully addressed. Our firm will present a summary of recommendations, guide you in the implementation
of some or all of them at your request, and we encourage plan reviews thereafter.
A broad-based financial plan is an endeavor that requires significant detail. Therefore, certain variables can
affect the cost involved in the development of such a plan, such as the quality of records, the complexity
and number of current investments, the diversity of insurance products and employee benefits, the size of
the potential estate, and special needs of the client and/or their dependents, among others. Per client
request, we may concentrate on reviewing only a specific area, such as an employer retirement plan
allocation, college funding, or evaluating the sufficiency of a savings plan. When Financial Planning Services
focus only on certain areas of client interest or need, the overall situation or needs may not be fully
addressed due to limitations established by the client. In all instances involving our financial planning
engagements, our clients retain discretion over implementation decisions and are free to accept or reject
any recommendations we make.
Depending on the scope of the engagement, you may be asked to provide copies of financial documents as
part of the process, such as:
Insurance policies
• Tax returns or tax-related documents
•
• Mortgage and/or student loan information
• Wills, codicils, trusts, and other estate documents
• Divorce decree or separation agreement
•
Information on current retirement plans and benefits provided by your employer
• Statements reflecting current investments in retirement and non-retirement accounts
• Employment or other business agreements you may have in place
• Completed risk profile questionnaires or other forms provided by our firm
While the individual services provided to each client may vary based on unique circumstances, the following
services typically apply: an initial discovery meeting, a financial plan report or access to financial planning
software, ongoing support regarding covered services, and a financial plan review meeting. The focus of
each meeting depends on the specific services requested and the needs of the client.
Cash Flow Analysis and Debt Management
A review of income and expenses determines current surplus or deficit which can inform recommendations
about prioritizing how any surplus should be used, or how to reduce expenses if they exceed your income.
Advice may also be provided regarding which debts to pay off first based on factors such as the interest rate
of the debt and any income tax ramifications. Recommendations may also be made with respect to
appropriate cash reserves for emergencies and other financial goals, and a review of accounts (such as
money market funds) for such reserves, plus strategies to save desired amounts.
Risk Management
A risk management review includes an analysis of exposures to major risks that could have a significant
adverse impact on your financial picture, such as premature death, disability, property and casualty losses,
or the need for long-term care planning. Advice may be provided on ways to minimize such risks and about
weighing the costs of purchasing insurance versus the benefits of doing so and, likewise, the potential cost
of not purchasing insurance (“self-insuring”).
Employee Benefits
A review and analysis of employee benefits that you have available to you, as an employee, ensures that you
are taking maximum advantage of your benefits. We may offer advice on employer-sponsored retirement
plan or stock options, among other benefits that may be available to you.
Blue Barn Wealth, LLC
Form ADV Part 2A
Last Updated: March 31, 2025
Page 5 of 32
Retirement Planning
Retirement planning typically includes building projections of the likelihood of achieving financial goals, with
financial independence as an objective. For situations where projections show less than the desired results,
recommendations may include making changes in certain variables (e.g., working longer, saving more,
spending less, taking more risk with investments) and the impact those changes have on projections. If you
are near retirement or already retired, advice may be given on appropriate distribution strategies to minimize
the likelihood of running out of money or having to adversely alter spending during retirement years. Advice
may also be given on optimal Social Security and Medicare claiming strategies as well as tax strategies that
aim to limit the amount of your Social Security benefit that will be taxed.
Education Planning
Education planning typically includes projecting the amount that will be needed to achieve post-secondary
education funding goals. Advice may be provided regarding savings strategies and the “pros-and-cons” of
various college savings vehicles that are available, strategies for paying for college, and education loan
repayment strategies.
Estate Planning
Estate planning involves an analysis of current estate plans and exposures to estate and inheritance taxes.
Recommendations may include encouragement to see a licensed attorney to create a new or revisions to a
will, powers of attorney, trusts and other related documents. Advice may include ways to minimize or avoid
future estate taxes by implementing relevant planning strategies. Estate planning also includes
understanding the purpose behind your desired estate plans and helping you to create a plan that is in line
with your long-term goals and values as well as your desires for your beneficiaries.
Tax Projections and Planning
Tax projections and planning may include strategies to minimize current and future income taxes as a part
of your overall financial plan. Recommendations may be provided as to which type of account(s) or specific
investments should be owned, where contributions should go, and from where distributions should come,
based in part on their impact on your current and future income taxes. Consideration is also given for
potential changes to federal, state and/or local tax laws and rates that may impact each client’s situation.
Investment Consultation
Our investment consultation may involve providing information about the types of investment vehicles
available, advice on stock options, investment analysis and strategies, asset selection, asset location, and
portfolio design. It may include assisting you with investment accounts that are maintained at other
broker/dealers or custodians. The strategies and types of investments that may be recommended are further
discussed in Item 8 of this brochure.
Charitable Giving
We believe that giving generously is a key aspect of living a meaningful life. To give generously, individuals
need to feel confident that they have enough to care for their own needs. We use the financial planning
process to help clients achieve this assurance. We also provide clients with resources to give efficiently and
effectively. Recommendations may involve various methods of charitable giving, such as donor-advised
funds (DAFs), foundations, and direct giving. We may also provide guidance about how to evaluate charities
to ensure that the money donated is being used effectively.
Business Consultation
Business owners may be consulted in a variety of ways that impact their financial situation, including
business strategy, practice management, general financial advice, capital structure/table, and debt
management. Business consultation may also involve coordinating with other financial institutions,
attorneys, and/or accountants.
Blue Barn Wealth, LLC
Form ADV Part 2A
Last Updated: March 31, 2025
Page 6 of 32
If a conflict of interest exists between the interests of Blue Barn Wealth and the interests of the Client, the
Client is under no obligation to act upon Blue Barn Wealth’s recommendation. If the Client elects to act on
any of the recommendations, the Client is under no obligation to effect the transaction through Blue Barn
Wealth. Financial plans will be completed and delivered inside of six (6) months contingent upon timely
delivery of all required documentation.
Ongoing Financial Planning Services
Ongoing consultations are different than the planning offered above in that the clients are looking for
ongoing support and services as opposed to creating a one-time plan. Ongoing consultations consist of one
or more of the items as described above.
When engaging in ongoing consultations a client can expect the following:
Meet at least once per year - in person or telephone. Includes but is not limited to the following:
•
o updated financial plan
o
o
tax plan
recommendations (as needed) on:
charitable giving
Social Security or Medicare
budget
debt planning
legacy planning/review
insurance planning
investment recommendations on assets held outside Blue Barn Wealth (e.g. 401k,
other employer plans)
If a conflict of interest exists between the interests of Blue Barn Wealth and the interests of the Client, the
Client is under no obligation to act upon Blue Barn Wealth’s recommendation. If the Client elects to act on
any of the recommendations, the Client is under no obligation to effect the transaction through Blue Barn
Wealth. Ongoing services will continue from year to year unless cancelled by either party.
Portfolio Management Services
Many of our clients engage our firm to implement the investment strategies that we recommended to you.
Depending on your risk profile, goals and needs, among other considerations, your portfolio will involve the
employment of one or more of our investment strategies as well as either a broad range or more narrowly
focused choice of investment vehicles which are further discussed in Item 8 of this brochure.
We typically prepare an Investment Policy Statement (IPS) to reflect your objectives, time horizon, tolerance
for risk, as well as any reasonable account constraints you may have for the portfolio. For example, you have
the right to exclude certain securities (e.g., options, stocks, etc.) at your discretion. Each client’s IPS is
designed to be specific enough to provide future guidance while also allowing flexibility to work with
changing market conditions. Since this effort is the product of information and data you provide, you may
be asked to review it and provide your final approval. We will then develop a customized portfolio for you
based on your unique situation, investment goals, and tolerance for risk. We manage your portfolio on a
discretionary basis. The Client will authorize Blue Barn Wealth discretionary authority to execute selected
investment program transactions as stated within the Investment Advisory Agreement. We want to note
that it will remain your responsibility to promptly notify us if there are any changes in your financial situation
and/or investment objectives for the purpose of our reviewing, evaluating, or revising previous account
restrictions or firm investment recommendations.
When deemed appropriate for the Client, Blue Barn Wealth may hire Sub-Advisors to manage all or a portion
of the assets in the Client account. Blue Barn Wealth has full discretion to hire and fire Sub-Advisors as we
deem suitable. Sub-Advisors will maintain the models or investment strategies agreed upon between Sub-
Blue Barn Wealth, LLC
Form ADV Part 2A
Last Updated: March 31, 2025
Page 7 of 32
Advisor and Blue Barn Wealth. Sub-Advisors execute trades on behalf of Blue Barn Wealth in Client
accounts. Blue Barn Wealth will be responsible for the overall direct relationship with the Client. Blue Barn
Wealth retains the authority to terminate the Sub-Advisor relationship at Blue Barn Wealth’s discretion.
