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D I S C L O S U R E B R O C H U R E
Main Office Address:
th
510 N. 17
Telephone
Facsimile
Avenue
Suite A
Wausau, WI 54401
: 715-355-4445
: 715-355-4445
Branch Office Address:
Telephone:
3621 E. Hamilton Ave
Eau Claire, WI 54701
715-318-4540
Cole@InvestWithBuska.com
www.InvestWithBuska.com
MARCH 19, 2025
This brochure provides information about the qualifications and business practices of Buska
Wealth Management, LLC. Being registered as a registered investment advisor does not imply
a certain level of skill or training. If you have any questions about the contents of this
brochure, please contact us at 715-355-4445. The information in this brochure has not been
approved or verified by the United States Securities and Exchange Commission, or by any
state securities authority.
Additional information about Buska Wealth Management, LLC (IARD#170627) is available on
the SEC’s website at www.adviserinfo.sec.gov
Item 2: Material Changes
Annual Update
Material Changes since the Last 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.
•
Since the last update on January 13, 2025, the following changes have occurred:
Full Brochure Available
Item 4 updated with new Vice President information.
This Firm Brochure being delivered is the complete brochure for the Firm.
ii
Item 3: Table of Contents
Form ADV – Part 2A – Firm Brochure
Item 1: Cover Page
Item 2: Material Changes .................................................................................................................... ii
Annual Update ................................................................................................................................................................... ii
Material Changes since the Last Update.................................................................................................................. ii
Item 3: Table of Contents ................................................................................................................... iii
Full Brochure Available .................................................................................................................................................. ii
Item 4: Advisory Business .................................................................................................................. 1
Firm Description ............................................................................................................................................................... 1
Types of Advisory Services ........................................................................................................................................... 1
Client Tailored Services and Client Imposed Restrictions ............................................................................... 3
Wrap Fee Programs ......................................................................................................................................................... 3
Item 5: Fees and Compensation ....................................................................................................... 3
Client Assets under Management .............................................................................................................................. 3
Method of Compensation and Fee Schedule .......................................................................................................... 3
Client Payment of Fees ................................................................................................................................................... 4
Additional Client Fees Charged ................................................................................................................................... 4
Prepayment of Client Fees ............................................................................................................................................ 4
Item 6: Performance-Based Fees and Side-by-Side Management ........................................ 4
External Compensation for the Sale of Securities to Clients ........................................................................... 4
Item 7: Types of Clients ....................................................................................................................... 5
Sharing of Capital Gains ................................................................................................................................................. 4
Description .......................................................................................................................................................................... 5
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................ 5
Account Minimums .......................................................................................................................................................... 5
Methods of Analysis ......................................................................................................................................................... 5
Investment Strategy ........................................................................................................................................................ 5
Item 9: Disciplinary Information ..................................................................................................... 8
Security Specific Material Risks .................................................................................................................................. 5
Criminal or Civil Actions ................................................................................................................................................ 8
Administrative Enforcement Proceedings ............................................................................................................. 8
Self-Regulatory Organization Enforcement Proceedings ................................................................................ 8
iii
Buska Wealth Management, LLC
Item 10: Other Financial Industry Activities and Affiliations ............................................... 9
Broker-Dealer or Representative Registration .................................................................................................... 9
Futures or Commodity Registration ......................................................................................................................... 9
Material Relationships Maintained by this Advisory Business and Conflicts of Interest ................... 9
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ................ 9
Trading ..................................................................................................................................................... 9
Code of Ethics Description ............................................................................................................................................ 9
Investment Recommendations Involving a Material Financial Interest and Conflict of Interest. 10
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest 10
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities
Item 12: Brokerage Practices ......................................................................................................... 10
Transactions and Conflicts of Interest .................................................................................................................. 10
Factors Used to Select Broker-Dealers for Client Transactions ................................................................. 10
Item 13: Review of Accounts ........................................................................................................... 11
Aggregating Securities Transactions for Client Accounts ............................................................................. 11
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons
Involved ............................................................................................................................................................................. 11
Review of Client Accounts on Non-Periodic Basis ........................................................................................... 11
Item 14: Client Referrals and Other Compensation ................................................................ 12
Content of Client Provided Reports and Frequency ........................................................................................ 12
Economic benefits provided to the Advisory Firm from External Sources and Conflicts of
Interest ............................................................................................................................................................................... 12
Item 15: Custody .................................................................................................................................. 12
Advisory Firm Payments for Client Referrals .................................................................................................... 12
Item 16: Investment Discretion ..................................................................................................... 12
Account Statements ...................................................................................................................................................... 12
Item 17: Voting Client Securities ................................................................................................... 13
Discretionary Authority for Trading...................................................................................................................... 12
Item 18: Financial Information ...................................................................................................... 13
Proxy Votes ...................................................................................................................................................................... 13
Balance Sheet .................................................................................................................................................................. 13
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments
to Clients ............................................................................................................................................................................ 13
Bankruptcy Petitions during the Past Ten Years .............................................................................................. 13
iv
Buska Wealth Management, LLC
Brochure Supplement (Part 2B of Form ADV) .......................................................................... 15
Principal Executive Officer ........................................................................................................................................ 15
Cole J. Bruner ................................................................................................................................................................... 15
Item 2 Business Experience and Educational Background .......................................................................... 15
Item 3 Disciplinary Information .............................................................................................................................. 15
Item 4 Other Business Activities ............................................................................................................................. 15
Item 5 Additional Compensation ............................................................................................................................ 15
Item 6 Supervision ........................................................................................................................................................ 16
v
Buska Wealth Management, LLC
Item 4: Advisory Business
Firm Description
Buska Wealth Management, LLC (“Advisor”, “We”, “Our”, “Firm” and “Us”) was formed in
2014 and became a registered investment advisor in 2014. Cole J. Bruner is 100% owner.
