View Document Text
Brochure
Form ADV Part 2A
Item 1 - Cover Page
Wealth Dimensions Group, Ltd.
CRD# 107618
7870 E Kemper Road
Suite 210
Cincinnati, Ohio 45249
(513) 554-6000
www.WealthDimensions.com
March 31, 2025
This Brochure provides information about the qualifications and business practices of Wealth
Dimensions Group, Ltd. If you have any questions about the contents of this Brochure, please
contact us at (513) 554-6000 or info@WealthDimensions.com. The information in this Brochure
has not been approved or verified by the United States Securities and Exchange Commission or
by any state authority.
Wealth Dimensions Group, Ltd. is an investment advisory firm registered with the appropriate
regulatory authority. Registration does not imply a certain level of skill or training. Additional
information about Wealth Dimensions Group, Ltd. also is available on the SEC’s website at
www.AdviserInfo.sec.gov.
Item 2 - Material Changes
This Brochure, dated March 31, 2025, was prepared in accordance with the SEC requirements, and
contains the following material changes since Wealth Dimensions Group’s previous annual
amendment (filed on March 29, 2024).
• The firm added details under Item 4 – Advisory Business, Item 5 – Fees and
Compensation and Item 10 – Other Financial Activities and Affiliations around estate
planning services.
•
In March 2025, Ms. Karey Williams assumed the role of Chief Compliance Officer from
Mr. Kenton Pettit (September 2024).
•
In March 2025, Mr. Patrick Hayes assumed the role of Chief Legal Officer. Mr. Hayes
previously served as CCO to Wealth Dimensions through September 2024 and has
continuously served as counsel to Wealth Dimensions during all relevant timeframes
since 2017.
You may obtain a copy of our Brochure by contacting us at 513-554-6000 or by email at
info@WealthDimensions.com.
Additional information about Wealth Dimensions Group is also available via the SEC’s web site
www.adviserinfo.sec.gov.
Page 2
Item 3 - Table of Contents
Item 1 - Cover Page ............................................................................................................................................................... 1
Item 2 - Material Changes................................................................................................................................................... 2
Item 3 - Table of Contents .................................................................................................................................................. 3
Item 4 - Advisory Business ................................................................................................................................................ 4
Item 5 - Fees and Compensation ..................................................................................................................................... 9
Item 6 - Performance-Based Fees and Side-By-Side Management ................................................................. 10
Item 7 - Types of Clients .................................................................................................................................................. 10
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ........................................................ 11
Item 9 - Disciplinary Information ................................................................................................................................ 13
Item 10 - Other Financial Industry Activities and Affiliations .......................................................................... 13
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .... 14
Item 12 - Brokerage Practices........................................................................................................................................ 15
Item 13 - Review of Accounts ........................................................................................................................................ 16
Item 14 - Client Referrals and Other Compensation ............................................................................................ 17
Item 15 - Custody ................................................................................................................................................................ 17
Item 16 - Investment Discretion ................................................................................................................................... 17
Item 17 - Voting Client Securities ................................................................................................................................ 18
Item 18 - Financial Information .................................................................................................................................... 18
Page 3
Item 4 - Advisory Business
General Information
Wealth Dimensions Group, Ltd. (“WDG”) was formed in 1990 (succeeding Spectrum Financial
Advisors, LLC in 2009) and provides financial planning, portfolio management and general
consulting services to its clients.
Thomas A. Curti, Douglas P. Loftus, Daniel D. Vogelpohl, Eric M. Loftus, and Matthew S. Bolser are
the Principals and the owners of WDG. For more information, please contact us to receive a copy of
the WDG Form ADV Part 2B brochure supplement.
As of December 31, 2024, WDG managed $1,023,470,007 on a discretionary basis and $1,596,043
on a non-discretionary basis, for a total of $1,025,066,050 regulatory assets under management.
SERVICES OFFERED
At the outset of each client relationship, WDG spends time with the client, asking questions,
discussing the client’s investment experience and financial circumstances, and broadly identifying
major goals of the client.
Clients may elect to retain WDG to prepare a full financial plan. This written report is presented to
the client for consideration. In most cases, clients subsequently retain WDG to manage the
investment portfolio on an ongoing basis.
For those financial planning clients making this election, and for other clients who do not need
financial planning but retain WDG for portfolio management services, based on all the information
initially gathered, WDG generally develops with each client:
• a financial outline for the client based on the client’s financial circumstances and goals, and
•
the client’s risk tolerance level (the “Financial Profile” or “Profile”);
the client’s investment objectives and guidelines (the “Investment Plan” or “Plan”).
The Financial Profile is a reflection of the client’s current financial picture and a look to the future
goals of the client. The Investment Plan outlines the types of investments WDG will make or
recommend on behalf of the client to meet those goals. The Profile and the Plan are discussed
regularly with each client but are not necessarily written documents.
Finally, where WDG provides only limited financial planning or general consulting services, WDG
will work with the client to prepare an appropriate summary of the specific project(s) to the extent
necessary or advisable under the circumstances.
Financial Planning
One of the services offered by WDG is financial planning, described below. This service may be
provided as a stand-alone service or may be coupled with ongoing portfolio management.