ERISA Plan Services
Blue Barn Wealth provides service to qualified retirement plans including 401(k) plans, 403(b) plans, pension
and profit-sharing plans, cash balance plans, and deferred compensation plans as either a 3(21) or 3(38)
advisor:
Limited Scope ERISA 3(21) Fiduciary. Blue Barn Wealth may serve as a limited scope ERISA 3(21) fiduciary
that can advise, help and assist plan sponsors with their investment decisions. As an investment advisor Blue
Barn Wealth has a fiduciary duty to act in the best interest of the Client. The plan sponsor is still ultimately
responsible for the decisions made in their plan, though using Blue Barn Wealth can help the plan sponsor
delegate liability by following a diligent process.
1. Fiduciary Services are:
• Provide investment advice to the Client about asset classes and investment options available for the
Plan in accordance with the Plan’s investment policies and objectives. Client will make the final
decision regarding the initial selection, retention, removal and addition of investment options. Blue
Barn Wealth acknowledges that it is a fiduciary as defined in ERISA section 3 (21) (A) (ii).
• Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes
the investment policies and objectives for the Plan. Client shall have the ultimate responsibility and
authority to establish such policies and objectives and to adopt and amend the IPS.
• Provide investment advice to the Plan Sponsor with respect to the selection of a qualified default
investment option for participants who are automatically enrolled in the Plan or who have otherwise
failed to make investment elections. The Client retains the sole responsibility to provide all notices
to the Plan participants required under ERISA Section 404(c) (5) and 404(a)-5.
• Assist in monitoring investment options by preparing periodic 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, remove or replace investment options.
• Meet with Client on a periodic basis to discuss the reports and the investment recommendations.
2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and the
investment options available to them under the Plan. Client understands Blue Barn Wealth’s
assistance in education of the Plan participants shall be consistent with and within the scope of the
Department of Labor’s definition of investment education (Department of Labor Interpretive
Bulletin 96-1). As such, Blue Barn Wealth is not providing fiduciary advice as defined by ERISA
3(21)(A)(ii) to the Plan participants. Blue Barn Wealth will not provide investment advice concerning
the prudence of any investment option or combination of investment options for a particular
participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan participation among
the employees and investment and financial understanding by the employees.
Blue Barn Wealth may provide these services or, alternatively, may arrange for the Plan’s other providers to
offer these services, as agreed upon between Blue Barn Wealth and Client.
3. Blue Barn Wealth has no responsibility to provide services related to the following types of assets
(“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
Blue Barn Wealth, LLC
Form ADV Part 2A
Last Updated: March 31, 2025
Page 8 of 32
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and similar vehicles);
or
• Other hard-to-value or illiquid securities or property.
Excluded Assets will not be included in calculation of Fees paid to Blue Barn Wealth on the ERISA
Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure.
ERISA 3(38) Investment Manager. Blue Barn Wealth can also act as an ERISA 3(38) Investment Manager in
which it has discretionary management and control of a given retirement plan’s assets. Blue Barn Wealth
would then become solely responsible and liable for the selection, monitoring and replacement of the plan’s
investment options.
1. Fiduciary Services are:
• Blue Barn Wealth has discretionary authority and will make the final decision regarding the initial
selection, retention, removal and addition of investment options in accordance with the Plan’s
investment policies and objectives.
• Assist the Client with the selection of a broad range of investment options consistent with ERISA
Section 404(c) and the regulations thereunder.
• Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes
the investment policies and objectives for the Plan.
• Provide discretionary investment advice to the Plan Sponsor with respect to the selection of a
qualified default investment option for participants who are automatically enrolled in the Plan or
who have otherwise failed to make investment elections. The Client retains the sole responsibility
to provide all notices to the Plan participants required under ERISA Section 404(c) (5).
2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and the
investment options available to them under the Plan. Client understands the Blue Barn Wealth’s
assistance in education of the Plan participants shall be consistent with and within the scope of the
Department of Labor’s definition of investment education (Department of Labor Interpretive
Bulletin 96-1). As such, the Blue Barn Wealth is not providing fiduciary advice as defined by ERISA
to the Plan participants. Blue Barn Wealth will not provide investment advice concerning the
prudence of any investment option or combination of investment options for a particular participant
or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan participation among
the employees and investment and financial understanding by the employees.
Blue Barn Wealth may provide these services or, alternatively, may arrange for the Plan’s other providers to
offer these services, as agreed upon between Blue Barn Wealth and Client.
3. Blue Barn Wealth has no responsibility to provide services related to the following types of assets
(“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and similar vehicles);
or
Blue Barn Wealth, LLC
Form ADV Part 2A
Last Updated: March 31, 2025
Page 9 of 32
• Other hard-to-value or illiquid securities or property.
Excluded Assets will not be included in calculation of Fees paid to the Adviser on the ERISA Agreement.
Specific services will be outlined in detail to each plan in the 408(b)2 disclosure.
Assets Held Away
Blue Barn Wealth uses a third party platform to facilitate management of held away assets such as defined
contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to
have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades.
We are not affiliated with the platform in any way and receive no compensation from them for using their
platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once
Client account(s) is connected to the platform, Blue Barn Wealth will review the current account allocations.
When deemed necessary, Blue Barn Wealth will rebalance the account considering client investment goals
and risk tolerance, and any change in allocations will consider current economic and market trends. The goal
is to improve account performance over time, minimize loss during difficult markets, and manage internal
fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation
changes will be made as deemed necessary.
Client Tailored Services and Client Imposed Restrictions
The goals and objectives for each Client are documented in our Client files. Investment strategies are created
that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities
or types of securities.
Agreements may not be assigned without Client consent.
Wrap Fee Programs
We do not offer or sponsor any investment program involving wrapped (bundled) fees.
Client Assets Under Management
Blue Barn Wealth has the following Client assets under management:
Discretionary Amounts:
Non-discretionary Amounts:
Date Calculated:
$503,899,881
$17,470,609
December 31, 2024
General Information
Blue Barn Wealth does not offer legal or tax preparation or compliance related services. With your prior
written consent, we will work with your attorney or accountant to assist with the coordination and
implementation of any accepted strategies. These other professionals will charge you separately for their
services, and their fee is separate of our advisory fee.
Blue Barn Wealth, LLC
Form ADV Part 2A
Last Updated: March 31, 2025
Page 10 of 32
Item 5: Fees and Compensation
Method of Compensation and Fee Schedule
Wealth Management Services
For our Wealth Management Services (which includes both our Financial Planning Services and our Portfolio
Management Services), we charge an asset-based fee, which is a regressively tiered schedule based on the
level of a client’s Assets Under Management (AUM). Clients with less than 180,000 in assets under
management may also be required to pay a financial planning fee in addition to the tiered AUM fee in order
to receive Wealth Management Services.
The asset-based fee is typically charged quarterly in arrears, which means that at the end of each calendar
quarter, you pay for the preceding quarter. The fee is determined by multiplying the aggregate account
balance across all accounts in a client’s household as of the last day of the quarter by the annual percentages
listed in the tiered fee schedule below. The result is then divided by four to determine the quarterly fee for
the preceding quarter. If margin is utilized, the fees will be billed based on the net asset value of the account.
In addition, any deposits or withdrawals that occur during the quarter will follow the same calculation to be
prorated by the number of days the funds were in the account. If the asset-based fee is less than any
applicable minimum fee included in your client engagement agreement, then the minimum fee will be
assessed instead of the asset-based fee. If a minimum fee applies, it may be paid monthly instead of
quarterly.
The asset-based fee is based on the tiered schedule below. For example, a client who has a total portfolio
of $2,000,000 managed by our firm would be assessed an annualized fee of 1% for the first $1,000,000 and
0.75% on the next $1,000,000, for a blended rate of 0.875% on the $2,000,000 portfolio.
Assets Under Management
Annual Fees
1.00%
0.75%
0.50%
First $1 Million
($0 - $1,000,000)
Next $3 Million
($1,000,000.01-$4,000,000)
Next $6 Million
($4,000,000.01-$10,000,000)
Above $10 Million
0.25%
For the benefit of lowering your asset-based fee, we may aggregate accounts for the same individual or
married couple, including accounts where a family member has power of attorney over another family
member’s assets, into a single household. Blue Barn Wealth considers cash to be an asset class, and as such
is included in fee calculations. Also, to be noted, at times fees will exceed the money market yield. If the
Account does not contain sufficient funds to pay advisory fees, Blue Barn Wealth has authority to sell or
redeem securities in sufficient amounts to pay advisory fees.
At the end of each calendar quarter, the asset-based fee is determined by multiplying the aggregate account
balance across all accounts in the Client’s household (two or more accounts owned by the Client) as of the
last day of the quarter by the annual percentages listed in the tiered fee schedule. The result is then divided
by four (4) to determine the quarterly fee for the preceding quarter. In addition, any deposits or withdrawals
that occur during the quarter will follow the same calculation; however, they will be prorated by the number
of days the funds were in the account.
