Part 2A of Form ADV: Firm Brochure
Item 1

Cover Page

Occidental Asset Management, LLC
also doing business as

OCCAM
YMW Advisors

301 California Drive #9
Burlingame, CA 94010
www.occamllc.net

Telephone:
Facsimile:(650) 344-1600(650) 745-7347

February 13, 2024

This Brochure provides information about the qualifications and business practices of Occidental AssetManagement, LLC (“Occidental”, the “Advisor” or “we”). If you have any questions about the contentsof this Brochure, please contact us at by telephone at (650) 344-1600 or by email at nwhatton@occamllc.net. The
information in this Brochure has not been approved or verified by the United States Securities and Exchange
Commission (the “SEC”) or by any state securities authority.
Any reference to or use of the terms “registered investment adviser” or “registered,” does not imply
that Occidental Asset Management, LLC or any person associated with Occidental Asset Management,
LLC has achieved a certain level of skill or training. Additional information about Occidental also is available
on the SEC’s website at www.adviserinfo.sec.gov.
Registration of an investment Advisor with the SEC or with any state securities authority does not imply any
level of skill or training.

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
February 13, 2024-i-

Item 2

Material Changes

This statement refers to the disclosure brochure dated February 13, 2024.
Our previous brochure was dated January 12, 2024. The following material changes have been madein this version of the brochure:
Item 4 (Advisory Business): Updated client assets under management.
Item 12 (Brokerage Practices): Removed disclosure regarding TD Ameritrade.
Item 14 (Client Referrals and Other Compensation): Removed disclosure regarding TD
Ameritrade.

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
February 13, 2024
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Item 3

Table of Contents

Page
Item 1
Item 2Item 3Item 4
A.
B.
C.
D.
E.
Item 5A.
B.
C.
D.
Item 6Item 7Item 8A.
B.
C.
Item 9Item 10Item 11A.
B.
Item 12A.
B.
Item 13A.
B.
C.
Item 14
Item 15
Item 16
Item 17
Item 18

Cover Page .......................................................................................................................... iMaterial Changes ............................................................................................................... ii
Table of Contents ............................................................................................................. iii
Advisory Business .............................................................................................................. 1
General Description of Advisory Firm ...................................................................................................1
Description of Advisory Services (including any specializations) ......................................................1
Financial Planning Services.......................................................................................................................2
Wrap Fee Programs ...................................................................................................................................2
Client Assets Under Management ...........................................................................................................2
Fees and Compensation .................................................................................................... 3
Advisory Fees and Compensation ...........................................................................................................3
Payment of Fees .........................................................................................................................................4
Other Fees and Expenses .........................................................................................................................4
Prepayment of Fees ...................................................................................................................................5
Performance-Based Fees ................................................................................................... 6
Types of Clients ................................................................................................................. 7
Methods of Analysis, Investment Strategies and Risk of Loss ......................................... 8
Methods of Analysis and Investment Strategies....................................................................................8
Material Risks (Including Significant, or Unusual Risks) Relating to Investment Strategies..........9
Risks Associated with Types of Securities that are Primarily Recommended ..................................9
Disciplinary Information .................................................................................................. 11
Other Financial Industry Activities and Affiliations ........................................................ 12
Code of Ethics, Participation or Interest in Client Transactions andPersonal Trading .............................................................................................................. 13
Code of Ethics ......................................................................................................................................... 13
Personal Trading Policies ....................................................................................................................... 13
Brokerage Practices .......................................................................................................... 14
Factors Considered in Selecting or Recommending Broker-Dealers for Client Transactions ... 14
Block Allocation ...................................................................................................................................... 19
Review of Accounts ......................................................................................................... 20
Frequency and Nature of Review ......................................................................................................... 20
Factors Prompting a Non-Periodic Review of Accounts ................................................................. 20
Content and Frequency of Regular Account Report ......................................................................... 20
Client Referrals and Other Compensation ....................................................................... 21
Custody ............................................................................................................................ 23
Investment Discretion ..................................................................................................... 24
Voting Client Securities ................................................................................................... 25
Financial Information...................................................................................................... 26

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
February 13, 2024
- iii -

Item 4Advisory BusinessA.

General Description of Advisory Firm

Occidental Asset Management, LLC (the “Advisor”), is an independently owned limited liability
company formed under the laws of the State of Delaware, was formed on April 25, 2013. The Advisor
is currently wholly-owned by Occidental Capital, LLC, a Delaware limited liability company, which inturn is controlled by A. Charles Cattano, Brad T. Klontz, and Nathan H. Walsh.
Description of Advisory Services (including any specializations)B.

The Advisor will provide investment supervisory services on a discretionary and non-discretionary
basis to its clients who will include individuals and institutions with separately managed accounts. The
investment advisory services that the Advisor provides include wealth management and financial
planning services designed to provide each client with an investment plan tailored to achieve theirretirement and other financial planning goals.
The Advisor will have discretionary authority to make the following determinations without obtaining
the consent of the client before the transactions are effected:••••

the securities that are to be bought or sold;the total amount of the securities to be bought or sold;the brokers through which securities are to be bought or sold; andthe commission rates at which securities transactions for client accounts.

The Advisor’s authority may be subject to conditions imposed by the client, examples of which may
include where: 1) the client restricts or prohibits transactions in securities of a specific industry, and/or
2) the client directs that transactions be effected through specific brokers and dealers. The latter
restriction may be conditioned by the client on the broker or dealer being competitive as to price andexecution for each transaction, or offering a specified level of commission discount or may be subject
to varying degrees of restrictions such as an instruction to utilize the broker or dealer: a) whether or
not competitive, and b) where the specified levels of commission discounts are less favorable thanmight otherwise be obtained by the Advisor.
The Advisor may select certain independent managers (“Sub-advisors”) to actively manage a portionof its clients’ assets. The specific terms and conditions under which a client engages a Sub-advisor
will be set forth in a separate written agreement with the designated Sub-advisor. In addition to thisBrochure, clients will also receive the written disclosure documents of the designated Sub-advisor.
The Advisor evaluates a variety of information about Sub-advisors, including public disclosure
documents, materials supplied by the Sub-advisors and other third-party information it believes isreliable. The Advisor continues to provide services relative to the discretionary selection of Subadvisors. On an on-going basis, the Advisor monitors the performance of those accounts being
managed by Sub-advisors. The Advisor seeks to ensure that Sub-advisors’ strategies and allocations
remain aligned with clients’ investment objectives and overall best interests.
Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
February 13, 2024
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Please refer to Item 12—Brokerage Practices in this brochure for a discussion of Occidental’s services
offered through the Institutional Intelligent Portfolios® platform offered by Schwab Performance
Technologies.
C.

Financial Planning Services

The Advisor may provide certain clients with a financial analysis including non-investment related
matters. This service includes gathering of information regarding the client’s current and historicalstatus in the areas of net worth, income, expenses, taxes, investments, retirement plans andinsurance, as well as future goals and objectives. We then develop a personalized plan, which
includes specific recommendations in applicable areas.
Areas of focus may include retirement, education funding, survivor needs, or wealth transfers.
Our financial planning services do not include preparation of any kind of income tax, gift, or
estate tax returns nor preparation of any legal documents, including wills or trusts.
D.

Wrap Fee Programs

The Advisor does not currently participate in any wrap fee programs.
E.

Client Assets Under Management

As of December 31, 2023, the Advisor managed $625,459,642 on a discretionary basis on behalf of 473
clients.