Financial planning may include advice that addresses one or more areas of a client's financial
situation, such as estate planning, risk management, budgeting and cash flow controls, retirement
planning, education funding, and investment portfolio design. Depending on a client’s particular
situation, financial planning may include some or all of the following:
Page 4
• Gathering factual information concerning the client's personal and financial situation;
• Assisting the client in establishing financial goals and objectives;
• Analyzing the client’s present situation and anticipated future activities in light of the
•
client’s financial goals and objectives;
Identifying problems foreseen in the accomplishment of these financial goals and objectives
and offering alternative solutions to the problems;
• Making recommendations to help achieve retirement plan goals and objectives;
• Designing an investment portfolio to help meet the goals and objectives of the client;
• Providing estate planning strategies;
• Assessing risk and reviewing basic health, life and disability insurance needs;
• Providing tax planning strategies; or
• Reviewing goals and objectives and measuring progress toward these goals.
Once Financial Planning advice is given, the client may choose to have WDG implement the client’s
financial plan and manage the investment portfolio on an ongoing basis. However, the client is
under no obligation to act upon any of the recommendations made by WDG under a Financial
Planning engagement and/or engage the services of any recommended professional.
Estate Planning Services
To the extent requested by the client, WDG will consult on estate planning matters as part of its
investment advisory services. WDG does not hold itself out as providing estate planning services
separately from its primary service of investment management. Estate planning assistance generally
includes an estate plan review and estate document audit. Estate planning assistance should not be
construed as legal advice.
Please Note: WDG does not hold itself out to be a law firm or to provide legal advice. WDG does
employ an attorney, Kayla Lucke, to support the needs of WDG clients. The work she performs as an
employee of WDG is consultative and should not be construed as legal advice. If and when Ms. Lucke
is engaged to practice law it is through a separate entity, Kayla Lucke, LLC, and established by a
separate written agreement with the client. To the extent requested by a client, WDG will recommend
one or more attorneys for client legal work. The client is under no obligation to engage the services
of any such recommended attorney. If the client engages any such recommended attorney, and a
dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively
from and against the engaged attorney.
Portfolio Management
As described above, at the beginning of a client relationship, WDG meets with the client, gathers
information, and performs research and analysis as necessary to develop the client’s Investment
Plan. The Investment Plan will be updated from time to time when requested by the client, or when
determined to be necessary or advisable by WDG based on information provided by the client
regarding changes in the client’s financial circumstances.
To implement the client’s Investment Plan, WDG will manage the client’s investment portfolio on a
discretionary or a non-discretionary basis. As a discretionary investment adviser, WDG will have
the authority to supervise and direct trades in the portfolio as agreed but without specific
consultation with the client. Under a non-discretionary arrangement, clients must be contacted
prior to the execution of any trade in the account(s) under management. This may result in a delay
in executing recommended trades, which could adversely affect the performance of the portfolio.
This delay also normally means the affected account(s) will not be able to participate in block
Page 5
trades, a practice designed to enhance the execution quality, timing and/or cost for all accounts
included in the block. In a non-discretionary arrangement, the client retains the responsibility for
the final decision on all actions taken with respect to the portfolio.
Notwithstanding the foregoing, clients will have the opportunity to impose certain written
restrictions on WDG in the management of their investment portfolios, such as prohibiting the
inclusion of certain types of investments in an investment portfolio or prohibiting the sale of
certain investments held in the account at the commencement of the relationship. Each client
should note, however, that certain restrictions imposed by a client will adversely affect the
composition and performance of the client’s investment portfolio. Each client should also note
that his or her investment portfolio is treated individually by giving consideration to each purchase
or sale for the client’s account. For these and other reasons, performance of certain client
investment portfolios within the same investment objectives, goals and/or risk tolerance will
differ and clients should not expect that the composition or performance of their investment
portfolios would necessarily be consistent with similar clients of WDG.
Third Party Advisors (Managers)
From time to time, WDG recommends the use of a third- p a r t y advisor, each a “Manager.” In such
cases, WDG will typically gather information from the clients about the client’s financial situation,
investment objectives, and reasonable restrictions the clients want imposed on the management of
the account. WDG does not review specific securities purchased by the Manager, on a trade-by-trade
basis.
WDG will periodically review reports provided to the clients by the Manager. WDG will contact the
client periodically, as agreed to with the clients, to review the client’s financial situation and
objectives; communicate information to the Manager managing the account as warranted; and assist
the clients in understanding and evaluating the services provided by the Manager. Clients will be
expected to notify WDG of any changes in their financial situation, investment objectives, or account
restrictions. Clients may also contact directly the Manager managing the account.
A complete description of the programs and services available through the Manager will be provided
to the client upon receipt and review of the applicable Manager’s Form ADV Part 2A and 2B and/or
equivalent brochures, investment advisory contracts, and account opening documents. WDG makes
every reasonable attempt to ensure that any investment advisers that the firm selects or
recommends to clients are properly licensed or exempt from registration.
Covered Call Strategy
Certain clients of WDG hold large positions in one or more securities with very low- c os t basis.