Blue Barn Wealth, LLC
Form ADV Part 2A
Last Updated: March 31, 2025
Page 11 of 32
Blue Barn Wealth may also utilize the services of a Sub-Advisor to manage Clients’ investment portfolios by
executing a Sub-Advisor agreement with other registered investment advisor firms. If a sub-advisor is
engaged to execute its investment strategy within your account maintained at our custodian of record, the
sub-advisor’s fee is in addition to our fee schedule. The fee will be dependent on the account value,
investment style and types of securities used. The sub-advisor fee is often in lieu of an expense ratio on a
mutual fund or exchange-traded fund. The sub-advisor fees will be disclosed to and acknowledged by the
Client in Blue Barn Wealth’s Client Agreement.
In the rare absence of a reportable market value, our firm may seek a third-party opinion from a recognized
industry source (e.g., unaffiliated public accounting firm). A client may choose to separately seek such an
opinion at their own expense as to the valuation of “hard-to-price” securities if they believe it to be
necessary.
The first billing cycle will begin once your engagement agreement is executed with our firm and assets have
settled into your account held by the custodian of record. Advisory fees for partial quarters will be prorated
based on the remaining days in the reporting period in which our firm services the account.
Financial Planning Services
Fees for our Financial Planning Services take into consideration the number of services requested, the
anticipated time involved in generating and executing the services, and other related factors that informed
these estimates, such as the complexity of a client’s financial situation and the assets that comprise a clients’
overall value or net worth.
Blue Barn Wealth charges an hourly fee of up to $300 per hour. Prior to entering into an agreement, we
provide an estimate of the overall cost of the project based on the requested deliverables and the expected
time involved. An initial deposit of 50% of the total estimated cost is due at the onset of the engagement;
the remainder of the balance is due in full upon delivery of the final invoice, which coincides with the
presentation of the agreed upon deliverables. Once the project is complete, the engagement ends, and no
further services are provided until the client requests to enter a new agreement. Services are completed and
delivered inside of six (6) months contingent upon timely delivery of all required documentation.
Ongoing Financial Planning Services
The Ongoing Financial Planning Engagement includes an initial fee that ranges from $100 - $2,000 as well
as an annual fee that ranges from $1,800 to $24,000 per year. The annual fee is divided into twelve equal
installments and is billed monthly in arrears. Clients under this engagement agree fees will continue from
year to year
unless the client provides written notice of their desire to terminate 30 days in advance of the
renewal date.
Portfolio Management Services
For our Portfolio Management Services, we charge an asset-based fee, which is a regressively tiered
schedule. This asset-based fee is typically charged quarterly in arrears, which means that at the end of each
calendar quarter, you pay for the preceding quarter. The fee is determined by multiplying the aggregate
account balance across all accounts in a client’s household as of the last day of the quarter by the annual
percentages listed in the tiered fee schedule below. The result is then divided by four to determine the
quarterly fee for the preceding quarter. If margin is utilized, the fees will be billed based on the net asset
value of the account. In addition, any deposits or withdrawals that occur during the quarter will follow the
same calculation to be prorated by the number of days the funds were in the account. If the asset-based fee
is less than any applicable minimum fee included in your client engagement agreement, then the minimum
fee will be assessed instead of the asset-based fee. If a minimum fee applies, it may be paid monthly instead
of quarterly.
Blue Barn Wealth, LLC
Form ADV Part 2A
Last Updated: March 31, 2025
Page 12 of 32
The asset-based fee is based on the tiered schedule below. For example, a client who has a total portfolio
of $2,000,000 managed by our firm would be assessed an annualized fee of 1% for the first $1,000,000 and
0.75% on the next $1,000,000, for a blended rate of 0.875% on the $2,000,000 portfolio.
Assets Under Management
Annual Fees
1.00%
0.75%
0.50%
First $1 Million
($0 - $1,000,000)
Next $3 Million
($1,000,000.01-$4,000,000)
Next $6 Million
($4,000,000.01-$10,000,000)
Above $10 Million
0.25%
For the benefit of lowering your asset-based fee, we may aggregate accounts for the same individual or
married couple, including accounts where a family member has power of attorney over another family
member’s assets, into a single household. Blue Barn Wealth considers cash to be an asset class, and as such
is included in fee calculations. Also, to be noted, at times fees will exceed the money market yield. If the
Account does not contain sufficient funds to pay advisory fees, Blue Barn Wealth has authority to sell or
redeem securities in sufficient amounts to pay advisory fees.
Blue Barn Wealth may also utilize the services of a Sub-Advisor to manage Clients’ investment portfolios by
executing a Sub-Advisor agreement with other registered investment advisor firms. If a sub-advisor is
engaged to execute its investment strategy within your account maintained at our custodian of record, the
sub-advisor’s fee is in addition to our fee schedule. The fee will be dependent on the account value,
investment style and types of securities used. The sub-advisor fee is often in lieu of an expense ratio on a
mutual fund or exchange-traded fund. The sub-advisor fees will be disclosed to and acknowledged by the
Client in Blue Barn Wealth’s Client Agreement.
In the rare absence of a reportable market value, our firm may seek a third-party opinion from a recognized
industry source (e.g., unaffiliated public accounting firm). A client may choose to separately seek such an
opinion at their own expense as to the valuation of “hard-to-price” securities if they believe it to be
necessary.
The first billing cycle will begin once your engagement agreement is executed with our firm and assets have
settled into your account held by the custodian of record. Advisory fees for partial quarters will be prorated
based on the remaining days in the reporting period in which our firm services the account.
ERISA PLAN SERVICES
The annual fees are based on the market value of the Included Assets and will not exceed 1%. The annual
fee is negotiable and will be charged as a percentage of the Included Assets or as a flat fee. Fees may be
charged quarterly or monthly in arrears or in advance based on the assets as calculated by the custodian or
record keeper of the Included Assets (without adjustments for anticipated withdrawals by Plan participants
or other anticipated or scheduled transfers or distribution of assets). If the services to be provided start any
time other than the first day of a quarter or month, the fee will be prorated based on the number of days
remaining in the quarter or month. If this Agreement is terminated prior to the end of the billing cycle, Blue
Barn Wealth shall be entitled to a prorated fee based on the number of days during the fee period services
were provided or Client will be due a prorated refund of fees for days services were not provided in the
billing cycle.
The fee schedule, which includes compensation of Blue Barn Wealth for the services is described in detail
in Schedule A of the ERISA Plan Agreement. The Plan is obligated to pay the fees, however the Plan Sponsor
may elect to pay the fees. Client may elect to be billed directly or have fees deducted from Plan Assets. Blue
Blue Barn Wealth, LLC
Form ADV Part 2A
Last Updated: March 31, 2025
Page 13 of 32
Barn Wealth does not reasonably expect to receive any additional compensation, directly or indirectly, for
its services under this Agreement. If additional compensation is received, Blue Barn Wealth will disclose this
compensation, the services rendered, and the payer of compensation. Blue Barn Wealth will offset the
compensation against the fees agreed upon under the Agreement.
ASSET HELD AWAY
Blue Barn Wealth offers discretionary direct asset management services to advisory Clients. Blue Barn
Wealth charges an annual investment advisory fee based on the total assets under management as follows:
Assets Under Management
Annual Fees
1.00%
0.75%
0.50%
First $1 Million
($0 - $1,000,000)
Next $3 Million
($1,000,000.01-$4,000,000)
Next $6 Million
($4,000,000.01-$10,000,000)
Above $10 Million
0.25%
This is a tiered or breakpoint fee schedule, the entire portfolio is charged the same asset management fee.
For example a client with $1,500,000 will pay a quarterly fee of $3,750 ($1,500,000 x 1.00%) / 4 = $3,750.
The annual fee is negotiable. The Advisory Fee for the initial period will be paid on a pro rata basis based on
the number of days in the billing period for which services under this Agreement were provided, in arrears,
based on the billing period ending value of the Client’s managed assets, in accordance with the fee schedule
listed in the Agreement. For all future periods, the Advisory Fee will be assessed and payable each billing
period, in arrears, based on the balance of Client’s managed assets as of the period-end, in accordance with
the fee schedule listed in the Agreement. By executing this Agreement, Client is authorizing Blue Barn
Wealth to debit its Advisory Fees directly from one or more of the Client’s Accounts. The Advisory Fee
payable for any Held Away Account will be deducted directly from another Client Account, and if there are
insufficient funds available in another Client Account or Blue Barn Wealth believes that deducting the
Advisory Fee from another Client Account would be prohibited by applicable law, it will invoice the Client.
No fee adjustment will be made for Account deposits and withdrawals during a billing period.
In addition to the fees paid to Blue Barn Wealth, investments used in managing the Account may subject
Client to additional fees. For example, mutual funds, index funds, exchange traded funds and private funds
typically charge ongoing management fees and have other expenses for the operation of those funds. These
fees should not be confused with “loads” or commissions. Blue Barn Wealth does not receive any additional
compensation, either directly or indirectly, from these investments.