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
February 13, 2024
-2-

Item 5

Fees and Compensation

A.

Advisory Fees and Compensation

The Advisor will charge each client an investment management fee (the “Management Fee”) basedon the value of the client’s assets under management, generally in accordance with the following
schedule:
Account Value

Annual Management
Fee Rate

Up to $200,000

1.50%$200,001 to $700,000

1.25%$700,001 to $1,200,000

1.15%$1,200,001 to $2,200,000

1.10%$2,200,001 to $3,200,000

1.00%$3,200,000 to $25,000,000

0.75%

The above fee schedule will apply to both discretionary and non-discretionary advisory accounts.
Management Fees will be charged each quarter in advance based on the total market value of the assets
in the client account (including net unrealized appreciation or depreciation of investments and cash,
cash equivalents and accrued interest) on the first day of the quarter. If a new client account isestablished during a quarter or a client makes an addition to its account during a quarter, theManagement Fee will be charged as of the effective date of the investment management agreement or
the date of the additional contribution based on the value of the assets as of the applicable date andwill be prorated for the number of days remaining in the quarter. Management Fees will be negotiablein the sole and absolute discretion of the Advisor.
For client assets managed by Sub-advisors, the Advisor receives no compensation directly from clientswith respect to those assets. Instead, the Advisor receives a portion of the fees charged by the Subadvisor and as disclosed to the client in a separate written agreement with the designated Sub-advisor.
The Advisor also reserves the right to reduce or waive our fees for employee or family accounts andcertain client accounts.

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
February 13, 2024
-3-

B.

Payment of Fees

With client authorization, the Advisor will automatically withdraw the Management Fee from theclient’s account held by an independent custodian. Typically, the custodian withdraws advisory
fees from the client’s account during the first month of each quarter based on the Advisors’
instruction. All clients will receive brokerage statements from the custodian no less frequently
than quarterly. The custodian statement will show the deduction of the Management Fee.
C.

Other Fees and Expenses

As part of our investment advisory services to you, we may invest, or recommend that you invest,
in mutual funds and exchange traded funds. The fees that you pay to our firm for investment
advisory services are separate and distinct from the fees and expenses charged by mutual funds or
exchange traded funds (described in each fund’s prospectus) to their shareholders. These fees will
generally include a management fee and other fund expenses. You will also incur transaction charges
and/or brokerage fees when purchasing or selling securities. These charges and fees are typically
imposed by the broker-dealer or custodian through whom your account transactions are executed.
We do not share in any portion of the brokerage fees/transaction charges imposed by the brokerdealer or custodian. To fully understand the total cost you will incur, you should review all the fees
charged by mutual funds, exchange traded funds, our firm, and others. For information on our
brokerage practices, please refer to the Brokerage Practices section of this Brochure.
All fees paid to the Advisor for investment advisory services are separate and distinct from the feesand expenses charged by mutual funds and ETF to their shareholders. These fees and expenses aredescribed in each mutual fund’s and ETF’s prospectus and may include a management fee,
distribution fee (i.e., Rule 12b-1 fee), sales charge and other fund expenses. A client could invest in
a mutual fund or an ETF directly, without the services of the Advisor. In that case, the client would
not receive the services provided by the Advisor which are intended, among other things, to assist
the client in determining which mutual fund(s) or ETF(s) are most appropriate to each client’s
financial condition and objectives. Accordingly, each client should review both the fees charged by
the mutual funds and the ETFs and the fees charged by the Advisor to fully understand the total
amount of fees paid by the client and to thereby evaluate the advisory services being provided.
If the Advisor invests its clients’ assets in mutual funds, the Advisor would not receive any 12b-1
fees from that mutual fund. Clients should also understand that while the Advisor does not receive
12b-1 fees, a 12b-1 fee may still be paid to a mutual fund distributor. These 12b-1 fees could
increase overall expenses to the client.
Please refer to Item 12—Brokerage Practices in this brochure for a discussion of Occidental’s brokeragepractices, including factors that we consider when selecting brokers and dealers for clienttransactions.
Clients with assets managed by Sub-advisors will incur fees payable directly to the Sub-advisor in
addition to fees payable to the Advisor. Fees charged by Sub-advisors will be established in a client’s
written agreement with the Advisor.
Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
February 13, 2024
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D.

Prepayment of Fees

Clients will be required to pay Management Fees to the Advisor quarterly in advance. Upon thetermination of a client account during a calendar quarter, the Management Fee will be prorated forthe days remaining in that calendar quarter and any prepaid, unearned fees will be refunded to therelevant client.

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
February 13, 2024
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Item 6

Performance-Based Fees

The Advisor currently does not currently charge performance-based fees (i.e., fees based on a shareof capital gains or capital appreciation of the assets of a client).

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
February 13, 2024
-6-

Item 7

Types of Clients

The Advisor’s clients will consist of individuals and institutions with separately managed accounts.
The Advisor will generally require a minimum of $500,000 of assets under management for aseparately managed account but may waive this minimum in its sole and absolute discretion. If theaccount size falls below the minimum requirement due to market fluctuations only, a client will not
be required to invest additional funds with the Advisor to meet the minimum account size.
Please refer to Item 12—Brokerage Practices in this brochure for a discussion of eligibility for enrollment
in the Institutional Intelligent Portfolios® platform offered by Schwab Performance Technologies.

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
February 13, 2024
-7-

Item 8

Methods of Analysis, Investment Strategies and Risk of Loss

A.

Methods of Analysis and Investment Strategies

Our investment strategies and advice may vary depending upon each client’s specific financial
situation. As such, we determine investments and allocations based upon your defined objectives, risk
tolerance, time horizon, financial horizon, financial information, liquidity needs, and other various
suitability factors. Your restrictions and guidelines may affect the composition of your portfolio.
Charting and Technical Analysis – Charting analysis involves the gathering and processing of price andvolume information for a particular security. This price and volume information is analyzed using
mathematical equations. The resulting data is then applied to graphing charts, which is used to predict
future price movements based on price patterns and trends. Technical Analysis involves studying past
price patterns and trends in the financial markets to predict the direction of both the overall market
and specific stocks. The risk of market timing based on technical analysis is that charts may notaccurately predict future price movements. Current prices of securities may reflect all information
known about the security and day to day changes in market prices of securities may follow random
patterns and may not be predictable with any reliable degree of accuracy.
Fundamental Analysis – Fundamental analysis involves analyzing individual companies and theirindustry groups, such as a company’s financial statements, details regarding the company’s productline, the experience, and expertise of the company’s management, and the outlook for the company’s
industry. The resulting data is used to measure the true value of the company’s stock compared to thecurrent market value. The risk of fundamental analysis is that information obtained may be incorrect
and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock’s
value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not
result in favorable performance.
Cyclical Analysis – Cyclical analysis is a type of technical analysis that involves evaluating recurring pricepatterns and trends based upon business cycles. Economic/business cycles may not be predictable
and may have many fluctuations between long term expansions and contractions. The lengths of
economic cycles may be difficult to predict with accuracy and therefore the risk of cyclical analysis is
the difficulty in predicting economic trends and consequently the changing value of securities thatwould be affected by these changing trends.
Long Term Purchases – securities purchased with the expectation that the value of those securities willgrow 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 pricefluctuations.
Margin Transactions – a securities transaction in which an investor borrows money to purchase asecurity, in which case the security serves as collateral on the loan.