The tax implications of selling the shares could, at least in the short run, outweigh the benefits of
diversification. WDG’s Covered Call Strategy is designed with the goals of delivering increased total
return, creating additional income, and/or providing an alternative to liquidating a concentrated
position. When appropriate for a client, using our disciplined investment approach we construct
a customized portfolio to meet the unique needs of each client, taking into consideration tax
requirements, risk and return, and liquidity needs. Our investment specialists conduct in-depth
research to identify investment opportunities while monitoring portfolios daily.
General Consulting
In addition to the foregoing services, WDG provides general consulting services to clients. These
services are generally provided on a project basis, and may include, without limitation, minimal
cash flow planning for certain events such as education expenses or retirement, estate planning
Page 6
analysis, income tax planning analysis and review of a client’s insurance portfolio, as well as other
matters specific to the client and when requested by the client and agreed to by WDG. The scope
and fees for consulting services will be negotiated with each client at the time of engagement for the
applicable project.
Retirement Plan Advisory Services
Establishing a sound fiduciary governance process is vital to good decision-making and to ensuring
that prudent procedural steps are followed in making investment decisions. WDG will provide
Retirement Plan consulting services to Plans and Plan Fiduciaries as described below. The
particular services provided will be detailed in the consulting agreement. The appropriate Plan
Fiduciary(ies) designated in the Plan documents (e.g., the Plan sponsor or named fiduciary) will (i)
make the decision to retain our firm; (ii) agree to the scope of the services that we will provide; and
(iii) make the ultimate decision as to accepting any of the recommendations that we may provide.
The Plan Fiduciaries are free to seek independent advice about the appropriateness of any
recommended services for the Plan. Retirement Plan consulting services may be offered individually
or as part of a comprehensive suite of services.
The Employee Retirement Income Security Act of 1974 (“ERISA”) sets forth rules under which Plan
Fiduciaries may retain investment advisers for various types of services with respect to Plan assets.
For certain services, WDG will be considered a fiduciary under ERISA. For example, WDG will act as
an ERISA § 3(21) fiduciary when providing non-discretionary investment advice to the Plan
Fiduciaries by recommending a suite of investments as choices among which Plan Participants may
select. Also, to the extent that the Plan Fiduciaries retain WDG to act as an investment manager
within the meaning of ERISA § 3(38), WDG will provide discretionary investment management
services to the Plan.
With respect to any account for which WDG meets the definition of a fiduciary under Department of
Labor rules, WDG acknowledges that both WDG and its Related Persons are acting as fiduciaries.
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 interests
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.
Additional disclosure may be found elsewhere in this Brochure or in the written agreement between
WDG and Client.
Page 7
Fiduciary Consulting Services
•
Investment Selection Services
WDG will provide Plan Fiduciaries with recommendations of investment options consistent
with ERISA section 404(c). Plan Fiduciaries retain responsibility for the final determination
of investment options and for compliance with ERISA section 404(c).
• Non-Discretionary Investment Advice
WDG provides Plan Fiduciaries and Plan Participants general, non-discretionary investment
advice regarding asset classes and investments.
•
that document
investment performance, consistency of
Investment Monitoring
WDG will assist in monitoring the plan’s investment options by preparing periodic
investment reports
fund
management and conformation to the guidelines set forth in the investment policy
statement and WDG will make recommendations to maintain or remove and replace
investment options. The details of this aspect of service will be enumerated in the
engagement agreement between the parties.
Fiduciary Management Services
• Discretionary Management Services
When retained as an investment manager within the meaning of ERISA § 3(38), WDG
provides continuous and ongoing supervision over the designated retirement plan assets.
WDG will actively monitor the designated retirement plan assets and provide ongoing
management of the assets. When applicable, WDG will have discretionary authority to
make all decisions to buy, sell or hold securities, cash or other investments for the
designated retirement plan assets in our sole discretion without first consulting with the
Plan Fiduciaries. We also have the power and authority to carry out these decisions by
giving instructions, on your behalf, to brokers and dealers and the qualified custodian(s) of
the Plan for our management of the designated retirement plan assets.
• Discretionary Investment Selection Services
WDG will monitor the investment options of the Plan and add or remove investment options
for the Plan without prior consultation with the Plan Fiduciaries. WDG will have
discretionary authority to make and implement all decisions regarding the investment
options that are available to Plan Participants.
•
Investment Management via Model Portfolios
WDG will provide discretionary management of Model Portfolios among which the
participants may choose to invest as Plan options. Plan Participants will also have the
option of investing only in options that do not include Model Portfolios (i.e., the Plan
Participants may elect to invest in one or more of the mutual fund options made available in
the Plan, and choose not to invest in the Model Portfolios at all).
Additional Consulting Services
On occasion, WDG is engaged as a consultant to perform the following types of services:
Asset Tracing and Forensics
• Financial Evaluation Analysis
• Financial Projections
• Tax Analysis
• Tax Services
• Business Consulting Services
Page 8
These services are provided for investment advisory clients as well as for non-clients. Clients are not
obligated to use these services.
