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DBA
Waypoint Wealth Partners, Inc.
1 Belvedere Place, Suite 200
Mill Valley, CA 94941
(877) 768-4802
www.WaypointWP.com
March 19, 2025
This Brochure provides information about the qualifications and business practices of Waypoint Wealth Partners
(“WWP”). If you have any questions about the contents of this Brochure, please contact us at (877) 768-4802. 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.
Waypoint Wealth Partners is a registered investment adviser. Registration of an Investment Adviser does not imply any
level of skill or training. The oral and written communications of an Adviser provide you with information about which
you determine to hire or retain an Adviser.
Additional information about Waypoint Wealth Partners is also available on the SEC’s website at
www.adviserinfo.sec.gov.
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Item 2 – Material Changes
The purpose of this page is to inform you of material changes since the last annual update to
our brochure. If you are receiving this brochure for the first time, this section may not be
relevant to you.
The last annual update of our Firm Brochure occurred on February 27, 2024.
As part of this annual update, this Brochure was revised to reflect the following material
changes:
In August 2024, updated Item 14 to remove language regarding compensation from All
California Mortgage (“All Cal”) to a supervised person no longer with WWP.
If you wish to receive a complete copy of our Form ADV Part 2A brochure, please contact
Michelle McCarthy, Chief Compliance Officer, at (513) 832-5447 or
michelle.mccarthy@dinsmorecomplianceservices.com. WWP’s Brochure is also available on
our web site www.WaypointWP.com, also free of charge.
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Item 3 – Table of Contents
Item 1 – Cover Page .................................................................................................................................................................. i
Item 2 – Material Changes.................................................................................................................................................... ii
Item 3 – Table of Contents .................................................................................................................................................. iii
Item 4 – Advisory Business ................................................................................................................................................. 1
Item 5 – Fees and Compensation ...................................................................................................................................... 3
Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................... 5
Item 7 – Types of Clients ...................................................................................................................................................... 5
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................................ 5
Item 9 – Disciplinary Information .................................................................................................................................... 6
Item 10 – Other Financial Industry Activities and Affiliations ............................................................................. 6
Item 11 – Code of Ethics ....................................................................................................................................................... 6
Item 12 – Brokerage Practices ........................................................................................................................................... 7
Item 13 – Review of Accounts ............................................................................................................................................ 8
Item 14 – Client Referrals and Other Compensation ................................................................................................ 9
Item 15 – Custody .................................................................................................................................................................. 11
Item 16 – Investment Discretion ..................................................................................................................................... 11
Item 17 – Voting Client Securities .................................................................................................................................. 12
Item 18 – Financial Information ...................................................................................................................................... 12
Privacy Policy .......................................................................................................................................................................... 13
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Item 4 – Advisory Business
Waypoint Wealth Partners (“WWP”) has been providing investment advice since 2004 and
became a Registered Investment Adviser with the SEC on June 17, 2008. WWP is a
privately held company owned by the following principals:
Founding Partner
Founding Partner
BOWES, CHARLES, L.
BRINTON, ANNETTE E.
HUTCHINSON, COURTNEY B. Chief Operating Officer
Education and Business Standards
Persons providing advisory services (Investment Adviser Representatives) must be
investment and financial planning professionals. Professional staff members must possess
a BA, BS, or MBA degree and be either credentialed as a Certified Financial Planner,
Certified Public Accountant, Chartered Life Underwriter, or enrolled in a course designed to
achieve such designations or possess the equivalent experience. Other staff members bring
appropriate skills and experiences.
Investment Management Services
WWP offers investment management services on a fee-only basis. WWP offers advice to
clients regarding asset allocation and the selection of investments. WWP’s investment
management services include designing, implementing, and continued monitoring of client
accounts. WWP will invest the account on a fully discretionary basis, limited only by the
client’s individual needs and any restrictions imposed on the account.