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
February 13, 2024
-8-

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 delivera specified number of shares at a specified price at the expiration of the option regardless of themarket value of the security at expiration of the option. Buying an option gives you the right topurchase or sell a specified number of shares at a specified price until the date of expiration of theoption regardless of the market value of the security at expiration of the option.
B.

Material Risks (Including Significant, or Unusual Risks) Relating toInvestment Strategies

Risk of Loss – Investing in securities involves risk of loss that you should be prepared to bear. We
do not represent or guarantee that our services or methods of analysis can or will predict future
results, successfully identify market tops or bottoms, or insulate clients from losses due to market
corrections or declines. We cannot offer any guarantees or promises that your financial goals andobjectives will be met. Past performance is in no way an indication of future performance.
Use of Sub-advisors – As described above, the Advisor may select certain Sub-advisors to manage aportion of clients’ assets. In these situations, the Advisor continues to conduct ongoing due
diligence of such Sub-advisors, but such recommendations rely to a great extent on the Subadvisors’ ability to successfully implement their investment strategies.
C.

Risks Associated with Types of Securities that are Primarily Recommended

Equity Securities – There are numerous ways of measuring the risk of equity securities (also known
simply as “equities” or “stock”). In very broad terms, the value of a stock depends on the financial
health of the company issuing it. However, stock prices can be affected by many other factors
including, but not limited to: the class of stock (for example, preferred or common); the health ofthe market sector of the issuing company; and, the overall health of the economy. In general, larger,
more well-established companies (“large cap”) tend to be safer than smaller start-up companies(“small cap”) but the mere size of an issuer is not, by itself, an indicator of the safety of theinvestment.
Mutual funds – Are professionally managed collective investment systems that pool money frommany investors and invest in stocks, bonds, short-term money market instruments, other mutual
funds, other securities or any combination thereof. A mutual fund will have a manager that trades
the fund's investments in accordance with the fund's investment objective. While mutual funds
generally provide diversification, risks can be significantly increased if the fund is concentrated in aparticular sector of the market, primarily invests in small cap or speculative companies, uses leverage(i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e.,equities) rather than balancing the fund with different types of securities. The returns on mutual
funds can be reduced by the costs to manage the funds. Also, while some mutual funds are “noload” and charge no fee to buy into, or sell out of, the fund, other types of mutual funds do charge
such fees which can also reduce returns.
Exchange-Traded Funds (ETFs) – An ETF is a type of investment company (usually, an open-end
fund or unit investment trust) containing a basket of stocks. Typically, the objective of an ETF is
to achieve returns similar to a particular market index, including sector indexes. An ETF is similar
Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
February 13, 2024-9-

to an index fund in that it will primarily invest insecurities of companies that are included in a
selected market. Unlike traditional mutual funds, which can only be redeemed at the end of a trading
day, ETFs trade throughout the day on an exchange. Like stock mutual funds, the prices of theunderlying securities and the overall market may affect ETF prices. Similarly, factors affecting aparticular industry segment may affect ETF prices that track that particular sector.
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 delivera specified number of shares at a specified price at the expiration of the option regardless of themarket value of the security at expiration of the option. The seller of an uncovered call or put option
assumes the risk of increases or decreases, respectively, in the market price of the underlying option
with respect to the exercise price 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. The buyer of a call or put
option assumes the risk of losing the entire investment in the price of the option.

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
February 13, 2024
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Item 9

Disciplinary Information

Investment advisors are required to disclose any legal or disciplinary events that are material to yourevaluation of us. We have no information of this type to report.

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
February 13, 2024
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Item 10

Other Financial Industry Activities and Affiliations

The Advisor has no affiliation with other financial industry firms with common ownership.

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
February 13, 2024
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Item 11

Code of Ethics, Participation or Interest in Client Transactions andPersonal TradingA.

Code of Ethics

Occidental Asset Management, LLC believes that we owe clients the highest level of trust and fairdealing. As part of our fiduciary duty, our goal is to protect your interests and to demonstrate ourcommitment to our fiduciary duties. Occidental’s personnel are required to conduct themselveswith integrity at all times and follow the principles and policies detailed in our Code of Ethics.
Occidental’s Code of Ethics attempts to address specific conflicts of interest that either we haveidentified or that could likely arise. Occidental’s personnel are required to follow clear guidelines
from the Code of Ethics, which require compliance with fiduciary duties, applicable securities laws,
maintaining confidentiality of client nonpublic personal information, insider trading policies, andplacing client interests first. Additionally, individuals who make securities recommendations toclients, or who have access to nonpublic information regarding any client’s purchase or sale ofsecurities, are subject to personal trading policies governed by the Code of Ethics (see below).
Occidental will provide a complete copy of the Code of Ethics to any client or prospective client
upon request. Clients or prospective clients may obtain a copy of the Code by contacting Nathan
H. Walsh (Chief Compliance Officer) by telephone at (650) 344-1600 or by email at
nwhatton@occamllc.net.
B.

Personal Trading Policies

The Advisor, or its associated persons may invest in the same securities that the Advisor
recommends to clients. This could be viewed as presenting a potential conflict of interest.
The Advisor recognizes that the personal investment transactions of its associated persons demand
the application of a high code of ethics and require that all such transactions be carried out in a waythat does not endanger the interest of any client. At the same time, the Advisor believes that if
investment goals are similar for clients and for the Advisor’s associated persons, it is logical that
there be a common ownership of some securities. However, it is the express policy of the Advisor
that no associated person may purchase or sell any security prior to a transaction being implemented
for a client account, thereby preventing that associated person from benefiting from transactions
placed on behalf of the Advisor’s advisory clients. In order to address conflicts of interest, theAdvisor has adopted procedures with respect to transactions effected by its associated persons fortheir personal accounts.
From time to time, trading by the Advisor, its associated persons (and certain of their relatives) inparticular securities may be restricted in recognition of impending investment decisions on behalfof clients. If transaction orders for a client and the Advisor (and/or its associated persons andcertain of their relatives) are not aggregated, the transaction orders for the Advisor (and/or its
associated persons and certain of their relatives) will be the last orders filled.

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
February 13, 2024
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Item 12

Brokerage Practices

A.

Factors Considered in Selecting or Recommending Broker-Dealers for Client
Transactions

The Advisor will generally seek “best execution” on an overall basis in light of the circumstances
involved in transactions. The Advisor considers a number of factors in selecting a broker-dealer to
execute transactions (or series of transactions) and determining the reasonableness of the brokerdealer’s compensation. Such factors include net price, reputation, financial strength and stability,
efficiency of execution and error resolution, and offering to the Advisor on-line access tocomputerized data regarding a client’s accounts. In selecting a broker-dealer to execute transactions(or series of transactions) and determining the reasonableness of the broker-dealer’s compensation,
the Advisor need not solicit competitive bids and does not have an obligation to seek the lowest
available commission cost. It is not the Advisor’s practice to negotiate “execution only” commission
rates, thus a client may be deemed to be paying for research, brokerage or other services provided bya broker-dealer which are included in the commission rate. The Advisor does not intend to generate“soft dollars” in connection with client securities transactions.
The Advisor has an arrangement with Charles Schwab under which Schwab will reimburse clienttransfer of account exit fees for certain accounts placed at Schwab and the Advisor receives benefits
to be used for technology for servicing its accounts. The Advisor’s recommendation to place certain
client accounts at Schwab may be based in part on the benefit to the Advisor and the availability ofsome of the services and benefits provided and not solely on the nature, cost or quality of custodyand brokerage services provided by Schwab, which may create a potential conflict of interest. The
Advisor’s arrangement with Schwab is not dependent on the Advisor maintaining any particularlevel of client assets at Schwab.
1.