Discounting and Grandfathering Fees
The advisory services to be provided and their specific fees will be detailed in the client’s engagement
agreement. Published fees may be discounted at our firm’s discretion and are typically for our associates
and related persons. Our firm strives to offer fees that are fair and reasonable based on the expertise of our
firm and the services to be provided. Similar services may be made available from other firms and potentially
at a lesser fee.
For some of our clients, we have grandfathered their historical fee schedule as a courtesy. This fee schedule
may be billed differently than outlined above, including being billed in advance instead of in arrears. In all
cases, the appropriate fee schedule is outlined in the client engagement agreement and clearly disclosed on
any provided invoice.
Blue Barn Wealth, LLC
Form ADV Part 2A
Last Updated: March 31, 2025
Page 14 of 32
• Deducted from a designated Client account. The Client must consent in advance to direct debiting
Fees for portfolio management services are:
Client Payment of Fees
of their investment account.
• Check – to be remitted by Client to Blue Barn Wealth
• Deducted from a non-qualified account managed by Blue Barn Wealth
• Electronic Payment via ACH, Debit Card, or Credit Card (fees will be paid via a third party payment
processor in which the client will securely input payment information and pay the advisory fee
through a secure portal. Blue Barn Wealth will not have continuous access to the Client’s banking
information.)
Fees for financial plans will be billed:
• Check – to be remitted by Client to Blue Barn Wealth
• Electronic Payment via ACH, Debit Card, or Credit Card (fees will be paid via a third party payment
processor in which the client will securely input payment information and pay the advisory fee
through a secure portal. Blue Barn Wealth will not have continuous access to the Client’s banking
information.)
Fees for ERISA services will either be deducted from Plan assets or paid directly to Blue Barn Wealth. The
Client must consent in advance to direct debiting of their investment account.
Additional Client Fees
Any transactional or service fees (sometimes termed brokerage fees), individual retirement account fees,
qualified retirement plan fees, account termination fees, or wire transfer fees will be borne by the account
holder, per the separate fee schedule of the custodian of record or third-party administrator. The custodian
of record or third-party administrator will provide you with a copy of their fee schedule (e.g., Schwab Pricing
Guide) upon account opening and notify you of any future changes to those fees as they occur.
Fees paid by our clients to our firm for our advisory services are separate from any internal fees or charges
a client may pay for mutual funds, exchange-traded funds (ETFs), exchange-traded notes (ETNs), or other
investments. Margin interest may also apply for Client electing to utilize margin on their account(s).
Per annum interest at the current maximum statutory rate may be assessed on fee balances due more than
30 days. We may refer past due accounts to collections or legal counsel for processing. We reserve the right
to suspend some or all services once an account is deemed past due.
Additional information about our fees in relationship to our brokerage practices are noted in Items 12 and
14 of this document.
Blue Barn Wealth does not require any prepayment of fees of more than $1,200 per Client and six months
Prepayment of Client Fees
or more in advance.
Fees for financial plans are billed 50% in advance with the balance due upon plan delivery.
Fees for ERISA 3(21) and/or 3(38) services may be billed in advance.
If the Client cancels after five (5) business days, any unearned fees will be refunded to the Client, or any
unpaid earned fees will be due to Blue Barn Wealth.
Blue Barn Wealth, LLC
Form ADV Part 2A
Last Updated: March 31, 2025
Page 15 of 32
External Compensation for the Sale of Securities to Clients
We do not charge or receive a commission or mark-up on a client securities transaction, nor do we receive
“trailer” or SEC Rule 12b-1 fees from an investment company we may recommend when we are engaged to
provide portfolio management services. Fees charged by issuers are detailed in prospectuses or product
descriptions and clients are encouraged to read these documents before investing.
You retain the right to purchase recommended or similar investments through your own service provider.
Please note that many institutional investment managers do not make themselves directly available to the
public.
Termination of Services
Either party may terminate the agreement at any time by communicating the intent to terminate in writing
with 30 days’ notice. If you verbally notify our firm of the termination and, if in two business days following
this notification, we have not received your notice in writing, we will make a written notice of the termination
in our records and send you our own termination notice as a substitute. Our firm will not be responsible for
investment allocation, advice or transactional services (except for limited closing transactions) upon the
expiration of the 30-day notice period following receipt of a termination notice. It will also be necessary that
we inform the custodian of record and/or third-party investment manager that the relationship between
parties has been terminated.
A new client will have the right to terminate our firm’s engagement agreement without fee or penalty within
five business days after entering into the contract. Should a client terminate a financial planning service after
this five-day time period, the client will be assessed fees at the firm’s current hourly rate for any time
incurred in the preparation of that client’s analysis or plan. When a wealth management services client
terminates their agreement after the five-day period, that client will be assessed fees on a prorated basis for
services incurred from either (i) as a new client, the date of the engagement to the date of the firm’s receipt
of the written notice of termination, or (ii) all other accounts, the last billing period to the date of the firm’s
physical or constructive receipt of written termination notice.
You will be entitled to a refund if you were required to provide an initial deposit for a financial planning
engagement, you provided all requested information, and your plan was not delivered to you within six
months’ time from the date of the engagement.
Our firm will return any prepaid, unearned fees on a prorated basis (based on the amount of work that was
already completed) within 30 days of the expiration of the 30-day notice period, following the firm’s receipt
of termination notice. Earned fees in excess of any prepaid deposit will be billed at the time of termination
and will be due upon receipt of our invoice. Our return of payment to a client for our financial planning
services will only be completed via check from our firm’s US-based financial institution; no credits or
“transaction reversals” will be issued. We will coordinate remuneration of prepaid asset-based fees, if any,
to a client’s investment account or by check. Return of prepaid fees will never involve a personal check, cash
or money order from our firm or from an associate of our firm.
Item 6: Performance-Based Fees and Side-By-Side Management
Our firm’s advisory fees are not based on a share of capital gains or capital appreciation (growth) of any
portion of managed funds, also known as performance-based fees. Our fees are also not based on side-by-
side management, which refers to a firm simultaneously managing accounts that do pay performance-based
fees (such as a hedge fund) and those that do not.
Blue Barn Wealth, LLC
Form ADV Part 2A
Last Updated: March 31, 2025
Page 16 of 32
Item 7: Types of Clients
Description
Blue Barn Wealth provides advisory services to individuals and high net worth individuals (and their trusts
and estates) of all levels of investment experience. We also provide consulting services to pensions and
profit-sharing plans as well as to businesses and charities of all scale.
We reserve the right to waive or reduce certain fees based on unique individual circumstances, special
arrangements or preexisting relationships. We also reserve the right to decline services to any prospective
client for any nondiscriminatory reason.
Account Minimums
Blue Barn Wealth requires the following minimums for its Wealth Management Services:
Essential has a minimum asset under management (AUM) of $5,000 but may require a financial planning
fee in addition to the AUM fee;
Full-Service has a minimum AUM of $300,000; and
Premium has a minimum AUM of $10,000,000.
In certain instances, the minimum account size may be lowered or waived.
Item 8: Methods of Analysis, Investment Strategies, and Risk of
Loss
Methods of Analysis and Investment Strategies
Blue Barn Wealth’s methods of analysis for constructing client portfolios are based on Modern Portfolio
Theory. Modern Portfolio Theory is an investment theory which states that by employing securities whose
price movements have historically low correlations, it is possible to create an efficient portfolio that can
offer the highest expected return for a given level of risk, or one with the lowest level of risk for a given
expected return. The practice of Modern Portfolio Theory does not employ market timing or stock selection
methods of investing but rather a long term, buy-and-hold strategy with periodic rebalancing of the account
to maintain desired risk levels.
Whenever practical, our portfolios contain investment vehicles that are broadly diversified, tax-efficient and
low-cost. It is common to find a broad range of mutual funds or ETFs within a portfolio, as well as individual
stocks, bonds, options and limited partnerships. We use margin transactions for some of our clients when
appropriate.
When appropriate, we employ fundamental analyses and evaluate economic factors including interest rates,
the current state of the economy, or the future growth of an industry sector. Our research is drawn from a
variety of sources, including financial periodicals, financial software, corporate rating services, and research
reports from economists and other industry professionals, in addition to annual reports, prospectuses, and
filings with the Securities and Exchange Commission.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear.
Modern Portfolio Theory assumes that investors are risk averse, meaning that given two portfolios that offer
the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased
Blue Barn Wealth, LLC
Form ADV Part 2A
Last Updated: March 31, 2025
Page 17 of 32
risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected
returns must accept more risk that those returns may not be realized. The exact trade-off will be the same
for all investors, but different investors will evaluate the trade-off differently based on individual risk
aversion characteristics.
Our firm believes its strategies and investment recommendations are designed to produce the appropriate
potential return for the given level of risk; however, there is no guarantee that a planning goal or investment
objective will be achieved. Past performance is not indicative of future results.
The following paragraphs include examples of some of the risks associated with investing and various
investment strategies, and we believe it is important that our clients review and consider each of the risks
prior to investing.