WWP may recommend other investment advisers to manage a certain portion of client
assets. WWP will continue to provide advisory services to the client for the ongoing
monitoring and review of the overall account performance. Factors that WWP will
consider in recommending a particular sub-adviser include the sub-adviser’s management
style, performance, reputation, financial strength, reporting, pricing, and research. WWP
will also take the client’s stated investment objectives into account when determining
whether a particular sub-adviser is appropriate. The client will pay the sub-adviser directly
for their advisory services rendered. Fees paid to the sub-adviser are separate from and in
addition to WWP’s management fees.
Wealth Management Services
WWP offers wealth management services as part of their investment management service
offering. WWP’s wealth management offering includes the following:
• Understanding the client’s present circumstances by collecting and carefully
considering relevant personal and financial data.
•
Identifying the client’s goals, vision, values and concerns.
• Providing recommendations for specific issues requested by the client which
may include:
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Investment strategies
Income tax planning
- Preparing for or living in retirement
-
-
- Stock compensation analysis and planning
- Life, disability, long term care insurance
- Family savings and cash flow planning
- Education planning and funding
- Charitable gifting
- Employee benefits
- Other issues as needed
• As the client’s financial plans are developed, WWP may help with implementing
the plan, as requested by the client.
•
WWP also monitors and makes changes in the plan as circumstances change for
the duration of the client’s agreement with WWP. The client is always
responsible for notifying WWP of changes in their personal circumstances on a
timely basis.
The gathering of information, review of options, and plan development are all done
carefully with the client in a series of in person or video meetings, telephone and by using
electronic communication (e-mail) as appropriate. Proper planning is not a one-time
event. Life circumstances change, goals change and available opportunities may change
over time. Any plan will need to be adjusted and updated to reflect these changes or it may
become outdated and irrelevant. The initial planning is only the beginning step in a life-
long process.
WWP may provide more limited wealth management services for courtesy accounts, such
as for the accounts of adult children of clients. WWP’s wealth management services do not
include preparation of income tax, gift or estate tax returns nor preparation of any legal
documents, including wills or trusts. Investment Adviser Representatives at WWP are not
practicing tax professionals or attorneys.
When WWP provides investment advice to you regarding your retirement plan account or
individual retirement account, WWP is a fiduciary 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 WWP makes money creates some
conflicts with your interests, so WWP operates under a special rule that requires WWP to
act in your best interest and not put our interest ahead of yours.
Types of Investments
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WWP primarily utilizes mutual funds, exchange traded funds, and publicly traded REITs in
managing client portfolios, and may additionally utilize individual stocks and bonds in
particular client circumstances. WWP may also offer advice about any type of investment
held in a client’s portfolio at the beginning of the advisory relationship. The majority of
investments recommended by WWP are in the form of no-load mutual funds, index funds,
exchange traded funds or similar investment products. As a result of employee benefit
perquisites from their position as an owner or executive of a company, some clients may
own, be granted or may consider purchasing options in the shares of their company. WWP
offers advice about such investment decisions, as well as about the sale or liquidation of
these companies. The investment selection offered to clients may be limited by the
knowledge and experience of the personnel of WWP and/or the resources available to it as
a result of its relationships with custodians and other providers in the broader financial
industry. In addition, as a result of these resources, certain investments may be available
to clients of WWP that might not be available to members of the public at large. WWP
believes that the choices available under these restrictions are wide enough to effectively
make the full range of investment options available that might be important for all but the
rarest client. Suitable categories of investments are chosen according to the client’s
attitude about risk and need for capital appreciation or income production, with tax
considerations of all transactions given appropriate weight.
WWP manages client accounts based on the investment strategy discussed below under
Item 8. Individual securities are selected within each category when WWP believes their
characteristics are most consistent with the objectives for the category they were chosen
for. Risk factors of the different investments are considered, particularly in light of the
client’s stated risk tolerance. WWP makes investment decisions for clients based on
information the client supplies about their financial situation, goals, and risk tolerance.
WWP’s recommendations/investment selections may not be suitable if the client does not
provide WWP with accurate and complete information. It is the client’s responsibility to
keep WWP informed of any changes to their investment objectives or restrictions.