Directed Brokerage

The Advisor generally asks its clients to direct the Advisor to appoint Charles Schwab to serve as
custodian for the Advisor’s clients’ accounts. With respect to advisory client accounts maintained ata particular custodian, the Advisor, to the extent applicable, will direct all securities transactions
effected for such accounts through such custodian.

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
February 13, 2024
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When a client directs the Advisor to use a specified broker-dealer (such as Charles Schwab orotherwise) to execute all or a portion of the client’s securities transactions, the Advisor treats theclient direction as a decision by the client to retain, to the extent of the direction, the discretion theAdvisor would otherwise have in selecting broker-dealers to effect transactions and in negotiating
commissions for the client’s account. Although the Advisor attempts to effect such transactions ina manner consistent with its policy of seeking best execution, there may be occasions where it isunable to do so, in which case the Advisor will continue to comply with the client’s instructions.
Transactions in the same security for accounts that have directed the use of the same broker will beaggregated. When the directed broker-dealer is unable to execute a trade, the Advisor will selectbroker-dealers other than the directed broker-dealer to effect client securities transactions. A client
who directs the Advisor to use a particular broker-dealer to effect transactions should consider
whether such direction may result in certain costs or disadvantages to the client. Such costs may
include higher brokerage commissions (because the Advisor may not be able to aggregate orders to
reduce transaction costs), less favorable execution of transactions, and the potential of exclusionfrom the client's portfolio of certain foreign ordinary shares and/or small capitalization or illiquid
securities due to the inability of the particular broker-dealer in question to provide adequate priceand execution of all types of securities transactions. By permitting a client to direct the Advisor to
execute the client’s trades through a specified broker-dealer, the Advisor will make no attempt tonegotiate commissions on behalf of the client and, as a result, in some transactions such clients may
pay materially disparate commissions depending on their commission arrangement with thespecified broker-dealer and upon other factors such as number of shares, round and odd lots andthe market for the security. The commissions charged to clients that direct the Advisor to executethe client’s trades through a specified broker-dealer may in some transactions be materially different
that those of clients who do not direct the execution of their trades. Clients that direct the Advisor
to execute trades through a specified broker-dealer may also lose the ability to negotiate volumecommission discounts on batched transactions that may otherwise be available to other clients of
the Advisor, and this may cost such clients more money. Not all investment advisors require clientsto direct the advisor to execute client trades with a specific broker-dealer.
If the Advisor believes, in its exclusive discretion, that it cannot satisfy its fiduciary duty of best
execution by executing a transaction for a client account with a broker designated by the client, theAdvisor may execute that transaction with a different broker-dealer. Any client providing
instructions to the Advisor regarding direction of brokerage transactions must notify the Advisor
in writing if the client desires the Advisor to cease executing transactions with or through any suchbroker-dealer.
2.

Institutional Intelligent Portfolios® Accounts – Schwab Performance Technologies (“SPT”)
a.

Advisory Business (“SPT”)

For certain account offer an automated investment program (the “Program”) through whichclients are invested in a range of investment strategies we have constructed and manage,
each consisting of a portfolio of exchange-traded funds and mutual funds (“Funds”) and acash allocation. The client may instruct us to exclude up to three Funds from their portfolio.
The client’s portfolio is held in a brokerage account opened by the client at Charles Schwab& Co., Inc. (“CS&Co.”). We use the Institutional Intelligent Portfolios® platform
Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
February 13, 2024
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(“Platform”), offered by Schwab Performance Technologies (“SPT”), a software provider
to independent investment advisors and an affiliate of CS&Co., to operate the Program. We
are independent of and not owned by, affiliated with, or sponsored or supervised by SPT,CS&Co., or their affiliates (together, “Schwab”). We, and not Schwab, are the client’s
investment advisor and primary point of contact with respect to the Program. We are solely
responsible, and Schwab is not responsible, for determining the appropriateness of theProgram for the client, choosing a suitable investment strategy and portfolio for the client’s
investment needs and goals, and managing that portfolio on an ongoing basis. We havecontracted with SPT to provide us with the Platform, which consists of technology andrelated trading and account management services for the Program. The Platform enables us
to make the Program available to clients online and includes a system that automates certain
key parts of our investment process (the “System”). The System includes an online
questionnaire that can help us determine the client’s investment objectives and risk tolerance
and select an appropriate investment strategy and portfolio. Clients should note that, if we
use the online questionnaire, we will recommend a portfolio via the System in response to
the client’s answers to the online questionnaire The client may then indicate an interest in a
portfolio that is one level less or more conservative or aggressive than the recommended
portfolio, but we then make the final decision and select a portfolio based on all theinformation we have about the client. The System also includes an automated investment
engine through which we manage the client’s portfolio on an ongoing basis throughautomatic rebalancing and tax-loss harvesting (if the client is eligible and elects).
We charge clients a fee for our services with respect to the Program as described below
under Fees and Compensation (“SPT”). Our fees are not set or supervised by Schwab. Clients
do not pay brokerage commissions or any other fees to CS&Co. as part of the Program.
Schwab does receive other revenues, including (i) the profit earned by Charles Schwab Bank,
SSB, a Schwab affiliate, on the allocation to the Schwab Intelligent Portfolios Sweep
Program described in the Schwab Intelligent Portfolios Sweep Program DisclosureStatement; (ii) investment advisory and/or administrative service fees (or unitary fees)
received by Charles Schwab Investment Management, Inc., a Schwab affiliate, from Schwab
ETFs™ Schwab Funds® and Laudus Funds® that we select to buy and hold in the client’s
brokerage account; (iii) fees received by Schwab from mutual funds in the Schwab Mutual
Fund Marketplace® (including certain Schwab Funds and Laudus Funds) in the client’s
brokerage account for services Schwab provides; and (iv) remuneration Schwab receives
from the market centers where it routes ETF trade orders for execution.
b.

Fees and Compensation (“SPT”)

As described in Advisory Business (“SPT”), clients do not pay fees to SPT or brokeragecommissions or other fees to CS&Co. as part of the Program. Schwab does receive otherrevenues, including (i) the profit earned by Charles Schwab Bank, SSB, a Schwab affiliate,on the allocation to the Schwab Intelligent Portfolios Sweep Program described in the
Schwab Intelligent Portfolios Sweep Program Disclosure Statement; (ii) investment advisory
and/or administrative service fees (or unitary fees) received by Charles Schwab Investment
Management, Inc., a Schwab affiliate, from Schwab ETFs™ Schwab Funds® and Laudus
Funds® that we select to buy and hold in the client’s brokerage account; (iii) fees received
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by Schwab from mutual funds in the Schwab Mutual Fund Marketplace® (including certain
Schwab Funds and Laudus Funds) in the client’s brokerage account for services Schwab
provides; and (iv) remuneration Schwab receives from the market centers where it routes
ETF trade orders for execution. Brokerage arrangements are further described below inBrokerage Practices (“SPT”).
c.

Types of Clients (“SPT”)

Clients eligible to enroll in the Program include individuals, IRAs, and revocable living
trusts. Clients that are organizations (such as corporations and partnerships) or government
entities, and clients that are subject to the Employee Retirement Income Security Act of1974, are not eligible for the Program. The minimum investment required to open or
convert an account in the Program is $5,000. The minimum account balance to enroll in the
tax-loss harvesting feature is $50,000.
d.

