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FORM ADV PART 2A: FIRM BROCHURE
Godsey & Gibb Wealth Management
6806 Paragon Place, Suite 230
Richmond, VA 23230
(804) 285-7333
www.godseyandgibb.com
REVISED 03/19/2025
This Form ADV Part 2A Firm Brochure (“Brochure”) provides information about the qualifications and business practices
of Godsey & Gibb Wealth Management, also doing business as Planned Ahead by Godsey & Gibb Wealth Management.
If you have any questions about the contents of this brochure, please contact us at (804) 285-7333 or
compliance@godseyandgibb.com. The information in this brochure has not been approved or verified by the United
States Securities and Exchange Commission (SEC) or by any state securities authority. Registration with the SEC or with
any state securities authority does not imply a certain level of skill or training.
Additional information about Godsey & Gibb Wealth Management is also available on the SEC's website at
www.adviserinfo.sec.gov. Godsey & Gibb Wealth Management’s CRD number is 105650.
ITEM 2 – MATERIAL CHANGES
MATERIAL CHANGES
"Material changes" refer to changes of ownership or control; location; disciplinary proceedings; significant changes to
our advisory services or advisory affiliates—any information that is critical to a client's full understanding of who we are,
how to find us, and how we do business.
Material changes in this brochure since the last annual update dated March 22, 2024, are described below:
•
•
•
Item 4 has been amended to disclose that we have added a DBA name Planned Ahead by Godsey & Gibb Wealth
Management to market our financial planning services.
Item 4 has been amended to disclose that our financial planning services are now offered under two models—the
Wealth Preservation & Distribution model intended for individuals who are retired or approaching retirement and
the Wealth Accumulation model intended for individuals navigating the early-to-mid stages of financial growth. The
fee arrangement for each model is disclosed in Item 5.
Item 5 has been amended to disclose the updated fee arrangement for tax preparation services.
NON-MATERIAL CHANGES
From time to time, Godsey & Gibb Wealth Management may amend this brochure to reflect changes in response to
evolving industry and securities regulations or routine annual updates as required by the SEC. Godsey & Gibb Wealth
Management may also make revisions in an effort to clarify the descriptions of our business practices and policies, which
may include minor updates to hyperlinks, contact information and punctuation, as necessary.
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ITEM 3 – TABLE OF CONTENTS
COVER PAGE
MATERIAL CHANGES
TABLE OF CONTENTS
ADVISORY BUSINESS
FEES AND COMPENSATION
PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
TYPES OF CLIENTS
METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
DISCIPLINARY INFORMATION
1
2
3
4
6
7
7
7
9
9
ITEM 1
ITEM 2
ITEM 3
ITEM 4
ITEM 5
ITEM 6
ITEM 7
ITEM 8
ITEM 9
ITEM 10 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND
9
PERSONAL TRADING
INVESTMENT DISCRETION
ITEM 12 BROKERAGE PRACTICES
ITEM 13 REVIEW OF ACCOUNTS
ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION
ITEM 15 CUSTODY
ITEM 16
ITEM 17 VOTING CLIENT SECURITIES
ITEM 18
FINANCIAL INFORMATION
10
11
11
12
13
13
13
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ITEM 4 – ADVISORY BUSINESS
A. FIRM OVERVIEW
Godsey & Gibb Wealth Management (“GGWM,” “Adviser,” or the “Firm”) is registered with the Securities and
Exchange Commission (SEC) as a Registered Investment Adviser with its principal place of business located in
Richmond, Virginia. The firm was formed in February 1985 as a Corporation organized in the State of Virginia. The
principal shareholders controlling 25% or more of the Firm are Michael Reilly Gibb and the Gibb Family Stock Trust.
For purposes of providing financial planning services to certain clients, GGWM is also doing business as Planned
Ahead by Godsey & Gibb Wealth Management (“Planned Ahead”), whose brand name and logo may appear on client
statements and other marketing material. GGWM representatives providing services to clients under this brand
name are employed by and under the supervision of GGWM.
