WFPG is an investment adviser registered with the United States Securities and Exchange
Commission (“SEC”) and is a corporation formed under the laws of the State of Ohio.
WFPG offers asset management services through a wrap fee management program. In our wrap
fee management program, the fee for advisory services (including asset management) and
transaction costs` (including ticket charges) are “wrapped” into one fee. Our Asset Management
Services are considered a wrap fee program. Whenever a fee is charged for services described in
this Wrap Fee Program Brochure, we will receive all or a portion of the fee charged.
When making the determination of whether one of the advisory programs available through
WFPG is appropriate for your needs, you should bear in mind that fee-based accounts, when
compared with commission-based accounts, often result in lower costs during periods when
trading activity is heavier, such as the year an account is established. However, during periods
when trading activity is lower, the fee-based account arrangements may result in a higher annual
cost for transactions. Thus, depending on a number of factors, the total cost for transactions
under a fee account versus a commission account can vary significantly. Factors which affect the
total cost include account size, amount of turnover, type and quantities of securities purchased or
sold, commission rates and your tax situation. It should also be noted that lower fees for
comparable service may be available from other sources. The exact fees and other terms will be
outlined in the agreement between you and WFPG.
You should discuss the advantages and disadvantages of fee-based and commission-based
accounts with your adviser representative and you should read this Wrap Fee Disclosure
Brochure carefully as it explains, in detail, our Asset Management Services.
Investment Management Services
WFPG offers asset management services, which involves WFPG providing you with continuous
and ongoing supervision over your accounts. You can open a WRAP or Non-WRAP (traditional
asset management) account. A non-wrap or traditional account. This means in addition to the
investment advisory fee, you may also pay certain transaction charges to defray the costs
associated with trade execution. These costs are set out in the Charles Schwab & Company, Inc.
brokerage account and application agreement. A WRAP Account provides the same access to
asset management services but you do not pay transaction charges associated with trade
execution.
In providing asset management services, WFPG will continuously monitor your account and
make trades in your accounts when necessary. Your account will be managed by WFPG based
on your financial situation, investment objectives and risk tolerance. WFPG will actively
Waller Financial Planning Group, Inc. Page 6 Form ADV Part 2A Appendix 1
monitor your account and will make management recommendations and decisions regarding
buying, selling, reinvesting or holding securities, cash or other investments.
We recommend that your assets to be allocated to our Asset Management Services Program be
maintained in a brokerage account with Charles Schwab & Company, Inc., an SEC registered
broker/dealer and member NYSE/SIPC. Charles Schwab & Company, Inc. is the qualified
custodian for all accounts established through our asset management program. You will appoint
WFPG as your investment adviser of record on specified accounts. Your account will consist
only of separate account(s) held by the qualified custodian under your name. WFPG does not act
as custodian to your funds and securities except to have advisory fees deducted from your
account with your prior written authorization. The qualified custodian will maintain physical
custody of all funds and securities of your Account, and you will retain all rights of ownership
(e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive
transaction confirmations) for your account.
If you have authorized us to provide asset management services on a discretionary basis, we will
make all decisions to buy, sell or hold securities, cash or other investments in your managed
account in our sole discretion without consulting with you before making any transactions. You
must provide us with written authorization to exercise this discretionary authority, and you can
place reasonable restrictions and limitations on our discretionary authority.
Fees charged for our asset management services are charged based on a percentage of assets
under management, billed in advance (at the start of the billing period) on a quarterly basis and
calculated based on the fair market value of your account as of the last business day of the
current billing period. Fees are prorated (based on the number of days service is provided during
the initial billing period) for your account opened at any time other than the beginning of the
billing period. If asset management services are commenced in the middle of a billing period,
the prorated fee for the
initial billing period is billed in arrears at the same time as the next full
billing period’s fee is billed.
Fees charged for our asset management services are negotiable based on the complexity of the
client's situation, the potential for additional account deposits, the relationship of the client with
the investment adviser representative, and the total amount of assets under management for the
client.
For our asset management services, clients will be charged an annual flat fee of 0.50% of their
assets under management.
WFPG has a minimum annual fee of $3,000
The only compensation received by WFPG for asset management services is the annual fee as
specified in the client’s advisory services agreement. WFPG receives no other forms of
compensation in connection with providing asset management services.
Waller Financial Planning Group, Inc. Page 7 Form ADV Part 2A Appendix 1
WFPG believes that its annual fee is reasonable in relation to: (1) services provided and (2) the
fees charged by other investment advisers offering similar services/programs. However, our
annual investment advisory fee may be higher or lower than that charged by other investment
advisers offering similar services/programs. In addition to our compensation, you may also incur
charges imposed at the mutual fund level (e.g., advisory fees and other fund expenses).
The investment advisory fees will be deducted from your account and paid directly to our firm
by the qualified custodian(s) of your account. You will authorize the qualified custodian(s) of
your account to deduct fees from your account and pay such fees directly to our firm.
You should review your account statements received from the qualified custodian(s) and verify
that appropriate investment advisory fees are being deducted. The qualified custodian(s) will not
verify the accuracy of the investment advisory fees deducted.
You may incur certain charges imposed by third parties other than WFPG in connection with
investments made through your account including, but not limited to, surrender charges, variable
annuity fees and surrender charges, IRA and qualified retirement plan fees, and charges imposed
by the qualified custodian(s) of your account. Management fees charged by WFPG are separate
and distinct from the fees and expenses charged by investment company securities that may be
recommended to you. A description of these fees and expenses are available in each investment
company security’s prospectus.
The asset management services continue in effect until terminated by either party (i.e., WFPG or
you) by providing written notice of termination to the other party. Any prepaid, unearned fees
will be promptly refunded by WFPG to you. Fee refunds will be determined on a pro rata basis
using the number of days services are actually provided during the final period.
Block Trading
We may elect to purchase or sell the same securities for several clients at approximately the same
time. This process is referred to as aggregating orders, batch trading or block trading and is used
by our firm when WFPG believes such action may prove advantageous to clients. If and when
we aggregate client orders, allocating securities among client accounts is done on a fair and
equitable basis. Typically, the process of aggregating client orders is done in order to achieve
better execution, to negotiate more favorable transaction fees or costs or to allocate orders among
clients on a more equitable basis in order to avoid differences in prices and transaction fees or
other transaction costs that might be obtained when orders are placed independently.
WFPG uses the pro rata allocation method for transaction allocation.
Waller Financial Planning Group, Inc. Page 8 Form ADV Part 2A Appendix 1
Under this procedure, pro rata trade allocation means an allocation of the trade at issue among
applicable advisory clients in amounts that are proportional to the participating advisory client’s
intended investable assets. WFPG will calculate the pro rata share of each transaction included
in a block order and assigns the appropriate number of shares of each allocated transaction
executed for the client’s account.
If and when we determine to aggregate client orders for the purchase or sale of securities,
including securities in which WFPG or our associated persons may invest, we will do so in
accordance with the parameters set forth in the SEC No-Action Letter, SMC Capital, Inc.
Neither we nor our associated persons receive any additional compensation as a result of block
trades.
Suitability and Investment Strategy
WFPG will assist clients in determining their objective(s), investment strategy, and investment
suitability, prior and subsequent to opening an Asset Management account. Clients must contact
us to notify of any changes in their investment objective(s) and/or financial situation. Investment
strategies used to implement investment advice include, but are not necessarily limited to, long
term purchases (investments held at least a year).