Kailey Berendsen is Vice President.
insurance, stocks, bonds, mutual
funds,
We are a fee based financial planning and investment advisory firm. The firm does not sell
annuities,
limited partnerships, or other
commissioned products, but the firm’s Managing Member sells insurance products through
an affiliated company, Buska Retirement Solutions, Inc.
Investment advice is an integral part of financial planning. In addition, We advise clients
regarding cash flow, college planning, retirement planning, tax planning and estate planning.
Types of Advisory Services
Other professionals (e.g., lawyers, accountants, tax preparers, insurance agents, etc.) are
engaged directly by the client on an as-needed basis and may charge fees of their own.
Conflicts of interest will be disclosed to the client in the event they should occur.
ASSET MANAGEMENT
Advisor offers discretionary asset management services to advisory Clients. Advisor will
offer Clients ongoing asset management services through determining individual investment
goals, time horizons, objectives, and risk tolerance. Investment strategies, investment
selection, asset allocation, portfolio monitoring and the overall investment program will be
based on the above factors. The Client will authorize Advisor discretionary authority to
execute selected investment program transactions as stated within the Investment Advisory
Agreement.
ERISA PLAN SERVICES
Advisor provides service to qualified and non-qualified retirement plans including 401(k)
plans, 403(b) plans, pension and profit-sharing plans, cash balance plans, and deferred
Limited Scope ERISA 3(21) Fiduciary.
compensation plans. Advisor acts as a 3(21):
Advisor typically acts as a limited scope ERISA 3(21)
fiduciary that can advise, help and assist plan sponsors with their investment decisions on a
non-discretionary basis. As an investment advisor 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 Advisor can help mitigate that plan sponsor’s liability by
following a diligent process.
1.
Fiduciary Services are:
Provide non-discretionary investment advice to the Client about asset classes and
investment alternatives 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. Advisor
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 non-discretionary investment advice to the Plan Sponsor with respect to
the selection of a qualified default investment alternative for participants who are
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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 alternatives available to them under the Plan. Client
understands the Advisor’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 Advisor is not providing fiduciary advice as define by ERISA to the Plan
participants. Advisor 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 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.
Assist in the group enrollment meetings designed to increase retirement plan
participation among the employees and investment and financial understanding by
the employees.
Meet with Client on a periodic basis to discuss the reports and the investment
recommendations.
Advisor may provide these services or, alternatively, may arrange for the Plan’s other
providers to offer these services, as agreed upon between Advisor and Client.
3.
Advisor has no responsibility to provide services related to the following types of assets
(“Excluded Assets”):
a.
b.
c.
d.
e.
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;
f.
not
g.
Other non-publicly traded securities or property (other than collective trusts and
similar vehicles); or
Other hard-to-value or illiquid securities or property.
be included in calculation of Fees paid to the Advisor under this
Excluded Assets will
Agreement.
FINANCIAL PLANNING AND CONSULTING
Advisor offers planning and consulting services to individuals and business owners. The
services cover all areas of financial planning to risk management and estate conservation.
We specialize in helping our clients develop a comprehensive and cohesive financial strategy
that fits their unique needs and enables them to meet both short and long term objectives. If
a conflict of interest exists between the interests of the investment advisor and the interests
of the client; the client is under no obligation to act upon the investment advisor’s
recommendation. If the client elects to act on any of the recommendations, the client is
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Client Tailored Services and Client Imposed Restrictions
under no obligation to effect the transaction through Advisor. Financial plans will be
completed and delivered inside of thirty (30) days.
Wrap Fee Programs
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 written client consent.
Client Assets under Management
We do not sponsor any wrap fee programs.