WRITTEN ACKNOWLEDGMENT OF FIDUCIARY STATUS
When we provide investment advice to you regarding your retirement plan account or individual retirement
account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the
Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money
creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best
interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
B. DESCRIPTION OF SERVICES
INDIVIDUAL PORTFOLIO MANAGEMENT
GGWM offers ongoing individual portfolio management based on the individual objectives, time horizons, risk
tolerance, and liquidity needs of each client. GGWM creates an Investment Objective Statement for each client,
which outlines the client’s current financial situation (income, tax levels, risk tolerance, etc.). Individual portfolio
management services include, but are not limited to the following:
Investment strategy
•
• Asset allocation
• Risk tolerance
• Personal investment objective policy
• Asset allocation
• Regular portfolio monitoring
GGWM will request discretionary authority from clients in order to select securities and execute transactions on the
client’s behalf. GGWM generally limits its investment advice to fixed income securities, equities and ETFs. GGWM
may use other securities as well to help diversify a portfolio. GGWM seeks to provide that investment decisions are
made in accordance with the fiduciary duties owed to its accounts and without consideration of GGWM’s economic,
investment or other financial interests. To meet its fiduciary obligations, GGWM attempts to avoid investment or
trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, GGWM’s
policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid
favoring one client over another over time. It is GGWM’s policy to allocate investment opportunities and transactions
it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time.
FINANCIAL PLANNING SERVICES
GGWM provides ongoing as well as project-based financial planning services encompassing all or some of the
financial concerns to the client, including but not limited to budgeting, employee benefits optimization, credit score
analysis, income and cash management, retirement account optimization, debt strategies, real estate property
investing, retirement planning, education planning, savings analysis, risk tolerance, and insurance & estate
planning. Financial planning services are designed to be a collaborative experience tailored to the client’s personal
goals and customized to the complexity of the client’s financial circumstances. Clients purchasing this service
receive a detailed financial plan designed to assist the client in achieving their financial goals and objectives.
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GGWM offers financial planning services under two models—the Wealth Preservation & Distribution model intended
for individuals who are retired or approaching retirement, and the Wealth Accumulation model intended for
individuals navigating the early-to-mid stages of financial growth. This Wealth Accumulation model does not
involve active investment management but instead focuses on the client’s overall financial situation. For marketing
purposes, services performed under the Wealth Accumulation model are provided by Planned Ahead.
Typically, the written financial plan is presented to the client within 180 days of contract signing, provided that all
information needed to prepare the plan has been provided. Implementation of financial plan recommendations is
entirely at the client's discretion. Financial Planning recommendations are not limited to any specific product or
service offered by a broker-dealer or insurance company. GGWM relies on the accuracy and completeness of the
information provided by the client, without independent verification. This service requires clients to sign a separate
engagement letter specifically outlining the scope of services to be provided and estimated fees that will be
incurred.
TAX PREPARATION SERVICES
GGWM provides Tax Planning & Preparation services for clients, including but not limited to preparing and filing
income tax returns, facilitating payment of quarterly estimates, and offering recommendations on ways to
maximize tax savings. GGWM’s in-house team of licensed Certified Public Accountants (CPAs) and other tax
professionals assist clients with their individual tax returns, estate and trust income tax returns, gift tax returns, and
pass-through entity returns for small client-owned businesses. As client financial circumstances shift or tax laws
change, our tax team helps clients maintain a tax-efficient posture within the current statutory environment. GGWM
relies on the accuracy and completeness of the information provided by the client, without independent
verification. This service requires clients to sign a separate engagement letter specifically outlining the scope of tax
services to be provided and the estimated fees that will be incurred.
FINANCIAL EDUCATION SERVICES
GGWM provides general information on various financial topics including, but not limited to, estate and retirement
planning, and market trends via newsletters, webinars, presentations and speaking engagements. These
engagements are educational in nature and no specific investment or tax advice is provided.