Client Communications and Delivery of Documents
Where appropriate, WDG may combine the mailing of client statements and other client
correspondence and information for accounts that have a common address (householding). Client may
revoke client’s consent at any time by contacting WDG in writing. If client chooses to revoke client’s
consent, WDG will begin sending separate mailings within 30 days after receiving notice of revocation.
In addition, from time to time, Adviser may be required to deliver certain documents to the client. Client,
to the extent that client has email capability and/or web access, hereby consents to the Adviser’s use of
electronic means, such as email, to make delivery of required and other documents. This delivery may
include notification of the availability of such document(s) on a website, and client agrees that such
notification will constitute “delivery.” In conjunction with the investment advisory agreement, the
client agrees to provide WDG with the client’s email address and to keep this information current at all
times by promptly notifying WDG of any change in email address.
Item 5 - Fees and Compensation
General Fee Information
Fees paid to WDG are exclusive of all custodial and transaction costs paid to the client’s custodian,
brokers or other third-party consultants. Please see Item 12 - Brokerage Practices for additional
information. Fees paid to WDG are also separate and distinct from the fees and expenses charged
by mutual funds, ETFs (exchange traded funds) or other investment pools to their shareholders
(generally including a management fee and fund expenses, as described in each fund’s prospectus
or offering materials). The client should review all fees charged by funds, brokers, WDG and others
to fully understand the total amount of fees paid by the client for investment and financial-related
services.
Financial Planning Fees
Financial planning services are often included as part of the investment advisory services to WDG
wealth management clients. For those clients who separately retain WDG to complete a full written
financial plan, WDG will have a written estimate provided to them prior to the commencement
of work on the project. The agreed upon fee is payable one-half in advance, and the balance upon
completion of the plan. In the event of termination prior to the completion of the plan, partial refunds
will be prorated based on the value of the amount of work already performed on the plan. In addition
to full financial plans, WDG offers hourly financial planning consultations. The fees for this service
range from $150 to $350 per hour and is payable in arrears. Where applicable and with the proper
client authorization, fees will be debited directly from client accounts.
Portfolio Management Fees
The annual fee schedule, based on a percentage of assets under management, is as follows:
First $1,000,000
Next $2,000,000
Next $2,000,000
Balance above $5,000,000
1.00%
0.75%
0.60%
0.50%
The minimum portfolio value is generally set at $500,000. The minimum annual fee for any account
is $5,000. WDG may, at its discretion, make exceptions to the foregoing or negotiate special fee
arrangements where WDG deems it appropriate under the circumstances and factors involved,
including discounted fees for charitable or civic organizations.
Page 9
Portfolio management fees are generally payable quarterly, in advance. If management begins after
the start of a quarter, fees will be prorated accordingly. With client authorization and unless other
arrangements are made, fees are normally debited directly from client account(s).
Either WDG or the client may terminate their Investment Advisory Agreement at any time, subject
to any written notice requirements in the agreement. In the event of termination, any paid but
unearned fees will be promptly refunded to the client based on the number of days that the account
was managed, and any fees due to WDG from the client will be invoiced or deducted from the
client’s account prior to termination.
Third Party Advisor Fees
When utilized, Third Party Advisors will charge a fee to manage the client’s account. This fee is
separate from and in addition to the fee assessed by WDG.
General Consulting Fees
When WDG provides general consulting services to clients, these services are generally separate
from WDG’s financial planning and portfolio management services. Fees for general consulting are
negotiated at the time of the engagement for such services and are normally based on an hourly or
fixed fee basis.
Other Compensation
Certain Principals and employees of WDG maintain licenses with various life and disability insurance
companies and will receive, if applicable, commissions for sales of insurance products in their
individual capacity (and not as WDG representatives). In all such circumstances, however, the client
will be notified of this payment in advance of the transaction, and under no circumstances will the
client pay both a commission to these individuals and a management fee to WDG on the same
pool of assets. Clients are under no obligation to purchase insurance products.
Certain employees of WDG maintain licenses to practice law and will receive, if applicable, legal fees
for the provision of these services in their individual capacities (and not as WDG representatives). In
all circumstances, the client will have executed a separate written agreement defining these services.
Clients are under no obligation to consult with a particular attorney and are free to consult with any
attorney they choose.
Item 6 - Performance-Based Fees and Side-By-Side Management
WDG does not have any performance-based fee arrangements. “Side-by Side-Management” refers
to a situation in which the same firm manages accounts that are billed based on a percentage of
assets under management and at the same time manages other accounts for which fees are assessed
on a performance fee basis. Because WDG has no performance-based fee accounts, it has no side-
by-side management.
Item 7 - Types of Clients
WDG serves individuals, pension and profit-sharing plans, corporations, trusts, estates and
charitable organizations. With some exceptions, the minimum portfolio value eligible for
conventional investment advisory services is $500,000, and the annual minimum fee charged is
$5,000. Under certain circumstances and in its sole discretion, WDG may negotiate such minimums.
Page 10
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
In accordance with the Investment Plan, WDG primarily invests in mutual funds for client accounts.
However, when appropriate based on portfolio objective, and other factors, WDG may invest in
individual securities as well as ETFs (exchange traded funds).