Advisor has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts:
$0
Date Calculated:
December 31, 2024
$393,600,000
Item 5: Fees and Compensation
Method of Compensation and Fee Schedule
ASSET MANAGEMENT
Advisor offers discretionary direct asset management services to advisory Clients. Advisor
charges an annual investment advisory fee based on the total assets under management as
follows:
Assets Under Management
Up to $1,000,000
$1,000,001 to $2,000,000
$2,000,001 to $3,000,000
$3,00,001 to $5,00,000
$5,000,001 to $10,000,000
Over $10,000,000
Annual Fee
1.00%
0.85%
0.75%
0.65%
0.50%
0.25%
Quarterly Fee
0.25%
0.2125%
0.1875%
0.1625%
0.125%
0.0625%
This is a tiered or breakpoint fee schedule, the entire portfolio is charged the same asset
management fee. For example, a Client with $750,000 under management would pay $7,500
on an annual basis. $750,000 x 1.00% = $7,500.
The annual fee may be negotiable based upon certain criteria (e.g., historical relationship,
type of assets, anticipated future earning capacity, anticipated future additional assets,
dollar amounts of assets to be managed, related accounts, account composition, negotiations
with Clients, etc.).
Fees are billed quarterly in arrears based on the amount of assets managed as of the close of
business on the last business day of the previous quarter. Lower fees for comparable
services may be available from other sources. Clients may terminate their account within
five (5) business days of signing the Investment Advisory Agreement with no obligation and
without penalty. Clients may terminate advisory services with thirty (30) days written
notice. For accounts opened or closed mid-billing period, unearned fees will be refunded to
the Client. Client shall be given thirty (30) days prior written notice of any increase in fees.
Any increase in fees will be acknowledged in writing by both parties before any increase in
said fees occurs.
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ERISA PLAN SERVICES
The annual fees are based on the market value of the Included Assets and will not exceed
1%. Fees are charged either monthly or quarterly in arrears 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) on the last business day of the previous quarter or month. If the
services to be provided start any time other than the first day of a quarter, 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 fee period, Advisor shall be entitled to a prorated fee
based on the number of days during the fee period services were provided.
The compensation of Advisor 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. Advisor does not reasonably expect to receive any additional
compensation, directly or indirectly, for its services under this Agreement. If additional
compensation is received, Advisor will disclose this compensation, the services rendered,
and the payer of compensation. Advisor will offset the compensation against the fees agreed
upon under this Agreement.
Client Payment of Fees
FINANCIAL PLANNING AND CONSULTING
Financial Planning and consulting is available for a negotiable fixed fee with a maximum of
$2500. Pricing will be according to the degree of complexity associated with the client’s
situation. Prior to the planning process the client is provided an estimated plan fee. The
payments are received at the conclusion of the planning process and is refundable based on
the pro-rata of work completed. If the client chooses to execute the plan, the fee may be
waived or reduced.
Additional Client Fees Charged
Fees for financial plans are due upon the completion of the services rendered.
Custodians may charge transaction fees on purchases or sales of certain mutual funds,
equities, and exchange-traded funds. These charges may include Mutual Fund transactions
fees, postage and handling and miscellaneous fees (fee levied to recover costs associated
with fees assessed by self-regulatory organizations). The selection of the security is more
important than the nominal fee that the custodian charges to buy or sell the security.
Prepayment of Client Fees
For more details on the brokerage practices, see Item 12 of this brochure.
External Compensation for the Sale of Securities to Clients
Fees for financial plans are due upon the completion of the services rendered.
Item 6: Performance-Based Fees and Side-by-Side Management
We do not receive any external compensation for the sale of securities to clients, nor do any
of the investment advisor representatives of the Firm.
Sharing of Capital Gains
Fees are not based on a share of the capital gains or capital appreciation of managed
securities.
We do not use a performance-based fee structure or participate in side-by-side management.
Performance-based compensation may create an incentive for the advisor to recommend an
investment that may carry a higher degree of risk to the client.
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Item 7: Types of Clients
Description
We generally provide investment advice to individuals.
Account Minimums
Client relationships vary in scope and length of service.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
We do not manage accounts therefore have no minimum.
Methods of Analysis
Security analysis methods may include fundamental analysis, technical analysis, and cyclical
analysis. Investing in securities involves risk of loss that clients should be prepared to bear.
Past performance is not a guarantee of future returns.
Fundamental analysis involves evaluating a stock using real data such as company revenues,
earnings, return on equity, and profits margins to determine underlying value and potential
growth. Technical analysis involves evaluating securities based on past prices and volume.
Cyclical analysis involves analyzing the cycles of the market.
When creating a financial plan, we utilize fundamental analysis to provide review of
insurance policies for economic value and income replacement. Technical analysis is used to
review mutual funds and individual stocks. The main sources of information include
Morningstar, client documents such as tax returns and insurance policies.