Clients may also request other restrictions on the account, such as when a client needs to
keep a minimum level of cash in the account or does not want WWP to buy or sell specific
securities or security types in the account. WWP reserves the right to not accept and/or
terminate management of a client’s account if WWP feels that the client-imposed
restrictions would limit or prevent WWP from meeting or maintaining the client’s
investment strategy.
As of 12/31/2024, WWP’s assets under management totaled:
$1,073,263,835
$ 0
$1,073,263,835
Discretionary Assets
Non-Discretionary Assets
Total Assets
Item 5 – Fees and Compensation
WWP offers investment management services on a fee-only basis. Each Investment
Management Agreement entered into with clients will disclose the fee schedule and any
minimum quarterly fee clients that will be charged and may be different from the fee
schedules and minimums clients will see described in this Brochure. Clients should be sure
to review their Investment Management Agreement carefully before signing.
Fees and/or minimums may be negotiated or waived at WWP’s sole discretion and in some
cases, WWP may charge a client a negotiated flat fee rather than the fee range outlined
below. The amount of the asset management fee is based on the total assets under
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management. The fee range and break points start from 1% to 0.25% annually, depending
on the amount of assets to be managed. Accounts may be subject to a minimum quarterly
fee, which has varied based on when the fees were established with the client, and is
disclosed in the client’s Investment Management Agreement. Current quarterly fee
minimum is typically $2,500.
Client fees will be calculated at the beginning of each calendar quarter based on the market
value of the assets in the account on the last business day of the previous quarter. Client
fees will be deducted automatically from their investment account(s) and will appear as a
line item on the monthly or quarterly statement provided directly by their Custodian.
Prices and values for most assets are available from the Custodian through electronic
download on a daily basis. However, daily prices may not be available for certain assets
that are not held at WWP’s recommended custodians. In these cases, the month end,
quarter end, or annual asset values may be used in calculating the balance.
For new accounts, fees will be prorated as of the date that substantially all assets are
received.
There may be an initial one-time professional services fee charged upon the signing of the
Investment Management Agreement. The professional services fee will vary according to
the scope of services to be provided and will be quoted to each client in advance. If a client
requests extraordinary planning services, WWP may charge separately for those services at
an additional agreed upon fee. WWP will contact the client in advance if additional charges
will apply.
WWP’s fees are exclusive of charges imposed by Custodians, broker-dealers and third-
party investments such as brokerage commissions and transaction fees, custodian fees and
fees charged by sub-advisers.
Any charges that may be assessed by the Custodian are paid directly by the client. All fees
paid to WWP for investment advisory services are separate and distinct from the fees and
expenses charged by mutual funds to their shareholders. These fees and expenses are
described in each fund’s prospectus. These fees will generally include a management fee,
other fund expenses, and a possible distribution fee. The client should review both the fees
charged by the funds, the Custodian and the fees charged by WWP to fully understand the
total amount of fees the client will be required to pay, to whom, for what service, and to
evaluate the advisory services being provided.
transactions and determining the reasonableness of their
Item 12 further describes the factors that WWP considers in selecting or recommending
broker-dealers for client
compensation (e.g., commissions).
A client may terminate their agreement at any time but will be liable for the advisory fees
earned up to the termination date based on the fee schedule in effect for that client. WWP
will refund any fees that have been paid, but not earned, prorated for the period between
the start of the billing period in question up to and including the date the client provides a
notice of termination. A termination notice must be received in writing by WWP and is
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effective on the agreed upon date. There is never a penalty for terminating the agreement.
Item 6 – Performance-Based Fees and Side-By-Side Management
WWP does not charge any performance-based fees (fees based on a share of capital gains
on or capital appreciation of the assets of a client).