C. CLIENT TAILORED SERVICES AND CLIENT IMPOSED RESTRICTIONS
GGWM offers the same suite of services to all of its clients. However, specific client investment strategies and their
implementation are dependent upon the client Investment Objective Statement which outlines each client’s current
situation (income, tax levels, and risk tolerance levels). Clients may impose reasonable restrictions on investing in
certain securities, types of securities, or industry sectors in accordance with their values or beliefs. However, if such
restrictions prevent GGWM from properly servicing the client account, or if the restrictions would require GGWM to
deviate from its standard suite of services, GGWM reserves the right to end the relationship.
D. WRAP FEE PROGRAM
GGWM does not participate in a wrap fee program as a sponsor to a wrap fee program. However, GGWM acts as a
portfolio manager for third-party wrap fee programs and therefore receives a portion of the wrap fee for our services.
As a portfolio manager for third-party wrap fee programs, GGWM’s exclusive responsibility is to manage the account
assets according to the primary adviser’s instructions. At all times, such primary advisers, and not GGWM, will remain
exclusively responsible for initial and ongoing suitability determination for investment strategies and client
communications. Unless GGWM fails to manage the account with our received instructions, GGWM will not have any
responsibility for account losses. A list of each sponsor and corresponding wrap fee program for which GGWM acts as
portfolio manager can be found in GGWM’s Form ADV Part 1, Section 5.I.(2) of Schedule D.
E. ASSETS UNDER MANAGEMENT
GGWM has the following assets under management:
TOTAL
1,396,829,464
DISCRETIONARY
1,382,544,724
NON-DISCRETIONARY
14,284,740
DATE CALCULATED
December 31, 2024
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ITEM 5 – FEES AND COMPENSATION
A. FEE SCHEDULE
INDIVIDUAL PORTFOLIO MANAGEMENT FEES
ASSETS UNDER MANAGEMENT
First $1,000,000
Next $1,000,000
All above $2,000,000
ANNUAL FEE
1.00%
0.75%
0.50%
Annual fees for Individual Portfolio Management services are based upon a percentage of assets under
management. The minimum account size of $500,000, annual fee of $5,000, and fee schedule are negotiable. GGWM
may group certain related client accounts for the purpose of achieving the minimum account size and determining
the annualized fee. Such fees will be outlined in the written client agreement. Clients may terminate the agreement
without penalty within five business days of signing the agreement. Thereafter, clients may terminate the
agreement generally with 30 days' written notice.
FINANCIAL PLANNING FEES
Financial planning fees are based on the complexity of the client’s financial situation and the specific services to be
provided. Under the Wealth Accumulation Model, GGWM charges an ongoing fixed annual fee typically ranging from
$300 to $850 per month ($3,600 to $10,000 annually). Under the Wealth Preservation & Distribution Model, GGWM
charges an ongoing fixed annual fee typically ranging from $375 to $1,500 per quarter ($1,500 to $6,000 annually).
On a limited basis, project-based financial planning engagements may be offered for a fixed fee typically ranging
from $3,600 to $10,000 per engagement. Financial planning fees may be reduced or waived for Individual Portfolio
Management clients of GGWM to the extent specifically requested by such client. All fees are negotiable and agreed
upon prior to entering into a contract with any client. Clients may terminate the agreement without penalty within
five business days of signing the agreement. Clients may terminate the engagement generally upon written notice.
TAX PREPARATION FEES
Tax preparation fees are based on a rate of $200 per hour, subject to an $800 minimum per tax return. On a limited
basis, project-based tax planning engagements may be offered at a rate of $200 per hour. Certain complex
engagements may be offered at a higher fee. All fees are negotiable and agreed upon prior to entering the
engagement with the client. Tax preparation fees are due upon completion of the engagement. Clients may
terminate the engagement without penalty within five business days of execution of the engagement letter. Clients
may terminate the engagement generally upon written notice.
FINANCIAL EDUCATION FEES
GGWM does not charge clients for attending any seminars or other speaking engagements hosted by GGWM.