In developing a financial plan for a client, our analysis may include cash flow analysis,
investment planning, risk management, tax planning and estate planning. Based on the
information gathered, a detailed strategy is tailored to the client’s specific situation.
Investment Strategy
The main sources of information include financial newspapers and magazines, annual
reports, prospectuses, and filings with the Securities and Exchange Commission.
The investment strategy for a specific client is based upon the objectives stated by the client
during consultations. The client may change these objectives at any time.
Security Specific Material Risks
Other strategies may include long-term purchases, short-term purchases, trading, and option
writing (including covered options, uncovered options or spreading strategies).
• Market Risk
All investment programs have certain risks that are borne by the investor.
Our investment approach constantly keeps the risk of loss in mind. Investors face the
following investment risks and should discuss these risks with Advisor:
•
: The prices of securities held by mutual funds in which Clients invest
may decline in response to certain events taking place around the world, including
those directly involving the companies whose securities are owned by a fund;
conditions affecting the general economy; overall market changes; local, regional or
global political, social or economic instability; and currency, interest rate and
commodity price fluctuations. Investors should have a long-term perspective and
Interest-rate Risk
be able to tolerate potentially sharp declines in market value.
: Fluctuations in interest rates may cause investment prices to
fluctuate. For example, when interest rates rise, yields on existing bonds become
less attractive, causing their market values to decline.
- 5 -
Inflation Risk
•
• Currency Risk
: When any type of inflation is present, a dollar today will buy more
than a dollar next year, because purchasing power is eroding at the rate of inflation.
• Reinvestment 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.
• Liquidity Risk
: This is the risk that future proceeds from investments may have
to be reinvested at a potentially lower rate of return (i.e. interest rate). This
primarily relates to fixed income securities.
• Management Risk:
: Liquidity is the ability to readily convert an investment into cash.
Generally, assets are more liquid if many traders are interested in a standardized
product. For example, Treasury Bills are highly liquid, while real estate properties
are not.
• Equity Risk:
The advisor’s investment approach may fail to produce the
intended results. If the advisor’s assumptions regarding the performance of a
specific asset class or fund are not realized in the expected time frame, the overall
performance of the Client’s portfolio may suffer.
• Fixed Income Risk:
Equity securities tend to be more volatile than other investment
choices. The value of an individual mutual fund or ETF can be more volatile than
the market as a whole. This volatility affects the value of the Client’s overall
portfolio. Small and mid-cap companies are subject to additional risks. Smaller
companies may experience greater volatility, higher failure rates, more limited
markets, product lines, financial resources, and less management experience than
larger companies. Smaller companies may also have a lower trading volume, which
may disproportionately affect their market price, tending to make them fall more in
response to selling pressure than is the case with larger companies.
•
The issuer of a fixed income security may not be able to make
interest and principal payments when due. Generally, the lower the credit rating of
a security, the greater the risk that the issuer will default on its obligation. If a
rating agency gives a debt security a lower rating, the value of the debt security will
decline because investors will demand a higher rate of return. As nominal interest
rates rise, the value of fixed income securities held by a fund is likely to decrease. A
nominal interest rate is the sum of a real interest rate and an expected inflation
Investment Companies Risk:
rate.
When a Client invests in open end mutual funds or
ETFs, the Client indirectly bears their proportionate share of any fees and expenses
payable directly by those funds. Therefore, the Client will incur higher expenses,
which may be duplicative. In addition, the Client’s overall portfolio may be affected
by losses of an underlying fund and the level of risk arising from the investment
practices of an underlying fund (such as the use of derivatives). ETFs are also
subject to the following risks: (i) an ETF’s shares may trade at a market price that is
above or below their net asset value or (ii) trading of an ETF’s shares may be halted
if the listing exchange’s officials deem such action appropriate, the shares are de-
listed from the exchange, or the activation of market-wide “circuit breakers” (which
are tied to large decreases in stock prices) halts stock trading generally. Adviser has
no control over the risks taken by the underlying funds in which Client invests.
- 6 -
• REIT Risk:
• Derivatives Risk:
To the extent that a Client invests in REITs, it is subject to risks generally
associated with investing in real estate, such as (i) possible declines in the value of
real estate, (ii) adverse general and local economic conditions, (iii) possible lack of
availability of mortgage funds, (iv) changes in interest rates, and (v) environmental
problems. In addition, REITs are subject to certain other risks related specifically to
their structure and focus such as: dependency upon management skills; limited
diversification; the risks of locating and managing financing for projects; heavy
cash flow dependency; possible default by borrowers; the costs and potential losses
of self-liquidation of one or more holdings; the possibility of failing to maintain
exemptions from securities registration; and, in many cases, relatively small market
capitalization, which may result in less market liquidity and greater price volatility.