Item 7 – Types of Clients
WWP provides portfolio management services to individuals, high net worth individuals,
charitable institutions, foundations, and endowments.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis and Investment Strategies
WWP works with each client to develop an investment plan and appropriate asset
allocation based on the client’s individual circumstances. Depending on the client’s
financial needs and risk tolerance, client accounts will generally be allocated among equity
and fixed income securities. WWP uses a long-term investment philosophy that seeks to
capture the returns of the global capital markets. Client accounts are globally diversified
across multiple dimensions including market capitalizations, regions, sectors and
industries to reduce risk. WWP primarily uses institutional mutual funds and exchange
traded funds to implement their strategies. WWP may also recommend the use of a sub-
adviser to manage a portion of client assets. In these instances, WWP will provide the
client with the disclosure brochure of the sub-adviser, which includes a description of the
sub-adviser’s investment strategy.
Sources of Information
WWP uses commercially available information and research from multiple investment
companies to develop their strategies and recommendations. Company prepared materials
and research releases prepared by others are also utilized. Such information may be
obtainable in print, on computer media, via the internet or via some other electronic
means. As an investment advisor, WWP also has the opportunity to access information
from a variety of experts, whether through personal visits, telephone calls or at industry
conferences or related meetings. Independent, third party registered investment advisors
may also be employed to provide additional expertise in unique situations.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear.
The prices of securities held in client accounts and the income they generate may decline in
response to certain events taking place around the world. These include events directly
involving the issuers of securities held as underlying assets of mutual funds or exchange
traded funds in a client’s account, conditions affecting the general economy and overall
market changes. Other contributing factors include local, regional or global political, social,
or economic instability and governmental or governmental agency responses to economic
conditions. Finally, currency, interest rate, and commodity price fluctuations may also
affect security prices and income.
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Other Business Risks
Cybersecurity Risk
Investment advisers and their service providers may be prone to operational and
information security risks resulting from cyber-attacks. Cyber-attacks include, among other
behaviors, stealing or corrupting data maintained online or digitally (including, for
example, through cyber- attacks known as “phishing” and “spear-phishing”), denial-of-
service attacks on websites, the unauthorized release of confidential information and
causing operational disruption. Cyber- attacks may interfere with the processing of
transactions, cause the release of private information or confidential information of the
firm, cause reputational damage, and subject the firm to regulatory fines, penalties or
financial losses, reimbursement or other compensation costs, and/or additional
compliance costs. While the firm has established business continuity plans and systems
designed to prevent such cyber-attacks, there are limitations in such plans including the
possibility that certain risks have not been identified.
Coronavirus or Pandemic Risk
The global outbreak of the 2019 novel coronavirus (“COVID-19”), together with resulting
voluntary and U.S. federal and state and non-U.S. governmental actions, including, without
limitation, mandatory business closures, public gathering limitations, restrictions on travel
and quarantines, has meaningfully disrupted the global economy and markets. Although
the long-term economic fallout of COVID-19 is difficult to predict, it has and is expected to
continue to have ongoing material adverse effects across many, if not all, aspects of the
regional, national and global economy. A pandemic such as COVID-19 may impact the
ability of the firm to operate effectively, including the ability of its personnel or its service
providers and other contractors to function, communicate and travel to the extent
necessary. The spread of COVID-19 among the firm’s personnel and its service providers
Item 9 – Disciplinary Information
may also affect the firm’s ability to properly perform our duties.
Registered investment advisers are required to disclose all material facts regarding any
legal or disciplinary events that would be material to a client’s evaluation of WWP or the
integrity of WWP’s management. WWP has no history of legal or disciplinary events
applicable to this Item.
Item 10 – Other Financial Industry Activities and Affiliations
WWP is required to disclose all industry affiliations and other industry-related activities.
WWP has no affiliates and is not engaged in other financial industry activities.
Item 11 – Code of Ethics
WWP has adopted a Code of Ethics for all supervised persons of the firm describing its high
standard of business conduct and fiduciary duty to its clients. The Code of Ethics includes
provisions relating to the confidentiality of client information, a prohibition on insider
trading, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts
and the reporting of certain gifts and business entertainment items and personal securities
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trading procedures, among other things. All supervised persons at WWP must
acknowledge the terms of the Code of Ethics.