B. PAYMENT OF FEES
PAYMENT OF INDIVIDUAL PORTFOLIO MANAGEMENT FEES
Asset-based fees for Individual Portfolio Management services are billed at the end of each quarter in which services
are rendered based on the last day of the prior quarter and paid in arrears. Clients may elect to have fees withdrawn
directly from the client’s accounts or be invoiced and billed directly for fees incurred.
PAYMENT OF FINANCIAL PLANNING FEES
Financial planning fees may be paid monthly or quarterly, partially in advance, or paid in arrears upon completion,
as outlined in the agreement. Clients may elect to pay by check or electronic funds transfer initiated by the client.
PAYMENT OF TAX PREPARATION FEES
Tax preparation fees are paid in arrears upon completion. Clients may elect to pay such fees by check, credit card,
ACH transfer initiated by the client, or withdrawn directly from client’s account with client’s written authorization.
PAYMENT OF FINANCIAL EDUCATION FEES
GGWM does not charge a fee for attending any seminars or other speaking engagements.
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C. CLIENT RESPONSIBILITY FOR THIRD PARTY FEES
Clients are responsible for the payment of all third-party fees (i.e. custodian fees, brokerage fees, transaction fees,
etc.). Such fees are separate and distinct from the fees and expenses charged by GGWM. Clients should note that
similar advisory services may or may not be available from other registered or unregistered investment advisers for
similar or lower fees. Please refer to Item 12 of this brochure for additional information.
D. PREPAYMENT OF FEES
GGWM does not require or solicit payment of fees in excess of $1,200 more than three months in advance of services
rendered. A client agreement may be canceled at any time, by either party, for any reason upon receipt of 30 days
written notice. Upon termination of a written client agreement, any prepaid, unearned fees will be refunded.
E. OUTSIDE COMPENSATION FOR THE SALE OF SECURITIES TO CLIENTS
GGWM and its supervised persons do not accept compensation for the sale of investment products, including asset-
based sales charges or service fees from the sale of mutual funds to GGWM clients.
ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
GGWM does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation
of the assets of a client.
ITEM 7 – TYPES OF CLIENTS
GGWM generally provides advisory services to the following types of clients:
Individuals (other than high net worth individuals)
•
• High-net-worth individuals
• Banking or thrift institutions
• Pension, and profit-sharing plans (other than plan participants)
• Charitable organizations
• Corporations or other business entities not listed above
To open an account, GGWM requires a minimum account of $500,000, which may be negotiated or waived by GGWM in
its sole discretion. For more details, please review the disclosures provided in Item 5.
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
A. METHODS OF ANALYSIS AND INVESTMENT STRATEGIES
METHODS OF ANALYSIS
GGWM’s methods of analysis include fundamental and technical analysis. Fundamental analysis involves the
analysis of financial statements, the general financial health of companies, and/or the analysis of management or
competitive advantages. Technical analysis involves the analysis of past market data; primarily price and volume.
INVESTMENT STRATEGIES
GGWM uses long-term trading, short-term trading, and options trading (including covered and uncovered options,
or spreading strategies). Investing in securities involves risk of loss that you, as a client, should be prepared to bear.
B. MATERIAL RISKS INVOLVED
METHODS OF ANALYSIS
Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings.
This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their
perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Technical
analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the
market follows discernible patterns and if patterns can be identified, a prediction can be made. The risk is that
markets do not always follow patterns and relying solely on this method may not consider new patterns that emerge
over time.
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INVESTMENT STRATEGIES
GGWM's use of options trading generally holds greater risk, and clients should be aware that there is a material risk
of loss using any of those strategies.
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.
Options transactions involve a contract to purchase a security at a given price, not necessarily at market value,
depending on the market. There is a risk that an option may expire out of the money resulting in minimal or no
value, as well as possible leveraged loss of trading capital due to the leveraged nature of stock options.
Short-term trading risks include liquidity, economic stability, and inflation, in addition to the long-term trading
risks listed above. Frequent trading can affect investment performance, particularly through increased brokerage
and other transaction costs and taxes.