General Investment Risks
•
• Market Risk: The price of an investment may drop in reaction to tangible and intangible events and
conditions. This type of risk is caused by external factors independent of a security’s underlying
circumstances. For example, political, economic and social conditions may trigger market events.
When the stock market or an industry falls, it can cause the prices of individual stocks to fall
indiscriminately. This is also called systemic or systematic risk.
Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar
may next year because purchasing power is eroding at the rate of inflation.
• Political Risk: Financial and market loss may occur because of political decisions or disruptions in a
country or region. Political risk may also be known as "geopolitical risk."
•
• Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the
currency of the investment’s originating country. This is also referred to as exchange rate risk.
• Company Risk: When investing in securities, such as stocks, there is always a certain level of company
or industry-specific risk that is inherent in each company or issuer. There is the risk that the company
will perform poorly or have its value reduced based on factors specific to the company or its
industry. This is also referred to as unsystematic risk and can be reduced or mitigated through
diversification.
Financial Risk: Excessive borrowing to finance a business operation increases profitability risk
because the company must meet the terms of its obligations in good times and bad. During periods
of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining
market value.
Failure to Implement
Each financial planning client is free to accept or reject any or all recommendations made by our firm. While
no advisory firm can guarantee future performance, no plan can succeed if it is not implemented. Clients
who choose not to take the steps recommended in their financial plan may face an increased risk that their
stated goals and objectives will not be achieved.
Fundamental Analysis
Because information obtained for performing fundamental analysis may be incorrect, the analysis may not
provide an accurate estimate of earnings, which may be the basis for a security’s value. In addition, the
assumptions used in fundamental analysis may not adequately reflect what will occur in the future, which
can dramatically impact the results of the analysis.
Passive Investing
A portfolio that employs a passive, efficient markets approach has the potential risk at times to generate
lower-than-expected returns for the broader allocation than might be the case for a more narrowly focused
Blue Barn Wealth, LLC
Form ADV Part 2A
Last Updated: March 31, 2025
Page 18 of 32
asset class, and the return on each type of asset may be a deviation from the average return for the asset
class.
Research Data
When research and analyses are based on commercially available software, rating services, general market
and financial information, or due diligence reviews, a firm is relying on the accuracy and validity of the
information or capabilities provided by selected vendors, rating services, market data, and the issuers
themselves. Therefore, while our firm makes every effort to determine the accuracy of the information
received, we cannot predict the outcome of events or actions taken or not taken, or the validity of all
information researched or provided which may or may not affect the advice on or investment management
of an account.
Long-Term Trading
Long-term trading is designed to capture market rates of both return and risk. Due to its nature, the long-
term investment strategy can expose clients to various types of risk that will typically surface at various
intervals during the time the client owns the investments. These risks include but are not limited to inflation
(purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk.
Margin Transactions
Margin transactions use leverage that is borrowed from a brokerage firm as collateral. When losses occur,
the value of the margin account may fall below the brokerage firm’s threshold thereby triggering a margin
call. This may force the account holder to either allocate more funds to the account or sell assets on a shorter
time frame than desired.
Selection of Other Advisers
Although we seek to select only money managers who will invest clients' assets with the highest level of
integrity, our selection process cannot ensure that money managers will perform as desired. We also have
no control over the day-to-day operations of any of our selected money managers. We would not necessarily
be aware of certain activities at the underlying money manager level, including without limitation a money
manager's engaging in unreported risks, investment “style drift,” or even regulatory breaches or fraud.
Security-Specific Material Risks
Clients should be aware that there is a material risk of loss using any investment strategy. The investment
types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or
insured by the FDIC or any other government agency.
Equity (Stock) Risks
Equity investment generally refers to buying shares of stocks in return for receiving a future payment of
dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate
in response to specific situations for each company, industry conditions and the general economic
environments. Stocks are susceptible to general stock market fluctuations and to volatile increases or
decreases in value as market confidence in and perceptions of their issuers change. If an investor held
common stock or common stock equivalents of any given issuer, they may be exposed to greater risk than
if they held preferred stocks and debt obligations of the issuer.
Some types of stocks carry more risk than others. For example, small companies often have narrower
markets and limited financial resources, so investments in these stocks present more risk than investments
in larger, more established companies. Value Stocks, which are companies that are thought to be “under-
valued,” may never reach their full estimated market value, and they may underperform growth stocks or
other investments during given periods.
Blue Barn Wealth, LLC
Form ADV Part 2A
Last Updated: March 31, 2025
Page 19 of 32
Fixed Income Risks
Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments
can vary. This type of investment can include corporate and government debt securities, leveraged loans,
high yield, and investment grade debt and structured products, such as mortgage and other asset-backed
securities, although individual bonds may be the best-known type of fixed income security. In general, the
fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise,
bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.)
Fixed income securities also carry inflation risk, liquidity risk, call risk, duration risk, reinvestment risk, and
credit and default risks for both issuers and counterparties. The risk of default on treasury inflation
protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (which is generally
considered to be extremely unlikely); however, they carry a potential risk of losing share price value, albeit
rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S.
investing described below.
ETF and Mutual Fund Risks
The risks of owning ETFs and mutual funds reflect their underlying securities (e.g., stocks, bonds, securities
futures, etc.) and may result in investment losses. These forms of securities typically carry additional
expenses based on their share of operating expenses and certain brokerage fees, which lower investment
returns and may result in the potential duplication of certain fees. We do not recommend leveraged or
inverse ETFs due to their inherent heightened risks.
Real Estate Risks
Real estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which
historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows
may be adversely affected by: changes in local real estate market conditions due to changes in national or
local economic conditions or changes in local property market characteristics; competition from other
properties offering the same or similar services; changes in interest rates and in the state of the debt and
equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other
operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning
laws; the impact of present or future environmental legislation and compliance with environmental laws.
Annuities Risks
Annuities are a retirement product for those who may have the ability to pay a premium now and want to
guarantee (based on the creditworthiness of the insurance company) that they receive certain monthly
payments or a return on investment later in the future. Annuities are contracts issued by a life insurance
company designed to meet requirement or other long-term goals. An annuity is not a life insurance policy.
Variable annuities are designed to be long-term investments, to meet retirement and other long-range goals.
Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance
company charges may apply if you withdraw your money early. Variable annuities also involve investment
risks, just as mutual funds do.
Options Risks
There are various risks involving options trading which are detailed in the Chicago Board Options Exchange’s
“The Characteristics and Risks of Standardized Options” brochure that we will provide to you upon request
or may be found at their website at: http://www.cboe.com.
Private Placements Risks
Private placements carry a substantial risk as they are subject to less regulation than are publicly offered
securities, the market to resell these assets under applicable securities laws may be illiquid, due to
Blue Barn Wealth, LLC
Form ADV Part 2A
Last Updated: March 31, 2025
Page 20 of 32
restrictions, and the liquidation may be taken at a substantial discount to the underlying value or result in
the entire loss of the value of such assets.
Investing in limited partnerships involves certain risks related to investing in their underlying assets, as well
as the risks associated with pooled investment vehicles (certain pooled investments may be less regulated
than others). In addition, limited partnerships that concentrate in an industry or a geographic region are
subject to risks associated with that specific industry or region. A potential benefit derived from a limited
partnership is also dependent on the holding being treated as a partnership for federal income tax purposes;
if part or all the limited partnership is not, it may have potentially adverse tax consequences on the portfolio.
Hedge Fund Risks
Hedge funds often engage in leveraging and other speculative investment practices that may increase the
risk of loss; can be highly illiquid; are not required to provide periodic pricing or valuation information to
investors; may involve complex tax structures and delays in distributing important tax information; are not
subject to the same regulatory requirements as mutual funds; and often charge high fees. In addition, hedge
funds may invest in risky securities and engage in risky strategies.
Private Equity Risks
Private equity funds carry certain risks. Capital calls can be made on short notice, and the failure to meet
capital calls can result in significant adverse consequences, including but not limited to a total loss of
investment.
Venture Capital Funds
Venture capital funds invest in start-up companies at an early stage of development in the interest of
generating a return through an eventual realization event; the risk is high as a result of the uncertainty
involved at that stage of development.
Commodities
Commodities are tangible assets used to manufacture and produce goods or services. Commodity prices are
affected by different risk factors, such as disease, storage capacity, supply, demand, delivery constraints,
and weather. Because of those risk factors, even a well-diversified investment, such as through a mutual
fund or ETF, in commodities can be uncertain.
Non-U.S. Securities
Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social
unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public
information available.
Alternative Investments
Alternative investments involve a high degree of risk and can be illiquid due to restrictions on transfer and
lack of a secondary trading market. They can be highly leveraged, speculative and volatile, and an investor
could lose all or a substantial amount of an investment
.
Item 9: Disciplinary Information
Criminal or Civil Actions
Blue Barn Wealth and its management have not been involved in any criminal or civil action.