WWP’s employees and persons associated with WWP are required to follow WWP’s Code
of Ethics. Subject to satisfying this policy and applicable laws, officers, directors and
employees of WWP may trade for their own discretionary self-managed personal securities
accounts (e.g. not managed by WWP) in securities which are recommended to and/or
purchased for WWP’s clients, so long as any Access Persons obtain written pre-approval
before trading in any Reportable Securities, including initial public offerings, limited
offerings, and certain personal investments in accordance with the firm’s pre-clearance
policies. Under the Code of Ethics, certain classes of securities have been designated as
exempt transactions, based on a determination that these would not materially interfere
with the best interest of WWP’s clients. Many securities transactions on behalf of clients
consist of mutual funds, which do not trade but are issued and redeemed once daily at the
fund’s net asset value (“NAV”). Therefore, WWP believes that personal transactions in
mutual funds do not present a conflict of interest to its clients. The Code of Ethics includes
additional restrictions for WWP personnel in the event that non-mutual fund purchases or
sales are made in their personal accounts. It is designed to assure clients that the personal
securities transactions, activities and interests of the employees of WWP will not interfere
with (i) making decisions in the best interest of advisory clients and (ii) implementing such
decisions while, at the same time, allowing employees to invest for their own accounts. All
employee trading is monitored under the WWP Code of Ethics to reasonably prevent
conflicts of interest between WWP and its clients.
WWP’s clients or prospective clients may request a copy of WWP's Code of Ethics by
contacting the Chief Compliance Officer.
Item 12 – Brokerage Practices
As discussed in Item 8, WWP uses commercially available services, specifically financial
publications and information services dealing with investment research and taxation to
help develop its strategies and recommendations. WWP is required to disclose all
relationships with investment research production companies that could result in
compensation or benefits paid for by client commissions (called “soft dollars”) to WWP that
could present a conflict of interest. WWP does not receive compensation in the form of
research or any other soft dollar benefits.
Broker Recommendation
WWP requires each client to open one or more brokerage accounts with a specified
independent company that provides account custody and brokerage services, commonly
referred to as a “Custodian”. To perform appropriate transactions necessary to provide
investment management services, WWP may from time to time establish non-binding
relationships with one or more Custodians. WWP typically requires clients to maintain
their assets with and place transactions through Fidelity Brokerage Services, LLC
(“Fidelity”) or Charles Schwab & Co., Inc. (“Schwab”), each a registered broker-dealer,
member of FINRA/SIPC. The client will enter into a separate agreement with the Custodian
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to custody the assets. WWP is independently owned and operated and is not affiliated with
any Custodian. The commission rates charged by Custodians may be higher than those
obtainable from other brokers. While commission rates are an important factor in
custodian/broker selection, WWP may consider a number of factors in addition to
commission rates. These include, for example, reputation, financial strength and stability,
efficiency of execution and error resolution, willingness to execute difficult transactions,
selection of mutual funds offered, online access to computerized data regarding client
accounts, custody, record keeping or other similar services, as well as other matters
involved in the receipt of general brokerage services. The Custodian may provide WWP
with access to their institutional trading and custody services, which are typically not
available to retail investors. The benefits WWP receives under this arrangement are
described in Item 14. All WWP clients with assets held by a Custodian may benefit from
this arrangement. A sub-adviser may direct transactions through a broker other than the
Custodian where client assets are held. In these instances, the client will be charged a
trade-away fee. The sub-adviser takes this fee into consideration when directing
transactions. For more information, clients should review the Form ADV Part 2A of the
sub-adviser.
Cross Transactions
It is WWP’s policy that we will not affect any principal or agency cross securities
transactions for client accounts. WWP will also not cross trades between client accounts.
Sub-advisers utilized for some client accounts may conduct cross trades. For more
information regarding the sub-adviser’s policies, clients should contact WWP and review
the Form ADV Part 2A of the sub-adviser.