Brokerage Practices (“SPT”)

Client accounts enrolled in the Program are maintained at, and receive the brokerage
services of, CS&Co., a broker-dealer registered with the Securities and Exchange
Commission and a member of FINRA and SIPC. While clients are required to use
CS&Co. as custodian/broker to enroll in the Program, the client decides whether to do so
and opens its account with CS&Co. by entering into a brokerage account agreement
directly with CS&Co. We do not open the account for the client. If the client does notwish to place his or her assets with CS&Co., then we cannot manage the client’s accountthrough the Program. CS&Co. may aggregate purchase and sale orders for Funds acrossaccounts enrolled in the Program, including both accounts for our clients and accounts forclients of other independent investment advisory firms using the Platform.
Schwab Advisor Services™ is Schwab’s business serving independent investment advisory
firms like us. Through Schwab Advisor Services, CS&Co. provides us and our clients,
both those enrolled in the Program and our clients not enrolled in the Program, withaccess to its institutional brokerage services— trading, custody, reporting, and related
services—many of which are not typically available to CS&Co. retail customers. However,certain retail customers may be able to get institutional brokerage services from Schwab
without going through us. CS&Co. also makes available various support services. Some ofthose services help us manage or administer our clients’ accounts, while others help us
manage and grow our business. CS&Co.’s support services described below are generally
available on an unsolicited basis (we don’t have to request them) and at no charge to us.
The availability to us of CS&Co.’s products and services is not based on us giving
particular investment advice, such as buying particular securities for our clients.
CS&Co.’s institutional brokerage services include access to a broad range of investment
products, execution of securities transactions, and custody of client assets. The investment
products available through Schwab include some to which we might not otherwise haveaccess or that would require a significantly higher minimum initial investment by ourclients. CS&Co.’s services described in this paragraph generally benefit the client and theclient’s account.
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CS&Co. also makes available to us other products and services that benefit us but do notdirectly benefit the client or its account. These products and services assist us in managing
and administering our clients’ accounts and operating our firm. They include investment
research, both Schwab’s own and that of third parties. We use this research to service allor some substantial number of our clients’ accounts, including accounts not maintained at
CS&Co. In addition to investment research,
CS&Co. also makes available software and other technology that:• provide access to client account data (such as duplicate trade confirmations andaccount statements);• facilitate trade execution and allocate aggregated trade orders for multiple client
accounts;• provide pricing and other market data;• facilitate payment of our fees from our clients’ accounts; and• assist with back-office functions, recordkeeping, and client reporting.
CS&Co. also offers other services intended to help us manage and further develop ourbusiness enterprise. These services include:• educational conferences and events;• technology and business consulting;• Consulting on legal and related compliance needs;• publications and conferences on practice management and business succession;and• access to employee benefits providers, human capital consultants, and insurance
providers.
CS&Co. provides some of these services itself. In other cases, it will arrange for thirdparty vendors to provide the services to us. CS&Co. may also discount or waive its fees
for some of these services or pays all or a part of a third party’s fees.
The availability of services from CS&Co. benefits us because we do not have to produce orpurchase them. We don’t have to pay for these services, and they are not contingent upon us
committing any specific amount of business to CS&Co. in trading commissions or assets incustody. With respect to the Program, as described above in this Item under Advisory

Business (“SPT”) we do not pay fees to SPT for the Platform. The fact that we receive thesebenefits from Schwab is an incentive for us to recommend the use of Schwab rather thanmaking such a decision based exclusively on your interest in receiving the best value in custody
services and the most favorable execution of transactions. This is a conflict of interest. We believe,
however, that taken in the aggregate our recommendation of CS&Co. as custodian and broker
is in the best interests of our clients. It is primarily supported by the scope, quality, and price of
CS&Co.’s services and not Schwab’s services that benefit only us. We have adopted policies

and procedures designed to ensure that our use of Schwab’s services is appropriate foreach of our clients.
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e.

Custody (“SPT”)

Under government regulations, we are deemed to have custody of a client’s assets if theclient authorizes us to instruct CS&Co. to deduct our advisory fees directly from theclient’s account. This is the case for accounts in the Program. CS&Co. maintains actual
custody of clients’ assets. Clients receive account statements directly from CS&Co. at least
quarterly. They will be sent to the email or postal mailing address the client provides to
CS&Co. Clients should carefully review those statements promptly when received. We
also urge clients to compare CS&Co.’s account statements to the periodic reports clients
receive from us.
3.

Participant Account Management (Discretionary)

We use a third-party platform to facilitate management of held-away assets (such as defined
contribution plan participant accounts) with discretion. The platform allows us to avoid being
considered to have custody of those client funds since we do not have direct access to client log-in
credentials to affect trades. We are not affiliated with the platform in any way and receive nocompensation from them for using their platform. The platform allows clients to connect client
account(s) directly. Once client account(s) is/are connected to the platform, we review current
account allocations and, when deemed necessary, we rebalance the account(s) in light of theclient’s investment goals and risk tolerance, as well as current economic and market trends. The
goal is to improve account performance over time, minimize loss during difficult markets, andmanage internal fees that harm account performance. Client account(s) will be reviewed at least
quarterly.
B.

Block Allocation

Discretionary Accounts-Generally for discretionary accounts, we combine multiple orders forshares of the same securities purchased for advisory accounts we manage (this practice is commonlyreferred to as “block trading”). We will then distribute a portion of the shares to participating
accounts in a fair and equitable manner. The distribution of the shares purchased is typically
proportionate to the size of the account, but it is not based on account performance or the amountor structure of management fees. Subject to our discretion, regarding particular circumstances andmarket conditions, when we combine orders, each participating account pays an average price pershare for all transactions and pays a proportionate share of all transaction costs. Accounts owned
by our firm or persons associated with our firm may participate in block trading with your accounts;
however, they will not be given preferential treatment.
Non-discretionary Accounts-We do not combine multiple orders for shares of the same securities
purchased for non-discretionary accounts. Accordingly, non-discretionary accounts may pay
different costs than discretionary accounts pay. If you enter into non-discretionary arrangementswith our firm, we may not be able to buy and sell the same quantities of securities for you and you
may pay higher commissions, fees, and/or transaction costs than clients who enter into
discretionary arrangements with our firm.

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
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Item 13

Review of Accounts

A.

Frequency and Nature of Review

The investment adviser representative assigned to your managed account and/or a designatedportfolio manager will monitor your accounts on a continuous basis and re-balance your portfolio(s)as market conditions and your circumstances change. In addition, we will conduct internal accountreviews at least semi-annually to ensure that the advisory services provided to you are consistent
with your stated investment needs and objectives. Additional reviews may be conducted based on
various circumstances, including, but not limited to:-changes in your financial circumstances;-contributions and withdrawals;-year-end tax planning;-market moving events;-security specific events; and/or,-changes in your risk/return objectives.
B.

Factors Prompting a Non-Periodic Review of Accounts

Significant market events affecting the prices of one or more securities in client accounts, changes
in the wealth management or financial planning goals, investment objectives or guidelines of aparticular client, or specific arrangements with particular clients may trigger reviews of client
accounts on other than a periodic basis.
C.

Content and Frequency of Regular Account Report

Each client that is a separate account will receive quarterly performance and account statements andtrade confirmations from the qualified custodian of the client’s account. Such reports may bedelivered electronically to the client in accordance with the client’s agreement with the Advisor.