• Foreign Securities Risk:
Funds in a Client’s portfolio may use derivative instruments. The
value of these derivative instruments derives from the value of an underlying asset,
currency or index. Investments by a fund in such underlying funds may involve the
risk that the value of the underlying fund’s derivatives may rise or fall more rapidly
than other investments, and the risk that an underlying fund may lose more than
the amount that it invested in the derivative instrument in the first place.
Derivative instruments also involve the risk that other parties to the derivative
contract may fail to meet their obligations, which could cause losses.
• Long-term purchases
Funds in which Clients invest may invest in foreign
securities. Foreign securities are subject to additional risks not typically associated
with investments in domestic securities. These risks may include, among others,
currency risk, country risks (political, diplomatic, regional conflicts, terrorism, war,
social and economic instability, currency devaluations and policies that have the
effect of limiting or restricting foreign investment or the movement of assets),
different trading practices, less government supervision, less publicly available
information, limited trading markets and greater volatility. To the extent that
underlying funds invest in issuers located in emerging markets, the risk may be
heightened by political changes, changes in taxation, or currency controls that
could adversely affect the values of these investments. Emerging markets have
been more volatile than the markets of developed countries with more mature
economies.
long-term
investments
• Short-term purchases
: Long-term investments are those vehicles purchased with the
intension of being held for more than one year. Typically, the expectation of the
investment is to increase in value so that it can eventually be sold for a profit. In
addition, there may be an expectation for the investment to provide income. One of
the biggest risks associated with
is volatility, the
fluctuations in the financial markets that can cause investments to lose value.
• Trading risk
: Short-term investments are typically held for one year or
less. Generally, there is not a high expectation for a return or an increase in value.
Typically, short-term investments are purchased for the relatively greater degree of
principal protection they are designed to provide. Short-term investment vehicles
may be subject to purchasing power risk — the risk that your investment’s return
will not keep up with inflation.
: Investing involves risk, including possible loss of principal. There is no
assurance that the investment objective of any fund or investment will be achieved.
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• Options Trading
• Trading on Margin:
: The risks involved with trading options are that they are very time
sensitive investments. An options contract is generally a few months. The buyer of
an option could lose his or her entire investment even with a correct prediction
about the direction and magnitude of a particular price change if the price change
does not occur in the relevant time period (i.e., before the option expires).
Additionally, options are less tangible than some other investments. An option is a
“book-entry” only investment without a paper certificate of ownership.
• Equity Linked CD Risk:
In a cash account, the risk is limited to the amount of money
that has been invested. In a margin account, risk includes the amount of money
invested plus the amount that has been loaned. As market conditions fluctuate, the
value of marginable securities will also fluctuate, causing a change in the overall
account balance and debt ratio. As a result, if the value of the securities held in a
margin account depreciates, the Client will be required to deposit additional cash
or make full payment of the margin loan to bring account back up to maintenance
levels. Clients who cannot comply with such a margin call may be sold out or
bought in by the brokerage firm.
• Private Equity/Placement Risk:
Penalties may apply to early withdrawals. Fair market value
of CD’s when sold in the secondary market may be worth more or less than face
value. May or may not be FDIC insured. Returns are not based solely on market
returns, as there may be a maximum rate of interest the CD will earn. May be taxed
on income earned, but interest isn’t accrued (received) until the CD matures. Many
CDs may have “call” features, allowing the bank to close the contract early with no
penalty, paying back principle and any accrued interest.
Because offerings are exempt from registration
requirements, no regulator has reviewed the offerings to make sure the risks
associated with the investment and all material facts about the entity raising money
are adequately disclosed. Securities offered through private placements are
generally illiquid, meaning there are limited opportunities to resell the security.
Risk of the underlying investment may be significantly higher than publicly traded
investments.
•
The specific risks associated with financial planning include:
Risk of Loss
o
o
Client fails to follow our recommendations, resulting in market loss
Client has changes in financial status or lifestyle and therefore plan
recommendations are no longer valid
Item 9: Disciplinary Information
Criminal or Civil Actions
Administrative Enforcement Proceedings
The firm and its management have not been involved in any criminal or civil action.
Self-Regulatory Organization Enforcement Proceedings
The firm and its management have not been involved in administrative enforcement
proceedings.
The firm and its management have not been involved in legal or disciplinary events related
to past or present investment clients.
- 8 -
Item 10: Other Financial Industry Activities and Affiliations
Broker-Dealer or Representative Registration
Futures or Commodity Registration
Neither the Firm nor its employees are registered as a broker-dealer.
Material Relationships Maintained by this Advisory Business and Conflicts of Interest
Neither the Firm nor its employees are registered or have an application pending to register
as a futures commission merchant, commodity pool operator, or a commodity trading
advisor.