Trade Aggregation
In managing client accounts, which also includes any employee personal securities
accounts managed by WWP, WWP may recommend a trade across all or many client
accounts. Instead of placing trades individually, WWP may aggregate (combine) orders for
multiple accounts in an effort to seek best execution, negotiate more favorable commission
rates, and/or allocate differences in prices, commissions, and other transaction costs
equitably among clients. To ensure that client accounts are treated fairly, when a trade is
recommended across all or most accounts, WWP will utilize a rotating trade order (Trade
Rotation) when placing trades at each custodian for aggregated/block trades. When
aggregating orders, each participating client in the block must participate at the average
share price (per custodian) for all transactions by the block in that security, with the
number of securities and transaction costs shared pro rata based on each client’s
participation in the transaction by the block, unless changes in allocation are required by
special circumstances such as odd-lot considerations and small numbers of securities. Sub-
advisers utilized for some client accounts may also conduct trade aggregation. For more
information regarding the sub-adviser’s policies, clients should review the Form ADV Part
2A of the sub-adviser.
Item 13 – Review of Accounts
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Client accounts are carefully monitored and reviewed by the Investment Advisor
Representative responsible for the account for alignment with the target asset allocation
and the client’s stated circumstances on an ongoing basis, at least quarterly, and more
frequently in times of unstable markets or changing economic conditions.
Client Communication
Client communications occur at several levels:
•
•
•
•
•
Trade confirmations and account statements document all investment
transactions and are provided directly to the client by the broker-dealer
and/or Custodian.
Monthly statements are prepared and distributed by the Custodian holding
the assets.
Quarterly performance reports are provided to all clients via a personalized,
secure on-line portal.
Client meetings are generally held at least annually to review the client’s
account and determine if there have been any material changes in the client’s
financial goals.
Meetings, telephone calls, and emails typically occur throughout the year as
circumstances warrant.
Courtesy accounts do not receive reports and meetings from WWP separate from the
reports and meetings provided to the client.
Item 14 – Client Referrals and Other Compensation
Client Referrals
WWP does not accept referral fees.
WWP may, from time to time, compensate either directly or indirectly, any person (defined
as a natural person or a company) for client referrals.
If a client is introduced to WWP by an unaffiliated promoter:
•
may provide cash and/or non-cash compensation to the promoter in
WWP
accordance with the requirements of Rule 206(4)-1 of the Investment Advisers Act
of 1940. When such cash or non-cash compensation exceeds the de minimis value,
WWP will enter into a formal written agreement with the promoter.
•
The client will receive disclosure regarding whether the promoter is a client of
WWP, whether cash and/or non-cash compensation was paid to the promoter by
WWP, the material terms of the compensation arrangement if applicable, and any
material conflicts of interest on the part of the promoter resulting from WWP’s
relationship with the promoter and/or compensation arrangement.
If an unaffiliated promoter receives any cash or non-cash compensation from WWP, they
have an incentive to recommend WWP, resulting in a conflict of interest:
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•
Non-cash compensation is of a de minimis value and WWP does not anticipate any
material conflicts of interest due to the non-cash compensation paid to unaffiliated
promoters. Conflicts of interest due to cash compensation paid to unaffiliated
promoters are further described in the disclosure documents provided to the client.
•
Cash or non-cash compensation paid by WWP to promoters for a client referral does
not result in any additional fees being charged to the client.
WWP offers a Business Development Incentive Plan to its employees whereby the
employee receives compensation for referring new clients to WWP:
•
Compensation is based on the employee’s role in serving the client. WWP
compensates lead advisors as a percentage of revenue earned from managing the
new client’s assets for the first year. WWP compensates all other employees at a
one-time flat rate, provided that first year revenue exceeds a minimum threshold.
•
Compensation paid by WWP through the referral program does not result in any
additional fees being charged to the client.