WDG’s methods of analysis include an evaluation of portfolio statistics including beta, standard
deviation, turnover, management and trading cost, style drift, performance, risk, correlation and
mean-variance analysis. In addition, for individual securities we look at fundamental research,
earnings growth, dividend yield, dividend growth and reliability, and analysts’ recommendations.
In addition, WDG looks for opportunities to take advantage of market dynamics such as liquidity or
political events that create short-term displacement in asset pricing.
Investment Strategies
Overall Strategy
WDG uses a diversified asset allocation approach with a tilt to value-oriented securities. For the
equity exposure in growth-oriented portfolios, WDG primarily uses Dimensional Fund Advisor
(“DFA”) mutual funds to create a low-cost, low turnover portfolio with no style drift or overlap.
WDG will then fill in around the core with other funds or ETFs.
In some cases, WDG may recommend the use of third-party advisors. These outside managers
would fill specific roles in the management of the overall portfolio. Examples of specific areas
include small capitalization growth management, large capitalization value management, and
international investments. In some cases, WDG may recommend the use of several managers in the
same asset class to access a more diversified knowledge pool.
WDG’s approach is to invest each portfolio in accordance with the Plan that has been developed
specifically for each client. This means that the following strategies may be used in varying
combinations over time for a given client, depending upon the client’s individual circumstances.
Long Term Purchases – securities purchased with the expectation that the value of those
securities will grow over a relatively long period of time, generally greater than one year.
Short Term Purchases – securities purchased with the expectation that they will be sold
within a relatively short period of time, generally less than one year, to take advantage of
the securities’ short-term price fluctuations.
Margin Transactions – a securities transaction in which an investor borrows money to
purchase a security, in which case the security serves as collateral on the loan.
Options Trading/Writing – a securities transaction that involves buying or selling (writing)
an option. If you write an option, and the buyer exercises the option, you are obligated to
purchase or deliver a specified number of shares at a specified price at the exercise of the
option regardless of the market value of the security at expiration of the option. Buying an
option gives you the right to purchase or sell a specified number of shares at a specified
price until the date of expiration of the option regardless of the market value of the security
at expiration of the option.
Page 11
Covered Call Strategy
As described in Item 4 - Advisory Business, from time to time and when appropriate for individual
clients WDG may employ a Covered Call Strategy to assist clients in dealing with a concentrated
position in one or more securities or to create additional income in the portfolio. The most effective
strategy to reduce the risk of a concentrated position in most cases is to liquidate the position and
construct a well-diversified portfolio. However, due to restrictions on selling the stock, tax
consequences, or personal preferences, selling the position is not always a viable option. In these
cases, we will customize a strategy that meets the unique needs of each client and one that is
tailored specifically to the concentrated position.
A covered call is a combination of owning shares of a stock and selling (or writing) call options
against those shares. The seller of the call option (you) receives an upfront cash premium while the
buyer of the call option receives the right, but not the obligation, to purchase a fixed number of
shares of the stock at the predetermined price. While the sale of a covered call generates positive
cash flow, it does not eliminate the downside risk of stock ownership. Investing in stock options is
generally considered to carry higher risk than just owning the shares of stock. However, at WDG
we believe the protections offered by this strategy, such as increased income to the portfolio and
diversification achieved through the use of margin, outweighs the additional risk of a covered call
strategy.
Risk of Loss
While WDG seeks to diversify clients’ investment portfolios across various asset classes consistent
with their Investment Plans in an effort to reduce risk of loss, all investment portfolios are subject
to risks. Accordingly, there can be no assurance that client investment portfolios will be able to
fully meet their investment objectives and goals, or that investments will not lose money. Below is a
description of several of the principal risks that client investment portfolios face.
Management Risks. While WDG manages client investment portfolios or recommends one or more
Managers based on WDG’s experience, research and proprietary methods, the value of client
investment portfolios will change daily based on the performance of the underlying securities in
which they are invested. Accordingly, client investment portfolios are subject to the risk that WDG
or a Manager allocates client assets to individual securities and/or asset classes that are adversely
affected by unanticipated market movements, and the risk that WDG’s specific investment choices
could underperform their relevant indexes.
Risks of Investments in Mutual Funds, ETFs and Other Investment Pools. As described above, WDG or
a Manager(s) may invest client portfolios in mutual funds, ETFs and other investment pools (“pooled
investment funds”). Investments in pooled investment funds are generally less risky than investing
in individual securities because of their diversified portfolios; however, these investments are still
subject to risks associated with the markets in which they invest. In addition, pooled investment
funds’ success will be related to the skills of their particular managers and their performance in
managing their funds. Pooled investment funds are also subject to risks due to regulatory restrictions
applicable to registered investment companies under the Investment Company Act of 1940.
Equity Market Risks. WDG or a Manager(s) will generally invest portions of client assets directly
into equity investments, either stocks or pooled investment funds that invest in the stock market.
As noted above, while pooled investments have diversified portfolios that may make them less risky
than investments in individual securities, funds that invest in stocks and other equity securities are
nevertheless subject to the risks of the stock market. These risks include, without limitation, the
Page 12
risks that stock values will decline due to daily fluctuations in the markets, and that stock values
will decline over longer periods (e.g., bear markets) due to general market declines in the stock
prices for all companies, regardless of any individual security’s prospects.