Managing Member Cole J. Bruner has a financial industry affiliated business as a licensed
insurance agent. From time to time, he will offer clients advice or products from those
activities. Approximately 70% of his time is spent in this business. Mr. Bruner receives
commissions from insurance companies on the products he sells.
Mr. Bruner is Managing Member of Legacy Tax Solutions, LLC, an affiliated tax planning and
preparation company. From time to time, he will offer clients advice or services from those
activities. Approximately 10% of his time is spent in this business. Mr. Bruner receives fees
for the services he provides.
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest
These practices represent conflicts of interest because it gives an incentive to recommend
products and services based on the commissions or fees received rather than on client’s
needs. This conflict is mitigated by disclosures, procedures, and the firm’s Fiduciary
obligation to place the best interest of the client first and the clients are not required to
purchase any products or services. Clients have the option to purchase these products
through another insurance agent or tax professional of their choosing.
Advisor does not select or recommend other investment advisors.
Item 11: Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Code of Ethics Description
The employees of the Firm have committed to a Code of Ethics (“Code”). The purpose of our
Code is to set forth standards of conduct expected of our employees and addresses conflicts
that may arise. The Code defines acceptable behavior for employees of the Firm. The Code
reflects the Firm and its supervised persons’ responsibility to act in the best interest of their
client.
One area the Code addresses is when employees buy or sell securities for their personal
accounts and how to mitigate any conflict of interest with our clients. We do not allow any
employees to use non-public material information for their personal profit or to use internal
research for their personal benefit in conflict with the benefit to our clients.
Our policy prohibits any person from acting upon or otherwise misusing non-public or
inside information. No advisory representative or other employee, officer or director of the
Firm may recommend any transaction in a security or its derivative to advisory clients or
engage in personal securities transactions for a security or its derivatives if the advisory
representative possesses material, non-public information regarding the security.
Our Code is based on the guiding principle that the interests of the client are our top priority.
Our officers, directors, advisors, and other employees have a fiduciary duty to our clients and
must diligently perform that duty to maintain the complete trust and confidence of our
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clients. When a conflict arises, it is our obligation to put the client’s interests over the
interests of either employees or the company.
The Code applies to “access” persons. “Access” persons are employees who have access to
non-public information regarding any clients' purchase or sale of securities, or non-public
information regarding the portfolio holdings of any reportable fund, who are involved in
making securities recommendations to clients, or who have access to such recommendations
that are non-public.
The firm will provide a copy of the Code of Ethics to any client or prospective client upon
Investment Recommendations Involving a Material Financial Interest and Conflict of
request.
Interest
The Firm and its employees do not recommend securities to clients in which we have a
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
material financial interest.
Interest
The Firm and its employees may buy or sell securities that are also held by clients. In order
to mitigate conflicts of interest such as front running, employees are required to disclose all
reportable securities transactions as well as provide us with copies of their brokerage
statements.
The Chief Compliance Officer of the Firm is Cole Bruner. He reviews all employee trades each
quarter. The personal trading reviews helps mitigate that the personal trading of employees
does not affect the markets and that clients of the firm have received preferential treatment
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities
over employee trade.
Transactions and Conflicts of Interest
We do not maintain a firm proprietary trading account and do not have a material financial
interest in any securities being recommended and therefore no conflicts of interest exist.
However, employees 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, employees are
required to disclose all reportable securities transactions as well as provide us with copies of
their brokerage statements.
Item 12: Brokerage Practices
Factors Used to Select Broker-Dealers for Client Transactions
• Directed Brokerage
Advisor may recommend the use of a particular broker-dealer or may utilize a broker-dealer
of the Client's choosing. Advisor will select appropriate brokers based on a number of factors
including but not limited to their relatively low transaction fees and reporting ability. Advisor
relies on its broker to provide its execution services at the best prices available. Lower fees for
comparable services may be available from other sources. Clients pay for any and all custodial
fees in addition to the advisory fee charged by Advisor.
In circumstances where a Client directs Advisor to use a certain broker-dealer, Advisor
still has a fiduciary duty to its Clients. The following may apply with Directed
Brokerage: Advisor's inability to negotiate commissions, to obtain volume discounts,
there may be a disparity in commission charges among Clients and conflicts of interest
arising from brokerage firm referrals.
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• Best Execution
• Soft Dollar Arrangements
Investment advisors who manage or supervise Client portfolios have a fiduciary
obligation of best execution. The determination of what may constitute best execution
and price in the execution of a securities transaction by a broker involves a number of
considerations and is subjective. Factors affecting brokerage selection include the
overall direct net economic result to the portfolios, the efficiency with which the
transaction is effected, the ability to effect the transaction where a large block is
involved, the operational facilities of the broker-dealer, the value of an ongoing
relationship with such broker and the financial strength and stability of the broker. The
firm does not receive any portion of the trading fees.