Investing in securities involves a risk of loss that you, as a client, should be prepared to bear.
C. RISKS OF SPECIFIC SECURITIES UTILIZED
GGWM's use of options trading generally holds greater risk of capital loss. Clients should be aware that there is a
material risk of loss using any investment strategy. The investment types listed below are not guaranteed or insured
by the FDIC or any other government agency.
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.
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 carry inflation risk,
liquidity risk, call 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 (extremely unlikely);
however, they carry a potential risk of losing share price value, albeit rather minimal.
Exchange Traded Funds (ETFs) are investment funds traded on stock exchanges, similar to stocks. Investing in ETFs
carries the risk of capital loss. Areas of concern include the lack of transparency in products and increasing
complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Investing in ETFs include
trading risks, liquidity and shutdown risks, risks associated with a change in authorized participants and non-
participation of authorized participants, risks that trading price differs from indicative net asset value (iNAV), or
price fluctuation and disassociation from the index being tracked. With regard to trading risks, regular trading adds
cost to your portfolio thus counteracting the low fees that one of the typical benefits of ETFs. Regular trading to
beneficially “time the market” is difficult to achieve. With regard to liquidity and shutdown risks, not all ETFs have
the same level of liquidity. Since ETFs are at least as liquid as their underlying assets, trading conditions are more
accurately reflected in implied liquidity rather than the average daily volume of the ETF itself. Implied liquidity is a
measure of what can potentially be traded in ETFs based on its underlying assets. ETFs are subject to market
volatility and the risks of their underlying securities, which may include the risks associated with investing in smaller
companies, foreign securities, commodities, and fixed income investments. Foreign securities are subject to interest
rates, currency exchange rates, economic, and political risks, all of which are magnified in emerging markets. ETFs
targeting a small universe of securities, such as a specific region or market sector, are generally subject to greater
market volatility, as well as to the specific risks associated with that sector, region, or other focus. ETFs that use
derivatives, leverage, or complex investment strategies are subject to additional risks. The return of an index ETF is
usually different from that of the index it tracks because of fees, expenses, and tracking error. ETFs may trade at a
premium or discount to its net asset value (NAV) (or indicative value in cases of exchange-traded notes). The degree
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of liquidity varies from one ETF to another, and losses may be magnified if no liquid market exists for ETF shares
when attempting to sell them. Each ETF has a unique risk profile, detailed in its prospectus, offering circular or
similar material, which should be considered carefully when making investment decisions.
Options are contracts to purchase a security at a given price, risking that an option may expire out of money
resulting in minimal or no value. Uncovered options are a type of options contract that is not backed by an offsetting
position that help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss
for an uncovered call option is limitless. Spread option positions entail buying and selling multiple options on the
same underlying security, but with different strike prices or expiration dates, which help limit risks of other option
trading strategies. Option transactions involve risks including but not limited to economic risk, market risk, sector
risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk.
Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a
client, should be prepared to bear.
ITEM 9 – DISCIPLINARY INFORMATION
A. CRIMINAL OR CIVIL ACTIONS
There are no criminal or civil actions to report.
B. ADMINISTRATIVE PROCEEDINGS
There are no administrative proceedings to report.
C. SELF-REGULATORY ORGANIZATION (SRO) PROCEEDINGS
There are no self-regulatory organization proceedings to report.
ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
A. REGISTRATION AS A BROKER/DEALER OR BROKER/DEALER REPRESENTATIVE
Neither GGWM nor its representatives are registered as, or have pending applications, to become a broker/dealer or
a representative of a broker/dealer.
B. REGISTRATION AS A FUTURES COMMISSIONS MERCHANT, COMMODITY POOL OPERATOR, OR COMMODITY
TRADING ADVISOR
Neither GGWM nor its representatives are registered as, or have pending applications, to become a futures
commission merchant, commodity pool operator, commodity trading advisor, or an associated person of the
foregoing entities.