Fixed Income Risks. WDG or a Manager(s) may invest portions of client assets directly into fixed
income instruments, such as bonds and notes, or may invest in pooled investment funds that invest
in bonds and notes. While investing in fixed income instruments, either directly or through pooled
investment funds, is generally less volatile than investing in stock (equity) markets, fixed income
investments nevertheless are subject to risks. These risks include, without limitation, interest rate
risks (risks that changes in interest rates will devalue the investments), credit risks (risks of default
by borrowers), or maturity risk (risks that bonds or notes will change value from the time of
issuance to maturity).
Foreign Securities Risks. WDG or a Manager(s) may invest portions of client assets into pooled
investment funds that invest internationally. While foreign investments are important to the
diversification of client investment portfolios, they carry risks that may be different from U.S.
investments. For example, foreign investments may not be subject to uniform audit, financial
reporting or disclosure standards, practices or requirements comparable to those found in the U.S.
Foreign investments are also subject to foreign withholding taxes and the risk of adverse changes in
investment or exchange control regulations. Finally, foreign investments may involve currency
risk, which is the risk that the value of the foreign security will decrease due to changes in the
relative value of the U.S. dollar and the security’s underlying foreign currency.
Item 9 - Disciplinary Information
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 WDG or the integrity of WDG’s
management. WDG has no disciplinary events to report.
Item 10 - Other Financial Industry Activities and Affiliations
WDG is affiliated with Wealth Dimensions Family Office, Inc., a Registered Investment Adviser.
WDG serves as a sub-adviser for Wealth Dimensions Family Office and receives compensation for
the service.
Doug Loftus and Thomas Curti, each a Principal and Managing Member of WDG, are also owners of
Professional Practice Advisors, LLC (“PPA”), a practice management consulting firm for dentists and
other medical professionals. Because WDG and PPA are under common ownership, there is a benefit
for the firms to share clients. Although the two firms may each recommend the other to clients,
there is no requirement that any client of one firm use the services of the other. The services
of WDG and PPA are separate and distinct from one another and provided for separate and typical
compensation. Neither firm pays a referral fee to the other for recommending a client.
One of WDG's employees, Kayla Lucke, is also an attorney and owner of Kayla Lucke, LLC. Ms. Lucke
shares office space with the Wealth Dimensions Group office. To the extent that a client specifically
requests legal advice, WDG will recommend the services of an attorney, including Ms. Lucke in her
individual capacity as a licensed attorney, and/or the services of Kayla Lucke, LLC. Any such legal
services shall be rendered independent of WDG pursuant to a separate agreement between the client
and Kayla Lucke, LLC. The recommendation by WDG’s employees that a client engage the services of
Ms. Lucke, in her individual capacity as an attorney, or Kayla Lucke, LLC, presents a conflict of
interest. No client is under any obligation to engage Ms. Lucke in her individual capacity as an
attorney or engage the services of Kalyla Lucke, LLC.
Page 13
As indicated under Item 5 – Fees and Compensation above, certain Principals and employees of
WDG maintain licenses with various life and disability insurance companies and will receive, if
applicable, commissions for sales of insurance products in their individual capacity (and not as WDG
representatives). In all such circumstances, however, the client will be notified of this payment in
advance of the transaction, and under no circumstances will the client pay both a commission to these
individuals and a management fee to WDG on the same pool of assets. Please note, clients are under
no obligation to purchase any of the recommended life insurance products.
Certain employees of WDG maintain licenses to practice law and will receive, if applicable, legal fees
for the provision of these services in their individual capacities (and not as WDG representatives). In
all circumstances, the client will have executed a separate written agreement defining these services.
Clients are under no obligation to consult with a particular attorney and are free to consult with any
attorney they choose.
WDG’s Chief Compliance Officer, Ms. Karey Williams, remains available to address any questions that
a client or prospective client may have regarding the above conflicts of interest.
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Code of Ethics and Personal Trading
WDG has adopted a Code of Ethics (“the Code”), the full text of which is available to you upon
request. WDG’s Code has several goals. First, the Code is designed to assist WDG in complying with
applicable laws and regulations governing its investment advisory business. Under the Investment
Advisers Act of 1940, WDG owes fiduciary duties to its clients. Pursuant to these fiduciary duties,
the Code requires persons associated with WDG (managers, officers and employees) to act with
honesty, good faith and fair dealing in working with clients. In addition, the Code prohibits such
associated persons from trading or otherwise acting on insider information.
Next, the Code sets forth guidelines for professional standards for WDG’s associated persons. Under
the Code’s Professional Standards, WDG expects its associated persons to put the interests of its
clients first, ahead of personal interests. In this regard, WDG associated persons are not to take
inappropriate advantage of their positions in relation to WDG clients.