The Securities and Exchange Commission defines soft dollar practices as arrangement
under which products or services other than execution services are obtained by
Advisor from or through a broker-dealer in exchange for directing Client transactions
to the broker-dealer. As permitted by Section 28(e) of the Securities Exchange Act of
1934, Advisor receives economic benefits as a result of commissions generated from
securities transactions by the broker-dealer from the accounts of Advisor. These
benefits include both proprietary research from the broker and other research written
by third parties.
A conflict of interest exists when Advisor receives soft dollars. This conflict is mitigated
by the fact that Advisor has a fiduciary responsibility to act in the best interest of its
Clients and the services received are beneficial to all Clients.
Aggregating Securities Transactions for Client Accounts
Advisor utilizes the services of custodial broker dealers. Economic benefits are
received by Advisor which would not be received if Advisor did not give investment
advice to Clients. These benefits include: A dedicated trading desk, a dedicated service
group and an account services manager dedicated to Advisor's accounts, ability to
conduct "block" Client trades, electronic download of trades, balances and positions,
duplicate and batched Client statements, and the ability to have advisory fees directly
deducted from Client accounts.
Advisor 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 Advisor. All Clients participating in the aggregated order shall receive an
average share price with all other transaction costs shared on a pro-rated basis.
Item 13: Review of Accounts
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory
Persons Involved
Review of Client Accounts on Non-Periodic Basis
Accounts are reviewed quarterly by Cole Bruner, Chief Compliance Officer. Account reviews
are performed more frequently when market conditions dictate. Financial Plans are
considered complete when recommendations are delivered to the client and a review is
done only upon request of client.
Other conditions that may trigger a review of clients’ accounts are changes in the tax laws,
new investment information, and changes in a client's own situation.
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Content of Client Provided Reports and Frequency
Clients receive written account statements no less than quarterly for managed accounts.
Account statements are issued by Advisor’s custodian. Client receives confirmations of each
transaction in account from custodian and an additional statement during any month in
which a transaction occurs. Performance reports will be provided by Advisor at least
quarterly to Clients with assets under management
Under financial planning services, the client will receive a one-time written financial plan.
Item 14: Client Referrals and Other Compensation
Economic benefits provided to the Advisory Firm from External Sources and Conflicts of
Interest
Advisory Firm Payments for Client Referrals
Advisor does not receive any economic benefits from external sources.
Advisor may, from time to time, enter into agreements with individuals and organizations
(“referring party”) that refer Clients to Advisor in exchange for compensation. This activity
will either be considered an endorsement or testimonial, depending on if the referring party
is a Client of Advisor. For all Clients introduced by a referring party, Advisor may pay that
referring party a fee pursuant to a previously executed agreement. While the specific terms
of each agreement may differ, the compensation will be based upon Advisor’s engagement of
new Clients and is calculated using a fixed fee, or a varying percentage of the fees paid to
Advisor by such Clients. Any such fee shall be paid solely from Advisor’s investment
management fee and shall not result in any additional charge to the Client. Advisor ensures
that referring parties are registered with all appropriate jurisdictions or exempt from
registration as investment advisers or investment adviser representatives.
Each referred Client to Advisor under such an arrangement will receive a copy of this
brochure and a written disclosure clearly and prominently disclosing if the referring party is
a current Client or investor, the compensation that will be paid by Advisor to the referring
party and any material conflicts of interest. The referring party is required provide this
disclosure at the time the endorsement or testimonial is disseminated and will obtain the
Client’s signature acknowledging receipt of Advisor’s disclosure brochure and the written
disclosure.
Item 15: Custody
Account Statements
All assets are held at qualified custodians, which means the custodians provide account
statements directly to clients at their address of record at least quarterly. Clients are urged
to compare the account statements received directly from their custodians to any reports
prepared by Advisor or performance reports prepared by Advisor.
Advisor is deemed to have constructive custody solely because advisory fees are directly
deducted from Client’s accounts by the custodian on behalf of Advisor.
Item 16: Investment Discretion
Discretionary Authority for Trading
Advisor requires discretionary authority to manage securities accounts on behalf of Clients.
Advisor has the authority to determine, without obtaining specific Client consent, the
securities to be bought or sold, and the amount of the securities to be bought or sold. The
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client will authorize Advisor discretionary authority to execute selected investment
program transactions as stated within the Investment Advisory Agreement.
Advisor allows Client’s to place certain restrictions, as outlined in the Client’s Investment
Policy Statement or similar document. Such restrictions could include only allowing
purchases of socially conscious investments. These restrictions must be provided to Advisor
in writing.
The Client approves the custodian to be used and the commission rates paid to the
custodian. Advisor does not receive any portion of the transaction fees or commissions paid
by the Client to the custodian.