C. REGISTRATION RELATIONSHIPS MATERIAL TO ADVISORY BUSINESS
Neither GGWM nor its representatives have any material relationships to this advisory business that would present
a possible conflict of interest.
D. SELECTION OF OTHER ADVISERS OR MANAGERS
GGWM does not utilize nor select third-party investment advisers.
ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND
PERSONAL TRADING
A. CODE OF ETHICS SUMMARY
GGWM has established a written Code of Ethics that sets forth high ethical standards of business conduct that GGWM
requires of its employees, which is available upon request. GGWM’s Code of Ethics covers policies related to
Personal Securities Transactions, Prohibited Activities, Conflicts of Interest, Confidentiality, Compliance with Laws
and Regulations, and Recordkeeping provisions.
B. RECOMMENDATIONS INVOLVING MATERIAL FINANCIAL INTERESTS
GGWM does not recommend that clients buy or sell any security in which a related person to GGWM or GGWM has a
material financial interest.
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C. INVESTING PERSONAL MONEY IN THE SAME SECURITIES AS CLIENTS
From time to time, representatives of GGWM may buy or sell securities for themselves that they also recommend to
clients. This may provide an opportunity for representatives of GGWM to buy or sell the same securities before or
after recommending the same securities to clients, resulting in representatives profiting from the recommendations
they provide to clients. Such transactions may create a conflict of interest. GGWM will always document any
transactions that could be construed as conflicts of interest and will never engage in trading that operates to the
client’s disadvantage when similar securities are being bought or sold.
D. TRADING SECURITIES AT/AROUND THE SAME TIME AS CLIENTS’ SECURITIES
From time to time, GGWM representatives may buy or sell securities for themselves at or around the same time as
clients. This may provide an opportunity for GGWM representatives to buy or sell securities before or after
recommending securities to clients, resulting in representatives profiting from recommendations provided to
clients. Such transactions may create a conflict of interest. GGWM will never engage in trading that operates to the
client’s disadvantage if GGWM representatives buy or sell securities at or around the same time as clients.
ITEM 12 – BROKERAGE PRACTICES
A. FACTORS USED TO SELECT CUSTODIANS
Custodians/broker-dealers will be recommended based on GGWM’s duty to seek “best execution,” which is the
obligation to seek execution of securities transactions for a client on the most favorable terms for the client under
the circumstances. Clients will not necessarily pay the lowest commission or its equivalent, and GGWM may also
consider the market expertise and research access provided by the broker-dealer/custodian, including but not
limited to access to written research, oral communication with analysts, admittance to research conferences and
other resources provided by the brokers that may aid in GGWM's research efforts. GGWM will never charge a
premium or commission on transactions, beyond the actual cost imposed by the broker-dealer/custodian.
RESEARCH AND OTHER SOFT-DOLLAR BENEFITS
GGWM receives no research, product, or services other than execution from broker-dealers or custodians in
connection with client securities transactions (“soft dollar benefits”).
BROKERAGE FOR CLIENT REFERRALS
GGWM recommends clients establish brokerage accounts with Schwab Institutional, a division of Charles Schwab &
Co., Inc., a FINRA registered broker-dealer, to maintain custody of clients' assets and to effect trades for their
accounts. However, it is the client's decision to custody assets with Schwab. Refer to Item 14 for more information.
DIRECTED BROKERAGE
Clients may direct brokerage transactions through a specified broker-dealer or custodian only if client
acknowledges in writing that the client’s brokerage direction supersedes any authority granted to GGWM to select
brokers; this direction may result in higher commissions, which may result in a disparity between free and directed
accounts; the client may be unable to participate in block trades and trades for the client and other directed
accounts may be executed after trades for free accounts, which may result in less favorable prices, particularly for
illiquid securities or during volatile market conditions. Not all advisers allow clients to direct brokerage.