Additional Compensation
Custodian services are generally available to independent investment advisors on an
unsolicited basis, at no charge to them so long as WWP maintains a minimum amount of its
clients’ assets in accounts with the Custodian. Some of the services provided by Custodians
include brokerage, custody, research and access to certain mutual funds and other
investments that may not otherwise be available to non-institutional or retail investors or
would require a significantly higher minimum initial investment. In some cases, the
Custodian does not charge separately for custody but is compensated by account holders
through commissions or other transaction-related fees for security trades that are executed
through the Custodian. The Custodian may also make other products and services
available to WWP that benefit WWP but may not benefit its clients’ accounts. Some of these
other products and services may assist WWP in managing and administering clients’
accounts. These may include software and other technology that provide access to client
account data (such as trade confirmations and account statements), facilitation of trade
execution, providing research pricing information and other market data, assisting with
back-office functions, recordkeeping and client reporting. Many of these services may be
used to service all or a substantial number of WWP’s accounts, including accounts not
maintained at the Custodian providing the services. The Custodian may also make
available to WWP other services intended to help WWP manage and further develop its
business enterprise. These services may include consulting, publications and conferences
on practice management, information technology, business succession, regulatory
compliance and marketing. In addition, the Custodian may make available, arrange and/or
pay for these types of services rendered to WWP by other independent third parties. While
as a fiduciary, WWP endeavors to act in its clients’ best interests, WWP’s recommendation
that its clients maintain their assets in accounts at a certain Custodian may be based in part
on the benefit to WWP of the availability of some of the products and services discussed in
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this Brochure.
In addition, due to the fact that WWP does not directly pay for these services, including any
research received, it may be construed as receipt of an economic benefit by WWP and
therefore, a conflict of interest between WWP and the client.
Item 15 – Custody
WWP does not maintain physical custody of customer funds or securities.
WWP is deemed to have limited custody of some of its clients’ funds or securities when the
clients authorize WWP to deduct its management fees directly from the client’s account. A
qualified Custodian (generally a broker-dealer, bank, trust company, or other financial
institution) holds clients’ funds and securities. WWP is also deemed to have custody of
clients’ funds or securities when clients have standing authorizations with their custodian
to move money from a client’s account to a third-party (“SLOA”) and under that SLOA
authorizes WWP to designate the amount or timing of transfers with the custodian. The
SEC has set forth a set of standards intended to protect client assets in such situations,
which WWP follows.
Clients should receive at least quarterly statements from the broker-dealer, bank or other
qualified Custodian that holds and maintains a client’s investment assets. The statements
will reflect the client’s funds and securities held with the qualified Custodian as well as any
transactions that occurred in the account, including the deduction of WWP’s fee. WWP
urges clients to carefully review such statements and compare such official Custodian
records to the account statements that WWP may provide to clients. WWP statements may
vary from Custodian statements based on accounting procedures, reporting dates or
valuation methodologies of certain securities. Clients with any questions about their
statements should contact WWP at the address or phone number on the cover of this
brochure. Clients who do not receive their statement from their qualified Custodian at
least quarterly should also notify WWP.
Item 16 – Investment Discretion
WWP will typically have full discretion with respect to the selection, amount, purchase and
sale of securities without requesting and receiving specific advance client consent. WWP
will only manage accounts on a non-discretionary basis in rare and unique circumstances
and at the sole discretion of WWP.
WWP usually receives discretionary authority from the client at the beginning of an
advisory relationship to select the identity and amount of securities to be bought or sold.
This authority is granted in the investment management agreement the client signs. In all
cases, however, such discretion is to be exercised in a manner consistent with the stated
investment objectives for the particular client account.
When selecting securities and determining amounts, WWP observes the investment
policies, limitations and restrictions of the clients for which it advises.
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Item 17 – Voting Client Securities
Proxy Voting
WWP’s policy is to not vote proxies on behalf of its clients. Clients retain the right and
authority to vote securities for their accounts and therefore, WWP shall have no obligation
or authority to take any action or render any advice with respect to the voting of proxies
solicited by or with respect to issuers of securities presently or formerly held in a client’s
account. If the account is an ERISA account (pension, retirement or employee benefit
account), the plan delegates such authority to another named fiduciary. If the account is
managed by a sub-adviser, proxies for those securities will be voted by the client or by the
sub-adviser. Otherwise, the obligation to vote client proxies shall, at all times, rests with
the client. Clients will receive their proxies or other solicitations directly from their
custodian or a transfer agent. Clients may call WWP if they have questions about a
particular solicitation, but WWP shall not be deemed to have proxy voting authority solely
as a result of providing advice or information about a particular proxy vote to a client.