Blue Barn Wealth, LLC
Form ADV Part 2A
Last Updated: March 31, 2025
Page 21 of 32
Administrative Enforcement Proceedings
Blue Barn Wealth and its management have not been involved in administrative enforcement proceedings.
Self- Regulatory Organization Enforcement Proceedings
Blue Barn Wealth and its management have not been involved in any self-regulatory organizational
enforcement proceedings that are material to a Client’s or prospective Client’s evaluation of Blue Barn
Wealth or the integrity of its management.
Item 10: Other Financial Industry Activities and Affiliations
Broker-Dealer or Representative Registration
Our advisory firm is not registered nor has an application pending to register as a Financial Industry
Regulatory Authority (FINRA) member firm, nor are we required to be registered with such entities. Our
representatives are not registered or have pending applications to become a representative of a broker-
dealer, nor are they required to do so.
Futures or Commodity Registration
Our advisory firm is not registered nor has an application pending to register as a National Futures
Association (NFA) member firm, nor are we required to be registered with such entities. Our representatives
are not registered or have pending applications to become a representative of a futures commission
merchant, commodity pool operator, or commodity trading advisor, nor are they required to do so.
Material Relationships Maintained by this Advisory Business and
Conflicts of Interest
Neither our firm nor its management is or has a material relationship with any of the following types of
entities:
•
•
•
•
•
•
•
•
•
•
accounting firm or accountant
another financial planning firm
bank, credit union or thrift institution, or their separately identifiable department or division
insurance company or insurance agency
lawyer or law firm
pension consultant
real estate broker or dealer
sponsor or syndicator of limited partnerships
trust company
issuer of a security, to include investment company or other pooled investment vehicle
(including a mutual fund, closed-end investment company, unit investment trust, private
investment company or “hedge fund,” and offshore fund)
Blue Barn Wealth, LLC
Form ADV Part 2A
Last Updated: March 31, 2025
Page 22 of 32
Recommendations or Selections of Other Investment Advisors
and Conflicts of Interest
As referenced in Item 4 of this brochure, we may recommend pre-screened, sub-advisors (who are also
required to be registered as investment advisers) to service part of or the entire client portfolio. In such
cases, clients will pay Blue Barn Wealth its standard fee (as described in Item 5) in addition to the standard
fee for the advisers to which it directs those clients. This relationship will be memorialized in each contract
between Blue Barn Wealth and each third-party advisor. The fees will not exceed any limit imposed by any
regulatory agency. Blue Barn Wealth will always act in the best interests of our clients, including when
determining which, if any, third-party investment adviser to recommend to clients. Blue Barn Wealth will
ensure that all recommended advisers are licensed, or notice filed in the states in which Blue Barn Wealth
is recommending them to clients.
Sub-Advisors will maintain the models or investment strategies agreed upon between Sub-Advisor and Blue
Barn Wealth. Sub-Advisors execute all trades on behalf of Blue Barn Wealth in Client accounts. Blue Barn
Wealth will be responsible for the overall direct relationship with the Client. Blue Barn Wealth retains the
authority to terminate the Sub-Advisor relationship at Blue Barn Wealth’s discretion.
In addition to the authority granted to Blue Barn Wealth, Clients will grant Blue Barn Wealth full
discretionary authority and authorizes Blue Barn Wealth to select and appoint one or more independent
investment advisors (“Advisors”) to provide investment advisory services to Client without prior consultation
with or the prior consent of Client. Such Advisors shall have all of the same authority relating to the
management of Client’s investment accounts as is granted to Blue Barn Wealth in the Agreement.
Clients are welcome to review all of our investment program offerings and their stated fee ranges, and they
should review their fee schedule referenced in their agreement with our firm before the engagement. There
is the potential for clients’ fees assessed via a sub-advisor engagement to be higher than had a client
obtained those services directly from that portfolio manager. As stated in Item 5, each client has the option
to purchase recommended or similar investments through their own selected service provider. It should be
noted that certain sub-advisors may not be available to self-directed investors.
Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
Blue Barn Wealth and its associates will act in the utmost good faith, performing in a manner believed to be
in the best interest of our clients. We believe that our business methodologies, ethics rules, and adopted
policies are designed to eliminate or at least minimize material conflicts of interest, and to appropriately
manage any material conflicts of interest that may remain. It is important to point out that no set of rules
can anticipate or relieve all material conflicts of interest. Our firm will disclose to its advisory clients any
material conflict of interest relating to the firm, its representatives, or any of its employees which could
reasonably be expected to impair the rendering of unbiased and objective advice.
Code of Ethics Description
We have adopted a Code of Ethics that establishes policies for ethical conduct for our personnel. Our firm
accepts the obligation not only to comply with all applicable laws and regulations but also to act in an ethical
and professionally responsible manner in all professional services and activities. Firm policies include
provisions relating to the confidentiality of client information and prohibitions against insider trading,
circulation of industry rumors, and certain political contributions, among others. We periodically review and
Blue Barn Wealth, LLC
Form ADV Part 2A
Last Updated: March 31, 2025
Page 23 of 32
amend our Code of Ethics to ensure that they remain current, and we require firm personnel to annually
attest to their understanding of and adherence to the firm’s Code of Ethics. A copy of the firm’s Code of
Ethics is made available to any client or prospective client upon request.
Investment Recommendations Involving a Material Financial
Interest and Conflict of Interest
Blue Barn Wealth does not recommend that clients buy or sell any security in which Blue Barn Wealth or a
related person to Blue Barn Wealth has a material financial interest. An associate of Blue Barn Wealth is
prohibited from borrowing from or lending to a client unless the client is an approved lending institution.
Blue Barn Wealth does not trade for its own account (e.g., proprietary trading).
Advisory Firm Purchase of Same Securities Recommended to
Clients and Conflicts of Interest
From time to time, representatives of Blue Barn Wealth may buy or sell securities for themselves that they
also recommend to clients. This may provide an opportunity for representatives of Blue Barn Wealth to buy
or sell the same securities before or after recommending the same securities to clients, resulting in
representatives profiting off the recommendations they provide to clients. Such transactions may create a
conflict of interest; however, no person employed by the firm shall prefer his or her own interest to that of
the client nor make personal investment decisions based on investment decisions of the clients. As such,
Blue Barn Wealth will not engage in trading that operates to the client’s disadvantage if representatives of
Blue Barn Wealth buy or sell securities at or around the same time as clients.
The Chief Compliance Officer of Blue Barn Wealth is Jeff Brimhall. He reviews all trades of the affiliated
persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons
does not affect the markets and that Clients of the firm receive preferential treatment over associated
persons’ transactions.
Client Securities Recommendations or Trades and Concurrent
Advisory Firm Securities Transactions and Conflicts of Interest
Blue Barn Wealth does not have a material financial interest in any securities being recommended. However,
affiliated persons may buy or sell securities at the same time they buy or sell securities for Clients. In order
to mitigate conflicts of interest such as front running, affiliated persons are required to disclose all reportable
securities transactions as well as provide Blue Barn Wealth with copies of their brokerage statements.
The Chief Compliance Officer of Blue Barn Wealth is Jeff Brimhall. He reviews all trades of the affiliated
persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons
does not affect the markets and that Clients of the firm receive preferential treatment over associated
persons’ transactions.
Item 12: Brokerage Practices
Factors Used to Select Custodians and/or Broker/Dealers
Blue Barn Wealth does not maintain physical custody of client assets (see Item 15). Accounts must be
separately maintained by a qualified custodian (generally a broker-dealer, bank, or trust company) that is
frequently reviewed for its capabilities to serve in that capacity by their respective industry regulatory
authority. Our firm is not a custodian nor is there an affiliate that is a custodian.
Blue Barn Wealth, LLC
Form ADV Part 2A
Last Updated: March 31, 2025
Page 24 of 32
When engaged to provide an investment consultation component of our financial planning service, we may
recommend the service provider where client assets are currently maintained. Should a client prefer a new
service provider, a recommendation made by the firm would be based on client need, overall cost, and ease
of use.
We prefer that our wealth management services clients use Schwab Institutional, a division of Charles
Schwab & Co., Inc., a registered broker-dealer and member of FINRA/SIPC, to maintain custody of the
client’s assets and to effect trades for their accounts. Our firm is independently owned and operated; we
are not legally affiliated with Schwab Institutional. While we recommend Schwab Institutional as custodian
of record, the client will decide whether to do so and will open their account in their name with the custodian
by entering into an agreement directly with them. We do not technically open the account for a client, but
we will assist the client in doing so. If a client does not wish to place their assets with Schwab Institutional
as the custodian of record, we may be able to serve as investment adviser with another custodian of the
client’s choice, if the other custodian’s policies allow us to do so.
Schwab Institutional offers independent investment advisers various services which include custody of
client assets, trade execution, clearance and settlement, etc. Our firm may receive certain benefits from
Schwab Institutional through participation in its independent adviser support program (please refer to Item
14 for further details), however, there is no direct link between our firm’s participation in their program and
the investment advice we may provide to our clients. Our firm periodically conducts an assessment of any
recommended service provider (including Schwab Institutional) which generally involves a review of the
range and quality of services, reasonableness of fees, among other items, and in comparison to industry
peers. We do not receive referrals from our custodian, nor are client referrals a factor in our selection of our
custodian.
