A. General Description of Company Facet Wealth Inc. is a corporation formed on August 3, 2016 in the State of Delaware. Facet became registered as an Investment Adviser in November 2016. Anders Jones serves as Facet’s Chief Executive Officer and Patrick McKenna serves as Executive Chairperson, and each individually owns more than 5% of the firm. In addition, Durable Capital Partners through one investment fund, has an ownership interest of greater than 10% in the firm and Warburg Pincus, through two investment funds, has an ownership interest of greater than 25% in the firm.
B. Summary of Investment Advisory Services FINANCIAL PLANNING AND CONSULTING SERVICES Facet provides Members with the financial planning and/or consulting services as designated by the Member. The services provided depend on the nature and complexity of the Member’s situation and could include some or all of the following: financial goal setting, portfolio design and asset allocation, risk tolerance and capacity analysis, investment management, cash flow and expense planning, debt management and planning, employee benefits planning, employer stock plan analysis, retirement planning, education planning, risk management and insurance planning, estate planning and beneficiary, income tax planning, trust planning, small business planning, and small business retirement plans.
Prior to engaging Facet to provide financial planning and consulting services, the Member will be required to enter into a Financial Planning and Consulting Agreement with Facet setting forth the terms and conditions of the engagement and describing the scope of the services to be provided. Facet and the Member will work together to determine the specific suite of services to be provided. Facet’s financial planning and consulting fees are negotiable, but generally range from $2,400 to $8,000 per year on a flat fee basis, depending upon the level and scope of the services required.
The recommendations provided by Facet are focused solely on the individual needs of the Member. Facet engages in a Member intake process involving communication with prospective Members and the collection of their financial information to help determine each Member’s investment objectives and risk tolerance.
In performing its services, Facet shall not be required to verify any information received from the Member or from the Member’s other professionals and is expressly authorized to rely thereon. If requested by the Member, Facet shall recommend the services of other professionals for implementation purposes.
The Member is under no obligation to engage the services of any such recommended professional. If the Member engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the Member agrees to seek recourse exclusively from and against the engaged professional/firm.
The Member retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Facet.
Members are encouraged to renew Facet’s financial planning and consulting services on an annual basis for the purpose of reviewing and updating Facet’s previous recommendations and/or services.
It remains the Member’s responsibility to promptly notify Facet if there is ever any change in their financial situation or investment objectives for the purposeofreviewing,evaluating,orrevisingFacet’sprevious recommendations or services.
●Non-Investment Consulting/Implementation Services. For Members, Facet may provide consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. or direct services such as tax preparation. Any of those services will be provided under the Financial Planning and Consulting Agreement.
Some services may require a separate agreement with Facet or with the third party providing those services. Neither Facet, nor any of its representatives, serves as an attorney and no portion of Facet’s services should be construed as legal services. Accordingly, Facet does not prepare estate planning documents. To the extent requested by a Member, Facet may recommend the services of other professionals for certain non-investment

implementation purposes (i.e. attorneys, accountants, insurance, etc.), including certain of Facet’s related persons in their separate registered capacities as discussed below. The Member is under no obligation to engage the services of any such recommended professional. The Member retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Facet. No Member is under any obligation to purchase any securities or insurance commission products from a representative of Facet. Members are reminded that they may purchase securities and insurance products recommended by Facet through other, non-affiliated registered representatives of a custodian and/or insurance agencies.
●Retirement Plan Rollovers — No Obligation / Potential for Conflict of Interest. A Member or prospective Member leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the Member’s age, result in adverse tax consequences). If Facet recommends that a Member roll over their retirement plan assets into an account to be managed by Facet, such a recommendation creates a conflict of interest if Facet will earn a new (or increase its current) advisory fee as a result of the rollover. To the extent that Facet recommends that Members roll over assets from their retirement plan to an IRA managed by Facet, then Facet represents that it and its investment adviser representatives are fiduciaries under the Employment Retirement Income Security Act of 1974 (“ERISA”), or the Internal Revenue Code, or both. No Member is under any obligation to roll over retirement plan assets to an account managed by Facet. Facet’s Chief Compliance Officer, Christopher Hufman, remains available to address any questions that a Member or prospective Member may have regarding the conflict of interest presented by such rollover recommendation.
●ERISA / IRC Fiduciary Acknowledgment. (i) a participant or beneficiary of a Plan subject to Title I of ERISA or described in section 4975(e)(1)(A) of the Internal Revenue Code, with authority to direct the investment of assets in his or her Plan account or to take a distribution; (ii) the beneficial owner of an IRA acting on behalf of the IRA INVESTMENT MANAGEMENT SERVICES Facet does not generally offer standalone investment management services.
However, the Member can determine to engage Facet to provide discretionary investment management as part of its financial planning and consulting services. The list of such services available to a Member will be denoted on the relevant financial planning and consulting services agreement.
Prior to accepting discretionary authority over a Member’s assets, Facet engages in a Member intake process to determine each Member’s investment objectives and risk tolerance.
C. Tailored Services and Investment Restrictions Facet shall provide advisory services specific to the needs of each Member.
Prior to providing advisory services, an investment adviser representative will ascertain each Member’s investment objective(s). Thereafter, Facet shall recommend that the Member allocate investment assets consistent with the designated investment objective(s). The Member may, at any time, impose reasonable restrictions, in writing, on Facet’s services.
D. Wrap Fee Program Facet does not participate in a wrap fee program.
E. Assets Under Management As of March 2023, Facet had $2,078,080,182 in assets under management on a discretionary basis.
Facet considers every aspect of our Member’s financial lives in our approach to financial planning. We use a metric called Total Financial Life Resources (TFLR) which includes but is not limited to investments, cash, home equity, retired debt, and workplace retirement benefits and pensions. As of January 2023, our most recent TFLR calculation is over $15 billion.