Third, the Code sets forth policies and procedures to monitor and review the personal trading
activities of associated persons. From time to time, WDG’s associated persons may invest in the
same securities recommended to clients. Under its Code, WDG has adopted procedures designed to
reduce or eliminate conflicts of interest that this could potentially cause. The Code’s personal
trading policies include procedures for limitations on personal securities transactions of associated
persons, reporting and review of such trading and pre-clearance of certain types of personal trading
activities. These policies are designed to discourage and prohibit personal trading that would
disadvantage clients. The Code also provides for disciplinary action as appropriate for violations.
Participation or Interest in Client Transactions
Because associated persons will invest in the same securities as those purchased in client accounts,
WDG has established a policy requiring its associated persons to pre-clear transactions in some types
of securities with the Chief Compliance Officer. The goal of this policy is to avoid any conflicts
of interest that arise in these situations. Some types of securities, such as CDs, U.S. Treasury
obligations, ETFs, and open-end mutual funds are exempt from this pre-clearance requirement.
However, in the event of other identified potential trading conflicts of interest, WDG’s goal is to place
client interests first.
Page 14
Consistent with the foregoing, WDG maintains policies regarding participation in initial public
offerings (“IPOs”) and private placements to comply with applicable laws and avoid conflicts with
client transactions. If a WDG associated person wishes to participate in an IPO or invest in a private
placement, he or she must submit a pre-clearance request and obtain the approval of the Chief
Compliance Officer.
Finally, if associated persons trade with client accounts (i.e., in a bundled or aggregated trade), and
the trade is not filled in its entirety, the associated person’s shares will be removed from the block,
and the balance of shares will be allocated among client accounts in accordance with WDG’s written
policy.
Item 12 - Brokerage Practices
Best Execution and Benefits of Brokerage Selection
When given discretion to select the brokerage firm that will execute orders in client accounts, WDG
seeks “best execution” for client trades, which is a combination of a number of factors, including,
without limitation, quality of execution, services provided, and commission rates. Therefore, WDG
may use or recommend the use of brokers who do not charge the lowest available commission in
the recognition of research and securities transaction services, or quality of execution. Research
services received with transactions may include proprietary or third-party research (or any
combination) and may be used in servicing any or all of WDG’s clients. Therefore, research services
received may not be used for the account for which the particular transaction was effected.
WDG participates in Fidelity’s Institutional Wealth Services (“FIWS”) program. While there is no
direct link between the investment advice WDG provides and participation in the FIWS program,
WDG receives certain economic benefits from the program. These benefits include software and
other technology that provides access to client account data (such as trade confirmations and
account statements), facilitates trade execution (and allocation of aggregated orders for multiple
client accounts), provides research, pricing information and other market data, facilitates the
payment of WDG’s fees from its clients’ accounts, and assists with back-office functions,
recordkeeping and client reporting. Many of these services are used to service all or a substantial
number of WDG’s accounts, including accounts not held at Fidelity.
Fidelity also makes available to WDG other services intended to help WDG manage and further
develop its business. These services include consulting, publications and conferences on practice
management, information technology, business succession, regulatory compliance and marketing.
In addition, Fidelity makes available, arranges, and/or pays for these types of services to be
rendered to WDG by independent third parties. Fidelity discounts or waives fees it would
otherwise charge for some of these services, pays all or a part of the fees of a third-party providing
these services to WDG, and/or Fidelity pays for travel expenses relating to participation in such
training. These services are not soft dollar arrangements but are part of the institutional platform
offered by Fidelity. Finally, participation in the FIWS program provides WDG with access to mutual
funds which normally require significantly higher minimum initial investments or are normally
available only to institutional investors.
The benefits received through participation in the FIWS program do not necessarily depend upon
the proportion of transactions directed to Fidelity. The benefits are received by WDG, in part
because of commission revenue generated for Fidelity by WDG’s clients. This means that the
investment activity in client accounts is beneficial to WDG, because Fidelity does not assess a fee to
Page 15
WDG for these services. This creates an incentive for WDG to continue to recommend Fidelity to its
clients. While it may be possible to obtain similar custodial, execution and other services elsewhere
at a lower cost, WDG believes that Fidelity provides an excellent combination of these services.
Directed Brokerage
Clients may direct WDG to use a particular broker for custodial or transaction services on behalf of
the client’s portfolio. In directed brokerage arrangements, the client is responsible for negotiating
the commission rates and other fees to be paid to the broker. Accordingly, a client who directs
brokerage should consider whether such designation may result in certain costs or disadvantages
to the client, either because the client may pay higher commissions or obtain less favorable
execution, or the designation limits the investment options available to the client.
The arrangement that WDG has with Fidelity is designed to maximize efficiency and to be cost
effective. By directing brokerage arrangements, the client acknowledges that these economies of
scale and levels of efficiency are generally compromised when alternative brokers are used. While
every effort is made to treat clients fairly over time, the fact that a client chooses to use the
brokerage and/or custodial services of these alternative service providers can in fact result in a
certain degree of delay in executing trades for their account(s) and otherwise adversely affect
management of their account(s).