While Blue Barn Wealth has no formal soft dollars program in which soft dollars are used to pay for third
party services, we may receive research, products, or other services from custodians and broker-dealers in
connection with client securities transactions (“soft dollar benefits”). We may enter into soft-dollar
arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities
Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from
soft dollar research, whether or not the client’s transactions paid for it, and we do not seek to allocate
benefits to client accounts proportionate to any soft dollar credits generated by the accounts. We benefit
by not having to produce or pay for the research, products or services, and we may have an incentive to
recommend a broker-dealer based on receiving research or services. Clients should be aware that our
acceptance of soft dollar benefits may result in higher commissions charged to the client; however, we do
not consider any of these additional benefits, which include research or soft dollar benefits, to be a factor in
our selection of Schwab Institutional, and there is no conflict of interest in not having to pay for them.
Best Execution
“Best execution” means the most favorable terms for a transaction based on all relevant factors, including
those listed in the earlier paragraphs and in Item 14. We recognize our obligation in seeking best execution
for our clients; however, it is our belief that the determinative factor is not always the lowest possible cost
but whether the selected custodian’s transactions represent the best “qualitative execution” while taking
into consideration the full range of services provided. Our firm will seek services involving competitive rates,
but it may not necessarily correlate into the lowest possible rate for each transaction. We have determined
that having our wealth management clients’ accounts trades completed through our recommended
custodian is consistent with our obligation to seek best execution of client trades. A review is regularly
conducted with regard to recommending a custodian to our clients in light of our duty to seek best execution.
Blue Barn Wealth, LLC
Form ADV Part 2A
Last Updated: March 31, 2025
Page 25 of 32
Directed Brokerage
Our internal policy and operational relationship with our custodian requires client accounts custodied with
them to have trades executed per their order routing requirements. We do not direct which executing broker
should be selected for client account trades; whether that is an affiliate of our preferred custodian or another
executing broker of our custodian’s choice. As a result, the client may pay higher commissions or other
transaction costs, experience greater spreads, or receive less favorable net prices on transactions than might
otherwise be the case. In addition, since we routinely recommend a custodian to our advisory clients, and
that custodian may choose to use the execution services of its broker affiliate for some or all of our client
account transactions, there is an inherent conflict of interest involving our recommendation since our
advisory firm receives various products or services described in Item 14 from that custodian. Note that we
are not compensated for trade routing/order flow, nor are we paid commissions on such trades. We do not
receive interest on an account’s cash balance.
Client accounts maintained at our custodian are unable to direct brokerage. As a result, they may pay higher
commissions or other transaction costs, potentially experience greater spreads, or receive less favorable net
prices on transactions for their account than would otherwise be the case if they had the opportunity to
direct brokerage.
For accounts maintained at a custodian of the client’s choice (e.g., held-away accounts), the client may
choose to request that a particular broker is used to execute some or all account transactions. Under these
circumstances, the client will be responsible for negotiating, in advance of each trade, the terms and/or
arrangements involving their account with that broker, and whether the selected broker is affiliated with
their custodian of record or not. We will not be obligated to seek better execution services or prices from
these other brokers, and we will be unable to aggregate transactions for execution via our custodian with
other orders for accounts managed by our firm. As a result, the client may pay higher commissions or other
transaction costs, potentially experience greater spreads, or receive less favorable net prices on transactions
for their account than would otherwise be the case.
Brokerage for Client Referrals
We do not receive referrals from our preferred custodian, nor are client referrals a factor in our selection of
a custodian. However, Schwab maintains a website, https://www.findyourindependentadvisor.com, where
interested individuals can search for firms that custody at Schwab.
Aggregating Securities Transactions for Client Accounts
Trade aggregation involves the purchase or sale of the same security for several clients/accounts at
approximately the same time. This may also be termed “blocked” or “batched” orders. Aggregated orders are
effected in an attempt to obtain better execution, negotiate favorable transaction rates, or to allocate
equitably among multiple client accounts should there be differences in prices, brokerage commissions or
other transactional costs that might otherwise be unobtainable through separately placed orders. Our firm
may, but is not obligated, to aggregate orders, and our firm does not receive additional compensation or
remuneration as a result of aggregated transactions.
Transaction charges and/or prices may vary due to account size and/or method of receipt. To the extent
that the firm determines to aggregate client orders for the purchase or sale of securities, including securities
in which a related person may invest, the firm will generally do so in accordance with the parameters set
forth in SEC No-Action Letter, SMC Capital, Inc., or similar guidance if the jurisdiction in which the client
resides provides such direction.
Blue Barn Wealth, LLC
Form ADV Part 2A
Last Updated: March 31, 2025
Page 26 of 32
Please note that when trade aggregation is not allowed or infeasible and necessitates individual transactions
(e.g., withdrawal or liquidation requests, odd-lot trades, non-discretionary accounts, etc.), an account may
potentially be assessed higher costs or less favorable prices than those where aggregation has occurred.
Blue Barn Wealth is authorized in its discretion to aggregate purchases and sales and other transactions
made for the account with purchases and sales and transactions in the same securities for other Clients of
Blue Barn Wealth.
We review firm trading processes on a periodic basis to ensure they remain within stated policies and
regulation. Our clients will be informed, in advance, should trading practices materially change at any point
in the future.
Item 13: Review of Accounts
Schedule for Periodic Review of Client Accounts or Financial
Plans and Advisory Persons Involved
Financial Planning Services
Periodic financial check-ups or reviews are recommended if you are receiving our Financial Planning
Services. We believe they should occur on an annual basis whenever practical. Reviews are conducted by
one of our investment adviser representatives and typically involve analysis and possible revision of your
previous financial plan and/or investment allocation. A copy of revised plans or asset allocation reports will
be provided to the client upon request. Unless provided for in your engagement agreement, reviews are
generally conducted under a new or amended agreement and will be assessed at our current fee rate.
Portfolio Management Services
Investment accounts are reviewed by one of our investment adviser representatives on a quarterly or more
frequent basis to assess asset allocation and investment performance. Client-level reviews are also
recommended on at least an annual basis. A copy of a revised investment guideline or asset allocation report
will be provided to the client upon request.
Review of Client Accounts on Non-Periodic Basis
Financial Planning Engagements
You should contact our firm for additional reviews when you anticipate or have experienced changes in your
financial situation (e.g., changes in employment, an inheritance, the birth of a new child, etc.), or should you
prefer to change requirements involving your investment account. Non-periodic reviews are conducted by
one of our investment adviser representatives, and fees may be assessed at our published rate. A copy of
revised plans or asset allocation reports will be provided to the client upon request.
Portfolio Management Engagements
Additional reviews by your investment adviser representative may be triggered by news or research related
to a specific holding, a change in our view of the investment merits of a holding, or news related to the
macroeconomic climate affecting a sector or holding within that sector. A portfolio may be reviewed for an
additional holding or when an increase in a current position is under consideration. Account cash levels
above or below what we deem appropriate for the investment environment, given the client's stated
tolerance for risk and investment objectives, may also trigger a review.
Blue Barn Wealth, LLC
Form ADV Part 2A
Last Updated: March 31, 2025
Page 27 of 32
Content and Frequency of Regular Reports Provided to Clients
Each client of our advisory services provided on an ongoing basis will receive a quarterly report detailing the
client’s account, including assets held, asset value, asset allocation, investment performance, and invoice
showing the calculation of fees.
Whether you have opened and maintained an investment account on your own or with our assistance, you
will receive account statements sent directly from custodians (e.g., Schwab Institutional), mutual fund
companies, transfer agents, brokerage companies, and other third-party investment managers where your
investments are held. We do not back-test nor certify reports from an external party. We urge you to
carefully review and compare these account statements for accuracy and clarity, and to ask questions when
something is not clear.
Clients that receive periodic reports from our advisory firm that includes investment performance
information are urged to carefully review and compare these reports with their account statements that
they have received directly from their custodian of record.
Item 14: Client Referrals and Other Compensation
Economic Benefits Provided to the Advisory Firm from External
Sources and Conflicts of Interest
As disclosed in Item 12, our firm may receive economic benefit from Schwab Institutional in the form of
various products and services they make available to the firm and other independent investment advisers
that may not be made available to a “retail investor.” There is no direct link between our firm’s participation
in their program and the investment advice we may provide to our clients. These benefits may include the
following products and services (provided either without cost or at a discount):
•
•
•
•
•
•
•
•
•
receipt of duplicate client statements and confirmations
research related products and tools
access to trading desks serving our clients
access to block trading services
the ability to have advisory fees deducted directly from a client’s accounts (per written
agreement)
resource information related to capital markets and various investments
access to an electronic communications networks for client order entry and account information
access to mutual funds with no transaction fees and/or select investment managers
discounts on marketing, research, technology, and practice management products or services
provided to our firm by third-party providers
Some of the noted products and services made available by Schwab Institutional may benefit our advisory
firm but may not directly benefit a client account, and certain research and other previously referenced
services may qualify as "brokerage or research services" under Section 28(e) of the Securities Exchange Act
of 1934. The availability of these services from Schwab Institutional benefits our firm because it does not
have to produce or purchase them as long as firm clients maintain assets in accounts at Schwab Institutional.