B. AGGREGATE (BLOCK) TRADING
If GGWM buys or sells the same securities on behalf of more than one client, then it may (but would be under no
obligation to) aggregate or bunch such securities in a single transaction for multiple clients in order to seek more
favorable prices, lower brokerage commissions, or more efficient execution. In such cases, GGWM would place an
aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided,
however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged
by this policy. GGWM would determine the appropriate number of shares and select the appropriate brokers
consistent with its duty to seek best execution, except for those accounts with specific brokerage direction (if
applicable).
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ITEM 13 – REVIEW OF ACCOUNTS
A. PERIODIC REVIEWS
INDIVIDUAL PORTFOLIO MANAGEMENT
Client accounts for GGWM's Individual Portfolio Management services are reviewed at least quarterly by the Director
of Portfolio Management, according to the clients’ stated investment objective policies and risk tolerance levels.
FINANCIAL PLANNING
Financial plans are reviewed upon plan creation and plan delivery by the Financial Planning Advisor. While reviews
may occur at different stages depending on the nature and terms of the specific engagement, typically no formal
reviews will be conducted for financial planning clients unless otherwise contracted.
B. NON-PERIODIC REVIEWS
INDIVIDUAL PORTFOLIO MANAGEMENT
Individual Portfolio Management reviews may be triggered by material market, economic or political events, or by
changes in client's financial situations (such as retirement, termination of employment, or inheritance).
FINANCIAL PLANNING
Financial planning reviews may be triggered by changes in the client’s financial circumstances (such as marital
status, employment status, inheritance).
C. REGULAR REPORTS
INDIVIDUAL PORTFOLIO MANAGEMENT
Each Individual Portfolio Management client will receive a written report from GGWM at least quarterly summarizing
the client’s account performance, balances, and holdings. Clients will also receive a written report directly from the
client’s respective custodian at least monthly.
FINANCIAL PLANNING
Each financial planning client will receive their written financial plan upon completion. Additional reports are not
typically provided to clients unless otherwise contracted.
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION
A. ECONOMIC BENEFITS PROVIDED BY THIRD PARTIES
GGWM does not receive any economic benefit including cash, sales awards or other prizes, directly or indirectly,
from any third-party for advice rendered to GGWM’s clients.
With respect to Schwab, GGWM receives access to Schwab’s institutional trading and custody services, which are
typically not available to Schwab retail investors. These services generally are available to independent investment
advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’
assets are maintained in accounts at Schwab Advisor Services. Schwab’s services include brokerage services that
are related to the execution of securities transactions, custody, research, including that in the form of advice,
analyses and reports, and access to mutual funds and other investments that are otherwise generally available only
to institutional investors or would require a significantly higher minimum initial investment. For GGWM client
accounts maintained in its custody, Schwab generally does not charge separately for custody services but is
compensated by account holders through commissions or other transaction-related or asset-based fees for
securities trades that are executed through Schwab or that settle into Schwab accounts.
Schwab Institutional also makes available to GGWM other products and services that benefit GGWM but may not
directly benefit its clients' accounts. Many of these products and services may be used to service all or some
substantial number of GGWM’s client accounts, including accounts not maintained at Schwab. Schwab's products
and services that assist us in managing and administering our clients' accounts include software and other
technology that (i) provide access to client account data (such as trade confirmations and account statements); (ii)
facilitate trade execution and allocate aggregated trade orders for multiple client accounts; (iii) provide research,
pricing and other market data; (iv) facilitate payment of our fees from clients' accounts; and (v) assist with back-
office functions, recordkeeping and client reporting.
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Schwab Institutional also offers other services intended to help us manage and further develop our business
enterprise. These services may include (i) compliance, legal and business consulting; (ii) publications and
conferences on practice management and business succession; and (iii) access to employee benefits providers,
human capital consultants and insurance providers. Schwab may make available, arrange and/or pay third-party
vendors for the types of services rendered to GGWM. Schwab Institutional may discount or waive fees it would
otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services
to our firm. Schwab Institutional may also provide other benefits such as educational events or occasional business
entertainment of our personnel. In evaluating whether to recommend that clients custody their assets at Schwab,
we may take into account the availability of some of the foregoing products and services and other arrangements
as part of the total mix of factors we consider and not solely on the nature, cost or quality of custody and brokerage
services provided by Schwab, which may create a potential conflict of interest.