Proxies issued on securities held by a registered investment company (i.e. mutual fund) are
generally voted by the investment adviser advisor that manages the assets of the mutual
fund.
Class Actions
WWP does not instruct or give advice to clients on whether or not to participate as a
member of class action lawsuits and will not automatically file claims on the client’s behalf.
However, if a client notifies WWP that they wish to participate in a class action, WWP will
provide the client with any transaction information pertaining to the client’s account
needed for the client to file a proof of claim in a class action.
Item 18 – Financial Information
Registered investment advisers are required in this Item to provide clients with certain
financial information or disclosures about WWP’s financial condition. WWP has no
financial commitment that impairs its ability to meet contractual and fiduciary
commitments to clients and has not been the subject of a bankruptcy proceeding.
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Privacy Policy
Rev. March, 2019
FACTS
WHAT DOES WAYPOINT WEALTH PARTNERS, INC. (“WWP”)
DO WITH YOUR PERSONAL INFORMATION?
Why?
Financial companies choose how they share your personal information. Federal law
gives consumers the right to limit some but not all sharing. Federal law also requires
us to tell you how we collect, share, and protect your personal information. Please
read this notice carefully to understand what we do.
What?
The types of personal information we collect and share depend on the product or
•
service you have with us. This information can include:
•
•
no longer
Social Security number and income
account balances and transaction history
assets and risk tolerance
our customer, we continue to share your information as
When you are
described in this notice.
How?
Reasons we can share your personal information
All financial companies need to share customers’ personal information to run their
everyday business. In the section below, we list the reasons financial companies can
share their customers’ personal information; the reasons WWP chooses to share; and
whether you can limit this sharing.
Can you limit
this sharing?
Does WWP
share?
For our everyday business purposes -
YES
NO
For our marketing purposes -
as permitted by law
YES
NO
to offer our products and
NO
We Don’t Share
For joint marketing with other financial companies
services to you
For our affiliates’ everyday business purposes -
NO
We Don’t Share
information
For our affiliates’ everyday business purposes -
about your transactions and experiences
NO
We Don’t Share
NO
We Don’t Share
For nonaffiliates to market to you
information about your creditworthiness
Questions?
Call Courtney Hutchinson at 877-768-4802.
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WHO WE ARE
Who is providing this notice?
Waypoint Wealth Partners, Inc. (“WWP”)
WHAT WE DO
How does WWP protect my
personal information?
How does WWP collect my
personal information?
To protect your personal information from unauthorized access and
use, we use security measures that comply with federal law. These
measures include computer safeguards and secured files and
buildings.
•
We collect your personal information, for example, when you
•
•
•
•
seek advice about your investments
enter into an investment advisory contract
tell us about your investment or retirement portfolio
tell us about your investment or retirement earnings
give us your contact information
Why can’t I limit all sharing?
We also collect your personal information from other companies.
•
Federal law gives you the right to limit only:
•
•
sharing for affiliates’ everyday business purposes - information
about your creditworthiness
affiliates from using your information to market to you
sharing for nonaffiliates to market to you
State laws and individual companies may give you additional rights to
limit sharing.
DEFINITIONS
Affiliates
Companies related by common ownership or control. They can be
• WWP has no affiliates
financial and nonfinancial companies.
Nonaffiliates
Companies not related by common ownership or control. They can be
• WWP does not share with nonaffiliates so they can market to you
financial and non-financial companies.
Joint Marketing
A formal agreement between nonaffiliated financial companies that
• WWP doesn’t jointly market
together market financial products or services to you.
OTHER IMPORTANT INFORMATION
Information for California
Customers
In response to a California law, we automatically treat accounts with
California billing addresses as if you do not want to disclose personal
information about you to non-affiliated third parties except as
permitted by the applicable California law. We will also limit the
sharing of personal information about you with our affiliates to
comply with all California privacy laws that apply to us.
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