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
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Item 14

Client Referrals and Other Compensation

The Advisor engages independent solicitors to provide client referrals. If a client is referred to us
by a solicitor, this practice is disclosed to the client in writing by the solicitor and the Advisor pays
the solicitor out of its own funds—specifically, the Advisor generally pays the solicitor a portion of
the advisory fees earned for managing the capital of the client or investor that was referred.
The use of solicitors is strictly regulated under applicable federal and state law. The Advisor’s policy
is to fully comply with the requirements of Rule 206(4)-1, under the Investment Advisers Act of1940, as amended, and similar state rules, as applicable.
Charles Schwab
We receive an economic benefit from Schwab in the form of financial benefits it makes available to
us to be used for technology for servicing of accounts and other independent investment advisorsthat have their clients maintain accounts at Schwab. These arrangements, how they benefit us, andthe related conflicts of interest are described above (see Item 12 – Brokerage Practices). The
availability to us of Schwab’s benefits, products and services is not based on us giving particularinvestment advice, such as buying particular securities for our clients.
In addition, we receive client referrals from Schwab through our participation in Schwab Advisor
Network® (“the Service”). The Service is designed to help investors find an independent
investment advisor. Schwab is a broker-dealer independent of and unaffiliated with us. Schwab does
not supervise us and has no responsibility for our management of clients’ portfolios or our otheradvice or services. We pay Schwab fees to receive client referrals through the Service. Ourparticipation in the Service raises potential conflicts of interest described below.
We pay Schwab a Participation Fee on all referred clients’ accounts that are maintained in custodyat Schwab and a separate one-time Transfer Fee on all accounts that are transferred to anothercustodian. The Transfer Fee creates a conflict of interest that encourages us to recommend thatclient accounts be held in custody at Schwab. The Participation Fee paid by us is a percentage ofthe value of the assets in the client’s account. We pay Schwab the Participation Fee for so long as
the referred client’s account remains in custody at Schwab. The Participation Fee and any Transfer
fee is paid by us and not by the client. We have agreed not to charge clients referred through theService fees or costs greater than the fees or costs we charge clients with similar portfolios who
were not referred through the Service.
The Participation and Transfer Fees are based on assets in accounts of our clients who were referredby Schwab and those referred clients’ family members living in the same household. Thus, we will
have incentives to recommend that client accounts and household members of clients referredthrough the Service maintain custody of their accounts at Schwab.
Charles Schwab Institutional Intelligent Portfolios®
We use Charles Schwab Institutional Intelligent Portfolios’ platform to manage certain of ourclients’ accounts. We receive a non-economic benefit from Charles Schwab Institutional Intelligent
Portfolios in the form of the support products and services it makes available to us and otherOccidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
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independent investment advisors whose clients maintain their accounts at CS&Co. These products
and services, how they benefit us, and the related conflicts of interest are described above (see Item
12—Brokerage Practices). The availability to us of Charles Schwab Institutional Intelligent Portfolios’
products and services is not based on us giving particular investment advice, such as buying
particular securities for our clients.

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
February 13, 2024
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Item 15

Custody

Custody means holding, directly or indirectly, client funds or securities or having any authority toobtain possession of them. The SEC has rules and regulations which are designed to safeguardclient assets. The Advisor is deemed to have custody of client assets if clients authorize thededuction of advisory fees directly from client accounts. The Advisor follows the rules of the SEC,
which require us to follow the following procedures:
Maintain Accounts with Qualified Custodians: The Adviser has all client funds and securities, except
shares of mutual funds, maintained by a “qualified custodian” (i.e., a bank, registered broker-dealer)in separate accounts for each client. Although the Advisor may recommend a custodian, andgenerally does (see Item 12—Brokerage Practices), the client may choose its own. Shares of mutual funds
are held by the mutual fund’s transfer agent.
Periodic Account Statements: The Advisor requires each custodian to furnish account statements toour clients no less frequently than quarterly. The Advisor also requires that this statement, at aminimum, identifies the amount of funds and of each security in the account at the end of thequarter and all transactions in the account during the quarter. The Advisor urges clients to compare
the custodian’s account statements to the periodic statements clients will receive from the Advisor.

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
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Item 16

Investment Discretion

The Advisor will provide investment advisory services on a discretionary basis to clients. Please see
the description in “Advisory Business” (Item 4) for a description of limitations clients may place on
the Advisor’s discretionary authority.
Prior to assuming full discretion in managing a client’s assets, the Advisor will enter into an
investment management agreement or other agreement that sets forth the scope of the Advisor’s
discretion.
In addition, to the extent a portion of a client’s assets will be managed by a Sub-advisor selected by
the Advisor, the client will enter into an agreement with the Sub-advisor that sets forth the scopeof the Sub-advisor’s discretion.
Unless otherwise instructed or directed by a discretionary client, the Advisor will have the authority
to determine (i) the securities to be purchased and sold for the client account (subject to restrictions
on its activities set forth in the applicable investment management agreement and any written
investment guidelines) and (ii) the amount of securities to be purchased or sold for the client
account. Because of the differences in client investment objectives and strategies, risk tolerances,
tax status and other criteria, there may be differences among clients in invested positions andsecurities held.
All accounts are managed using the investment strategy described in the “Methods of Analysis,
Investment Strategies and Risk of Loss” section (Item 8). We do not allow clients to limit
investments we make that fall within the parameters of the investment strategy described above.

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Item 17

Voting Client Securities

Presently, the Advisor does not vote proxies for any client accounts. The client retains the rightand responsibility to vote proxies. Clients will receive their proxies or other solicitations directlyfrom their custodian.

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Item 18

Financial Information

The Advisor is required in this section to provide you with certain financial information or
disclosures about our financial condition. Neither the Advisor nor its associated persons has any
financial commitment that is reasonably likely to impair the Advisor’s ability to meet contractual
commitments to its clients, and neither the Advisor nor its associated persons has been the subjectof bankruptcy proceedings.

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Privacy Policy

We view protecting your private information as a top priority. Pursuant to applicable privacy
requirements, we have instituted policies and procedures to ensure that we keep your personal
information private and secure.
We do not disclose any nonpublic personal information about you to any nonaffiliated third parties,
except as permitted by law. In the course of servicing your account we may share some information
with our service providers, such as transfer agents, custodians, broker-dealers, accountants,
consultants, and attorneys.
We restrict internal access to nonpublic personal information about you to employees who needthat information in order to provide products or services to you. We maintain physical andprocedural safeguards that comply with regulatory standards to guard your nonpublic personal
information and to ensure our integrity and confidentiality. We will not sell information about youor your accounts to anyone. We do not share your information unless it is required to process atransaction, at your request, or required by law.
You will receive a copy of our privacy notice prior to or at the time you sign an advisory agreementwith our firm. Thereafter, we will deliver a copy of the current privacy policy notice to you on anannual basis. Please contact Nathan Hatton Walsh/Chief Compliance Officer at 650-344-1600, if
you have any questions regarding this policy.

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
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February 13, 2024
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Form ADV: Part 2B Supplement

Item 1

Cover Page

A. Charles Cattano III
Managing Principal
Occidental Asset Management, LLC
also doing business as

OCCAM
YMW Advisors
301 California Drive #9
Burlingame, CA 94010
www.occamllc.net

Telephone:
Facsimile:(650) 344-1600(650) 745-7347

February 13, 2024

This Brochure Supplement provides information about A. Charles Cattano III that supplements the Occidental
Asset Management, LLC Brochure. You should have received a copy of that Brochure. Please contact us at theabove telephone number if you did not receive our Brochure or if you have any questions about the content of
this supplement.
Additional information about A. Charles Cattano III is also available on the SEC’s website atwww.adviserinfo.sec.gov.