B. CLIENT REFERRAL FEES
Our firm may pay referral fees to independent persons or firms ("Solicitors") for introducing clients to us. Whenever
we pay a referral fee, we require the Solicitor to provide the prospective client with a copy of this document (our
Firm Brochure) and a separate disclosure statement that includes (i) the Solicitor's name and relationship with our
firm; (ii) the fact that the Solicitor is being paid a referral fee; (iii) the amount of the fee; and (iv) whether the fee paid
to us by the client will be increased above our normal fees in order to compensate the Solicitor. All such referral
activities will be conducted in accordance with Rule 206(4)-1 under the Advisers Act, where applicable.
SCHWAB ADVISOR NETWORK®
GGWM receives client referrals from Schwab through GGWM’s participation in Schwab Advisor Network® (“the
Service”). The Service is designed to help investors find an independent investment advisor. Schwab is a broker-
dealer independent of and unaffiliated with GGWM. Schwab does not supervise GGWM and has no responsibility for
GGWM’s management of clients’ portfolios or GGWM’s other advice or services.
GGWM pays Schwab fees to receive client referrals through the Service. GGWM’s participation in the Service raises
potential conflicts of interest described below. GGWM pays Schwab a Participation Fee on all referred clients’
accounts that are maintained in custody at Schwab and a separate one-time Transfer Fee on all accounts that are
transferred to another custodian.
The Transfer Fee creates a conflict of interest that encourages GGWM to recommend client accounts be held in
custody at Schwab. The Participation Fee paid by GGWM is a percentage of the value of the assets in the client’s
account. GGWM pays Schwab the Participation Fee for so long as the referred client’s account remains in custody at
Schwab. The Participation Fee is paid by GGWM and not by the client. GGWM has agreed not to charge clients
referred through the Service fees or costs greater than the fees or costs GGWM charges clients with similar portfolios
who were not referred through the Service.
The Participation and Transfer Fees are based on assets in accounts of GGWM’s clients who were referred by Schwab
and those referred clients’ family members living in the same household. Thus, GGWM has incentives to recommend
client accounts and household members of clients referred through the Service maintain custody of their accounts
at Schwab.
ITEM 15 – CUSTODY
When advisory fees are deducted directly from client accounts at client's custodian, GGWM will be deemed to have
limited custody of client's assets and must have written authorization from the client to do so. On at least a quarterly
basis, the client’s custodian is required to send to the client a statement showing all transactions within the account
during the reporting period. Clients will receive all account statements and billing invoices that are required in each
jurisdiction, and clients should carefully review those statements for accuracy. Clients should contact us directly if they
believe that there may be an error in their statement. In addition to the periodic statements that clients receive directly
from their custodians, GGWM also sends account statements directly to our clients on a quarterly basis. We urge our
clients to carefully compare the information provided on these statements to ensure that all account transactions,
holdings and values are accurate and current.
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ITEM 16 – INVESTMENT DISCRETION
GGWM provides discretionary and non-discretionary investment advisory services to clients. The advisory contract
established with each client sets forth the discretionary authority for trading. Where investment discretion has been
granted, GGWM generally manages 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
GGWM will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer
of the security or the custodian. Clients should direct all proxy questions to the issuer of the security.
ITEM 18 – FINANCIAL INFORMATION
A. BALANCE SHEET
GGWM neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in
advance, and therefore is not required to include a balance sheet with this brochure.
B. FINANCIAL CONDITIONS REASONABLY LIKELY TO IMPAIR ABILITY TO MEET CONTRACTUAL COMMITMENTS
Neither GGWM nor its management has any financial conditions that is likely to reasonably impair GGWM’s ability
to meet contractual commitments to clients.
C. BANKRUPTCY PETITIONS IN PREVIOUS TEN YEARS
GGWM has not been subject of a bankruptcy petition at any time.
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