Item 17: Voting Client Securities
Proxy Votes
We do not vote proxies on securities. Clients are expected to vote their own proxies. The
client will receive their proxies directly from the custodian of their account or from a
transfer agent.
When assistance on voting proxies is requested, we will provide recommendations to the
client. If a conflict of interest exists, it will be disclosed to the client.
Item 18: Financial Information
Balance Sheet
A balance sheet is not required to be provided because we do not serve as a custodian for
client funds or securities and we do not require prepayment of fees of more than $1200 per
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet
client and six months or more in advance.
Commitments to Clients
Bankruptcy Petitions during the Past Ten Years
We have no condition that is reasonably likely to impair our ability to meet contractual
commitments to our clients.
No bankruptcy petitions to report.
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S U P E R V I S E D P E R S O N B R O C H U R E
F O R M A D V P A R T 2 B
Cole J. Bruner
Office Address:
th
510 N. 17
Telephone
Facsimile
. Avenue
Suite A
Wausau, WI 54401
: 715-355-4445
: 715-355-4445
Branch Office Address:
Telephone:
3621 E. Hamilton Ave
Eau Claire, WI 54701
715-318-4540
Cole@InvestWithBuska.com
www.InvestWithBuska.com
MARCH 19, 2025
This brochure supplement provides information about Cole J. Bruner and supplements the
Buska Wealth Management, LLC’s brochure. You should have received a copy of that
brochure. Please contact Cole J. Bruner if you did not receive the brochure or if you have
any questions about the contents of this supplement.
Additional information about Cole J. Bruner (CRD #6311944) is available on the SEC’s
website at www.adviserinfo.sec.gov.
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Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Principal Executive Officer
Cole J. Bruner
•
Item 2 Business Experience and Educational Background
Year of birth: 1986
Business Experience:
•
•
•
•
•
•
•
Legacy Tax Solutions, LLC; Managing Member; 12/2018 - Present
Buska Wealth Management, LLC; Investment Adviser Representative; 03/2014 -
Present
Buska Retirement Solutions, Inc.; Vice President/Insurance Agent; 12/2007 –
Present
Namaste Traveling, LLC; Owner; 12/2021 - Present
American Neighborhood Mortgage Acceptance Company; Mortgage Loan Officer;
02/2018 – 10/2019
Isagenix; Consultant; 10/2014 – 12/2018
Marketplace Home Mortgage; Mortgage Loan Officer; 12/2015 – 01/2018
Gradient Home Mortgage; Mortgage Loan Originator; 01/2015 – 10/2015
•
•
Educational Background:
Item 3 Disciplinary Information
North Central Technical College; studied business management 09/2006 –
05/2007; no degree obtained
Item 4 Other Business Activities
None to report.
Managing Member Cole J. Bruner has a financial industry affiliated business as a licensed
insurance agent. From time to time, he will offer clients advice or products from those
activities. Approximately 40% of his time is spent in this business. Mr. Bruner receives
commissions from insurance companies on the products he sells.
Mr. Bruner is Managing Member of Legacy Tax Solutions, LLC, an affiliated tax planning and
preparation company. From time to time, he will offer clients advice or services from those
activities. Approximately 10% of his time is spent in this business. Mr. Bruner receives fees
from the services he provides.
Mr. Bruner is also co-owner of Namaste Traveling, LLC. He spends a minimal amount of time
on this activity.
Item 5 Additional Compensation
These practices represent conflicts of interest because it gives an incentive to recommend
products and services based on the commissions or fees received rather than on client’s
needs. This conflict is mitigated by disclosures, procedures, and the firm’s Fiduciary
obligation to place the best interest of the client first and the clients are not required to
purchase any products or services. Clients have the option to purchase these products
through another insurance agent or tax professional of their choosing.
Cole J. Bruner receives additional compensation in his capacity as an independent insurance
agent and consultant, but he does not receive any performance-based fees.
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Item 6 Supervision
Mr. Bruner may receive certain benefits from Gradient Investments, LLC (and/or its
affiliated companies) based on achieving certain production thresholds. These thresholds
are not based on the sale of any specific product or specific product type. These incentives
include marketing assistance, access to technology, office support, and business trainings
and trips. While some of these benefit the client, such as technology and training, some do
not. This creates a conflict of interest because it gives an incentive to the representative to
meet this threshold.
This conflict is mitigated by disclosures, procedures and the firm’s
fiduciary obligation to place the best interest of the Client first. Clients are not required to
use Gradient Investments, LLC or any of its affiliated companies.
Cole J. Bruner is solely responsible for all supervision and formulation and monitoring of
investment advice offered to clients. Mr. Bruner will adhere to the policies and procedures as
described in the firm’s compliance manual.
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