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
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Item 2

Educational Background and Business Experience

A. Charles Cattano, III was born in 1967. He received a BA in English from University of California at Berkeley
in 1989 and a MBA in Business Administration, Finance Emphasis from St. Mary’s College of California in
1999.
Mr. Cattano has been the Managing Principal of Occidental Asset Management, LLC since the firm’s inceptionin July 2013. He was previously the President of ACC Investment Management, Inc. (“ACCIMI”) from its
founding in January 2001 until August 2013. Mr. Cattano’s principal duties include portfolio management anddiversification services for high net worth individuals.

Item 3

Disciplinary Information

Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary
actions that would be material to your evaluation of each investment advisor representative providing
investment advice to you. There is no information of this type to report.

Item 4

Other Business Activities

Mr. Cattano is a principal in SK Conservation LLC, a company organized to create a mitigation/conservationbank. He devotes less than five hours per month to this activity. Mr. Cattano is not involved in any otherbusiness activities material to his relationship with advisory clients.

Item 5Additional Compensation

Mr. Cattano does not receive any economic benefit from any non-client for providing advisory services.

Item 6

Supervision

Nathan H. Walsh, Chief Compliance Officer and Managing Principal of Occidental Asset Management, LLC,
is responsible for the supervision of Mr. Cattano. His telephone number is (650) 344-1600.

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
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Form ADV: Part 2B Supplement

Item 1

Cover Page

Nathan H. Walsh
Chief Compliance Officer, Managing Principal
Occidental Asset Management, LLC
also doing business as

OCCAM
YMW Advisors
301 California Drive #9
Burlingame, CA 94010
www.occamllc.net

Telephone:
Facsimile:(650) 344-1600(650) 745-7347

February 13, 2024

This Brochure Supplement provides information about Nathan H. Walsh that supplements the Occidental
Asset Management, LLC Brochure. You should have received a copy of that Brochure. Please contact us at theabove telephone number if you did not receive our Brochure or if you have any questions about the content of
this supplement.
Additional information about Nathan H. Walsh is also available on the SEC’s website atwww.adviserinfo.sec.gov.

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
February 13, 2024
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Item 2

Educational Background and Business Experience

Nathan H. Walsh was born in 1974. He received a BA in History from Rhodes College in 1997.
Mr. Walsh has been the Chief Compliance Officer and Managing Principal of Occidental Asset Management,
LLC since the firm’s inception in July 2013. From January to August 2013, he was Managing Director of ACC
Investment Management, Inc. (“ACCIMI”). From August to December 2012 he was Managing Director of
Personal Financial Consultants, Inc., an investment advisor. From February 1999 to August 2012 he was apartner with Polaris Equity Management, Inc., an investment advisor. Mr. Walsh has also served as a brokerdealer representative with Round Hill Securities, Inc. from October 2001 to October 2004 and with Merrill
Lynch from June 1997 to February 1999.
Mr. Walsh’s principal duties include portfolio management and diversification services for high net worth
individuals and other clients.

Item 3

Disciplinary Information

Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary
actions that would be material to your evaluation of each investment advisor representative providing
investment advice to you. There is no information of this type to report.

Item 4

Other Business Activities

Mr. Walsh is not involved in any other business activities material to his relationship with advisory clients.

Item 5Additional Compensation

Mr. Walsh does not receive any economic benefit from any non-client for providing advisory services.

Item 6

Supervision

A. Charles Cattano III, Managing Principal of Occidental Asset Management, LLC, is responsible for thesupervision of Mr. Walsh. His telephone number is (650) 344-1600.

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
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Form ADV: Part 2B Supplement

Item 1

Cover Page

Dr. Bradley T. Klontz
Managing Principal
Occidental Asset Management, LLC
also doing business as

OCCAM
YMW Advisors
301 California Drive #9
Burlingame, CA 94010
www.occamllc.net

Telephone:
Facsimile:(650) 344-1600(650) 745-7347

February 13, 2024

This Brochure Supplement provides information about Dr. Bradley T. Klontz that supplements the Occidental
Asset Management, LLC Brochure. You should have received a copy of that Brochure. Please contact us at theabove telephone number if you did not receive our Brochure or if you have any questions about the content of
this supplement.
Additional information about Dr. Bradley T. Klontz is also available on the SEC’s website atwww.adviserinfo.sec.gov.

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
February 13, 2024
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Item 2

Educational Background and Business Experience

Dr. Bradley T. Klontz was born in 1971. He received a Bachelor of Science in Psychology from Olivet Nazarene
University in 1993, a Masters of Science in Counseling and Human Resources Development from South Dakota
State University in 1995, a Doctorate in Clinical Psychology from Wright State University in 1999, and a
Graduate Certificate in Personal Financial Planning from Kansas State University in 2011. From October 2011
to October 2013, Dr. Klontz was a Planner for Personal Financial Consultants, Inc. Since October 2000, he
has been the President of Coastal Clinics, Inc., which provides psychological services in Hawaii. Since 2010 hehas been an Associate Professor in Personal Financial Planning at Kansas State University, teaching courses infinancial planning, the psychology of financial planning, and behavioral finance. Since 2014, Dr. Klontz has
been the co-founder of the Financial Psychology Institute™, which conducts research and trains financial
advisors in financial psychology.

Item 3

Disciplinary Information

Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary
actions that would be material to your evaluation of each investment advisor representative providing
investment advice to you. There is no information of this type to report.

Item 4

Other Business Activities

Since 2000, Dr. Klontz has been the President of Coastal Clinics, Inc., which provides a range of psychological,
educational, and related services including: research, coaching, consulting, psychoeducation through books,
educational videos, courses, speeches, and related products, professional training, financial psychology
assessments, and spokesperson work for brands and media outlets.
Since 2014, Dr. Klontz has been a Managing Member of the Financial Psychology Institute, LLC, which trains
and certifies financial professionals in the areas of financial psychology and behavioral finance.

Dr. Klontz is also an Associate Professor of Practice, in the Department of Economics and Financeat Creighton University, Heider School of Business, teaching classes on financial psychology andbehavioral finance.
Item 5Additional Compensation

Dr. Klontz does not receive any economic benefit from any non-client for providing advisory services.

Item 6

Supervision

Nathan H. Walsh, Chief Compliance Officer and Managing Principal of Occidental Asset Management, LLC,
is responsible for the supervision of Dr. Klontz. His telephone number is (650) 344-1600.

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
February 13, 2024-2-

Form ADV: Part 2B Supplement

Item 1

Cover Page

John Wilbourne
Managing Partner
Occidental Asset Management, LLC
also doing business as

OCCAM
YMW Advisors
301 California Drive #9
Burlingame, CA 94010
www.occamllc.net

Telephone:
Facsimile:(650) 344-1600(650) 745-7347

February 13, 2024

This Brochure Supplement provides information about John Wilbourne that supplements the Occidental AssetManagement, LLC Brochure. You should have received a copy of that Brochure. Please contact us at the above
telephone number if you did not receive our Brochure or if you have any questions about the content of this
supplement.
Additional information about
www.adviserinfo.sec.gov.