By directing WDG to use a specific broker or dealer, clients who are subject to ERISA confirm and
agree to the following: that they have the authority to make the direction; there are no provisions
in any client or plan document which are inconsistent with the direction; that the brokerage and other
goods and services provided by the broker or dealer through the brokerage transactions are
provided solely to and for the benefit of the client’s plan participants, and their beneficiaries; that
the amount paid for the brokerage and other services have been determined by the client and the
plan to be reasonable; that any expenses paid by the broker on behalf of the plan are expenses that
the plan would otherwise be obligated to pay; and that the specific broker or dealer is not a party
in interest of the client or the plan as defined under applicable ERISA regulations.
Aggregated Trade Policy
WDG typically directs trading in individual client accounts when appropriate based on the client’s
Investment Plan, without regard to activity in other client accounts. However, from time to time,
WDG will aggregate trades together for multiple client accounts, most often when these accounts
are being directed to sell the same securities. If such an aggregated trade is not completely filled,
WDG will allocate shares received (in an aggregated purchase) or sold (in an aggregated sale) across
participating accounts on a pro rata or other fair basis; provided, however, that any participating
accounts that are owned by WDG or its officers, directors, or employees will be excluded first.
Item 13 - Review of Accounts
Managed portfolios are reviewed on an ongoing basis but may be reviewed more often if requested
by the client, upon receipt of information material to the management of the portfolio, or at any
time such review is deemed necessary or advisable by WDG. These factors generally include but
are not limited to, the following: change in general client circumstances (marriage, divorce,
retirement); or economic, political or market conditions. WDG’s Principals and Associated Persons
review all accounts.
For those clients to whom WDG provides separate financial planning and/or consulting services,
reviews are conducted on an as needed or agreed upon basis. Such reviews are conducted by one of
WDG’s investment adviser representatives or principals.
Page 16
Account custodians are responsible for providing monthly or quarterly account statements which
reflect the positions (and current pricing) in each account as well as transactions in each account,
including fees paid from an account. Account custodians also provide prompt confirmation of all
trading activity, and year-end tax statements, such as 1099 forms. WDG will provide additional
written reports as needed or requested by the client.
Item 14 - Client Referrals and Other Compensation
As noted above, WDG receives an economic benefit from Fidelity in the form of support products
and services it makes available to WDG and other independent investment advisors whose clients
maintain accounts at Fidelity. These products and services, how they benefit our firm, and the
related conflicts of interest are described in Item 12 - Brokerage Practices. The availability of
Fidelity’s products and services to WDG is based solely on our participation in the programs and
not in the provision of any particular investment advice. Neither Fidelity nor any other outside party
is paid to refer clients to WDG.
Item 15 - Custody
Fidelity is the custodian of nearly all client accounts at WDG. From time to time however, clients
may select an alternate broker to hold accounts in custody. In any case, it is the custodian’s
responsibility to provide clients with confirmations of trading activity, tax forms and at least
quarterly account statements. Clients are advised to review this information carefully, and to notify
WDG of any questions or concerns. Clients are also asked to promptly notify WDG if the custodian
fails to provide statements on each account held.
From time to time and in accordance with WDG’s agreement with clients, WDG will provide
additional reports. The account balances reflected on these reports should be compared to the
balances shown on the brokerage statements to ensure accuracy. At times there may be small
differences due to the timing of dividend reporting and pending trades.
WDG will retain the services of an independent public accountant to conduct an annual surprise
audit of any accounts where it has been deemed to have custody. If requested by our clients, we will
provide them with a copy of Form ADV-E, which is filed with the SEC by the public accountant with
the results of the audit.
Item 16 - Investment Discretion
As described in Item 4 - Advisory Business, WDG will accept clients on either a discretionary or
non-discretionary basis. For discretionary accounts, a Limited Power of Attorney (“LPOA”) is
executed by the client, giving WDG the authority to carry out various activities in the account,
generally including the following: trade execution; the ability to request checks on behalf of the
client; and, the withdrawal of advisory fees directly from the account. WDG then directs investment
of the client’s portfolio using its discretionary authority. The client may limit the terms of the LPOA
to the extent consistent with the client’s investment advisory agreement with WDG and the
requirements of the client’s custodian.
For non-discretionary accounts, the client also generally executes an LPOA, which allows WDG to
carry out trade recommendations and approved actions in the portfolio. However, in accordance
with the investment advisory agreement between WDG and the client, WDG does not implement
trading recommendations or other actions in the account unless and until the client has approved
the recommendation or action. As with discretionary accounts, clients may limit the terms of the
LPOA, subject to WDG’s agreement with the client and the requirements of the client’s custodian.
Page 17
Item 17 - Voting Client Securities
As a policy and in accordance with WDG’s client agreement, WDG does not vote proxies related to
securities held in client accounts. The custodian of the account will normally provide proxy materials
directly to the client. Clients may contact WDG with questions relating to proxy procedures and
proposals; however, WDG generally does not research particular proxy proposals.
Item 18 - Financial Information
WDG does not require nor solicit prepayment of more than $1,200 in fees per client, six months or
more in advance, and therefore has no disclosure required for this item.
As an advisory firm that maintains discretionary authority for client accounts, Wealth Dimensions is
required to disclose any financial condition that is reasonably likely to impair its ability to meet
contractual commitments to clients. As this time, Wealth Dimensions does not reasonably believe it
is unable to meet any of its contractual commitments.
Page 18