These benefits create a conflict of interest, since our firm has an incentive to select or recommend a
custodian based on our firm’s interest in receiving these benefits rather than your interest in receiving
favorable trade execution. However, it is important to mention that the benefit received by our firm through
participation in any custodian’s program does not depend on the amount of brokerage transactions directed
Blue Barn Wealth, LLC
Form ADV Part 2A
Last Updated: March 31, 2025
Page 28 of 32
to that custodian, and our selection of a custodian is primarily supported by the scope, quality, and cost of
services provided as a whole—not just those services that benefit only our advisory firm. Further, we will act
in the best interest of our clients regardless of the custodian we may select. Please refer to Items 10 and 12
for additional information with respect to our offerings and the potential conflict of interest they may
present.
Advisory Firm Payments for Client Referrals
We do not engage in solicitation activities involving unregistered persons. If we offer an introduction to a
client, we do not earn a referral fee, nor are there established quid pro quo arrangements. Each client has
the right to accept or deny such referral or subsequent services.
An associate of the firm may hold individual membership or serve on boards or committees of professional
industry associations. Generally, participation in any of these entities require membership fees to be paid,
adherence to ethical guidelines, as well as in meeting experiential and educational requirements. A benefit
these entities may provide to the investing public is the availability of online search tools that allow
interested parties (prospective clients) to search for individual participants within a selected state or region.
These passive websites may provide means for interested persons to contact a participant via email,
telephone number, or other contact information, in order to interview the participating member.
The public may also choose to telephone association staff to inquire about an individual within their area
and would receive the same or similar information. A portion of these participant’s membership fees may be
used so that their name will be listed in some or all of these entities’ websites (or other listings). Prospective
clients locating our advisory firm or an associate via these methods are not actively marketed by the noted
associations. Clients who find our firm in this way do not pay more for their services than clients referred in
any other fashion. The firm does not pay these entities for prospective client referrals, nor is there a fee-
sharing arrangement reflective of a solicitor engagement.
We also engage independent solicitors to provide client referrals. If a client is referred to us by a solicitor,
this practice is disclosed to the client in writing by the solicitor, and we pay the solicitor out of our own
funds—specifically, we generally pay the solicitor a portion of the advisory fees earned for managing the
capital of the client that was referred. The use of solicitors is strictly regulated under applicable federal and
state law. Our policy is to fully comply with the requirements of Rule 206(4)-3, under the Investment
Advisers Act of 1940, as amended, and similar state rules, as applicable.
One of the companies from which we may receive client referrals is Zoe Financial, Inc through our
participation in the Zoe Advisor Network (ZAN). Zoe Financial, Inc is independent of and unaffiliated with
Blue Barn Wealth, and there is no employee relationship between us. Zoe Financial does not supervise Blue
Barn Wealth and has no responsibility for our management of client portfolios or our other advice or
services. We pay Zoe Financial an on-going fee for each successful client referral. This fee is usually a
percentage of the advisory fee that the client pays to us (“Solicitation Fee”). We will not charge clients
referred through Zoe Advisor Network any fees or costs higher than our standard fee schedule offered to
our clients. The Zoe Financial Disclosure and Acknowledgement Form are provided to all prospective clients
referred through ZAN.
Blue Barn Wealth, LLC
Form ADV Part 2A
Last Updated: March 31, 2025
Page 29 of 32
Item 15: Custody
Account Statements
Client accounts are to be maintained by an unaffiliated, qualified custodian. Assets are not held by our firm
or any associate of our firm. In keeping with this policy involving our clients’ funds or securities, Blue Barn
Wealth:
•
•
•
•
Prohibits any associate from having authority to directly withdraw securities or cash assets from
a client account. Although we may be deemed to have “constructive custody” of the client
accounts since we may request the withdrawal of advisory fees from an account, we will only
do so through the engagement of a qualified custodian maintaining the client assets, via the
client’s prior written approval, and following our delivery of our written notice;
Does not accept or forward client securities (e.g., stock certificates) erroneously delivered to
our firm;
Will not collect advance fees of $1,200 or more for services that are to be performed six months
or more into the future; and
Will not authorize an associate to have knowledge of a client’s account access information (e.g.,
online 401(k), brokerage or bank accounts) if such access would allow physical control over
account assets.
The custodian of record will provide the client with the account transaction confirmations and statements,
which will include all debits and credits, as well as reference to our firm’s advisory fee for that period.
Statements are provided on at least a quarterly basis and confirmations are provided as transactions occur
within the client account.
Blue Barn Wealth is deemed to have limited custody solely because advisory fees are directly deducted from
Client’s accounts by the custodian on behalf of Blue Barn Wealth.
Blue Barn Wealth is also deemed to have limited custody due to its Third-Party Standing Letters of
Authorization (“SLOA”).
Blue Barn Wealth and its qualified custodian meet the following seven (7) conditions in order to avoid
maintaining full custody and be subject to the surprise exam requirement:
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.
1.
The Client authorizes Blue Barn Wealth, 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.
2.
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.
3.
The Client has the ability to terminate or change the instruction to the Client’s qualified custodian.
4.
Blue Barn Wealth 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.
5.
Blue Barn Wealth maintains records showing that the third party is not a related party nor located at
the same address as Blue Barn Wealth.
6.
Blue Barn Wealth, LLC
Form ADV Part 2A
Last Updated: March 31, 2025
Page 30 of 32
The Client’s qualified custodian sends the Client, in writing, an initial notice confirming the instruction
and an annual notice reconfirming the instruction.
7.
Item 16: Investment Discretion
Discretionary Authority for Trading
We provide our portfolio management services on a discretionary basis. Similar to a limited power of
attorney, discretionary authority allows our firm or selected sub-advisor to implement investment decisions,
such as the purchase or sale of a security on behalf of the client account, without requiring the client’s prior
authorization for each transaction in order to meet the client’s stated investment objectives. We will also
have the authority to select or terminate sub-advisors without client prior approval. This authority will be
granted through the client’s execution of both our engagement agreement and the selected custodian’s
account opening documents. Note that the custodian will specifically limit our firm’s authority within our
clients’ accounts to the placement of trade orders, the request for the deduction of our advisory fee, and
other limited powers based on the client’s authorization, such as initiating money transfers to and from our
clients’ internal or external accounts.
Our firm prefers to not manage client accounts on a nondiscretionary basis, but we may accommodate such
requests on a case-by-case basis. Such account authority requires the client’s ongoing prior approval
involving the investment and reinvestment of account assets, portfolio rebalancing, or for our firm to give
instructions to the custodian maintaining the account.
Our advisory contract established with each client sets forth the discretionary authority for trading. Where
investment discretion has been granted, we generally manage the client’s account and makes investment
decisions without consultation with the client as to when the securities are to be bought or sold for the
account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per
share.
Item 17: Voting Client Securities
Proxy Votes
Our clients may periodically receive proxies or other similar solicitations sent directly from the custodian of
record or transfer agent. Should we receive a duplicate copy, we do not forward these or any
correspondence relating to the voting of the client securities, class action litigation, or other corporate
actions.
Our firm does not vote proxies on a client’s behalf, including those accounts that we have discretionary
authority over; nor do we offer specific guidance on how to vote proxies. Clients should direct all proxy
questions to the issuer of the security.
Item 18: Financial Information
Balance Sheet
Our firm will not take physical custody of your assets, nor do we have the type of account authority to have
such control. Fee withdrawals must be done through a qualified intermediary (e.g., your custodian of record),
Blue Barn Wealth, LLC
Form ADV Part 2A
Last Updated: March 31, 2025
Page 31 of 32
per your prior written agreement, and following your receipt of our firm’s written notice (termed
“constructive custody”).
Engagements with our firm do not require that we collect advance fees from a client of $1,200 or more for
our advisory services that we have agreed to perform six months or more into the future.
Neither our firm nor its management serve as general partner for a partnership or trustee for a trust in which
the firm’s advisory clients are either partners of the partnership or beneficiaries of the trust.
Due to the nature of our firm’s advisory services and operational practices, an audited balance sheet is not
required nor included in this brochure.
Financial Conditions Reasonably Likely to Impair Advisory Firm’s
Ability to Meet Commitments to Clients
The firm and its management do not have a financial condition likely to impair its ability to meet
commitments to clients.
Bankruptcy Petitions during the Past Ten Years
Blue Barn Wealth nor its management have been the subject of a bankruptcy petition in the last ten years.
Blue Barn Wealth, LLC
Form ADV Part 2A
Last Updated: March 31, 2025
Page 32 of 32