John

Wilbourne isalsoavailable on

the SEC’s

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
February 13, 2024-1-

website at

Item 2

Educational Background and Business Experience

John Wilbourne was born in 1967. He received a B.A. in Economics from the University of Washington in
1990.
Mr. Wilbourne has been a Managing Partner of Occidental Asset Management, LLC since May 2016. Mr.
Wilbourne has previously served as a financial advisor of Private Advisor Group, LLC from January 2014 to
May 2016, of Washington Wealth Management from November 2012 to January 2014, and a financial
consultant of Wells Fargo Investments, LLC from July 2004 to January 2011. Mr. Wilbourne has also served asa broker-dealer representative of Overlake Partners from January 2016 to May 2016, of LPL Financial LLC
from November 2012 to May 2016, and of Wells Fargo Advisors LLC from January 2011 to November 2012.
Mr. Wilbourne’s principal duties include portfolio management and diversification services for high net worth
individuals and other clients.

Item 3

Disciplinary Information

Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary
actions that would be material to your evaluation of each investment advisor representative providing
investment advice to you. There is no information of this type to report.

Item 4

Other Business Activities

Mr. Wilbourne is not involved in any other business activities material to his relationship with advisory clients.

Item 5Additional Compensation

Mr. Wilbourne does not receive any economic benefit from any non-client for providing advisory services.

Item 6

Supervision

Nathan H. Walsh, Chief Compliance Officer and Managing Principal of Occidental Asset Management, LLC,
is responsible for the supervision of Mr. Wilbourne. His telephone number is (650) 344-1600.

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
February 13, 2024-2-

Form ADV: Part 2B Supplement

Item 1

Cover Page

Erin HadleyManaging Partner
Occidental Asset Management, LLC
also doing business as

OCCAM
YMW Advisors
301 California Drive #9
Burlingame, CA 94010
www.occamllc.net

Telephone:
Facsimile:(650) 344-1600(650) 745-7347

February 13, 2024

This Brochure Supplement provides information about Erin Hadley that supplements the Occidental AssetManagement, LLC Brochure. You should have received a copy of that Brochure. Please contact us at the above
telephone number if you did not receive our Brochure or if you have any questions about the content of this
supplement.
Additional information about Erin Hadley is also available on the SEC’s website at www.adviserinfo.sec.gov.

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
February 13, 2024
-1-

Item 2

Educational Background and Business Experience

Erin Hadley was born in 1972. She received a B.A. in English from the University of Florida in 1995.
Ms. Hadley has been a Managing Partner of Occidental Asset Management, LLC since October 2015. From
January 2004 to October 2015 she was a certified financial planner with Personal Financial Consultants, Inc.
Ms. Hadley’s principal duties include portfolio management and diversification services for high net worth
individuals and other clients.

Item 3

Disciplinary Information

Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary
actions that would be material to your evaluation of each investment advisor representative providing
investment advice to you. There is no information of this type to report.

Item 4

Other Business Activities

Ms. Hadley is not involved in any other business activities material to his relationship with advisory clients.

Item 5Additional Compensation

Ms. Hadley does not receive any economic benefit from any non-client for providing advisory services.

Item 6

Supervision

Nathan H. Walsh, Chief Compliance Officer and Managing Principal of Occidental Asset Management, LLC,
is responsible for the supervision of Ms. Hadley. His telephone number is (650) 344-1600.

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
February 13, 2024-2-

Form ADV: Part 2B Supplement

Item 1

Cover Page

Nicholas Maratta
Managing Partner
Occidental Asset Management, LLC
also doing business as

OCCAM
YMW Advisors
301 California Drive #9
Burlingame, CA 94010
www.occamllc.net

Telephone:
Facsimile:(650) 344-1600(650) 745-7347

February 13, 2024

This Brochure Supplement provides information about Nicholas Maratta that supplements the Occidental
Asset Management, LLC Brochure. You should have received a copy of that Brochure. Please contact us at theabove telephone number if you did not receive our Brochure or if you have any questions about the content of
this supplement.
Additional information about Nicholas Maratta is also available on the SEC’s website atwww.adviserinfo.sec.gov.

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
February 13, 2024
-1-

Item 2

Educational Background and Business Experience

Nicholas Maratta was born in 1979. He received a B.A. in Economics from Rollins College in 2001.
Mr. Maratta has been a Managing Partner of Occidental Asset Management, LLC since April 2016. From May
1999 to April 2016, he was a financial advisor and branch manager with Scottrade, Inc.
Mr. Maratta’s principal duties include portfolio management and diversification services for high net worth
individuals and other clients.

Item 3

Disciplinary Information

Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary
actions that would be material to your evaluation of each investment advisor representative providing
investment advice to you. There is no information of this type to report.

Item 4

Other Business Activities

Mr. Maratta is not involved in any other business activities material to his relationship with advisory clients.

Item 5Additional Compensation

Mr. Maratta does not receive any economic benefit from any non-client for providing advisory services.

Item 6

Supervision

Nathan H. Walsh, Chief Compliance Officer and Managing Principal of Occidental Asset Management, LLC,
is responsible for the supervision of Mr. Maratta. His telephone number is (650) 344-1600.

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
February 13, 2024-2-

Form ADV: Part 2B Supplement

Item 1

Cover Page

Bugra Bakan
Managing Partner
Occidental Asset Management, LLC
also doing business as

OCCAM
YMW Advisors
301 California Drive #9
Burlingame, CA 94010
www.occamllc.net

Telephone:
Facsimile:(650) 344-1600(650) 745-7347

February 13, 2024

This Brochure Supplement provides information about Bugra Bakan that supplements the Occidental AssetManagement, LLC Brochure. You should have received a copy of that Brochure. Please contact us at the above
telephone number if you did not receive our Brochure or if you have any questions about the content of this
supplement.
Additional information about Bugra Bakan is also available on the SEC’s website at www.adviserinfo.sec.gov.

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
February 13, 2024
-3-

Item 2

Educational Background and Business Experience

Bugra Bakan was born in 1974. He graduated from the University El Marmara in Istanbul, Turkey in 1996. In
2003 Mr. Bakan received a Master’s degree in Finance from San Francisco State University. He holds theCertified Financial Planner® designation.
Mr. Bakan has been a Managing Partner of Occidental Asset Management, LLC since October 2020. Mr. Bakan
was the founder and CEO of Shield Wealth Management LLC from October 2010 to October 2020. He
previously served as a Senior Vice President of Polaris Equity Management, Inc. from July 2007 to September
2010, as an Investment Consultant at TD Waterhouse from May 2005 to June 2007, and a Financial Consultant
at RBC Dain Rauscher, Inc. from March 2004 to May 2005.
Mr. Bakan’s principal duties include portfolio management and diversification services for high net worth
individuals and other clients.

Item 3

Disciplinary Information

Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary
actions that would be material to your evaluation of each investment advisor representative providing
investment advice to you. There is no information of this type to report.

Item 4

Other Business Activities

Mr. Bakan is not involved in any other business activities material to his relationship with advisory clients.

Item 5Additional Compensation

Mr. Bakan does not receive any economic benefit from any non-client for providing advisory services.

Item 6

Supervision

Nathan H. Walsh, Chief Compliance Officer and Managing Principal of Occidental Asset Management, LLC,
is responsible for the supervision of Mr. Wilbourne. His telephone number is (650) 344-1600.

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
February 13, 2024
-4-Form ADV: Part 2B Supplement

Item 1

Cover Page

James Griffin
Managing Partner
Occidental Asset Management, LLC
also doing business as

OCCAM
Your Mental Wealth
301 California Drive #9
Burlingame, CA 94010
www.occamllc.net

Telephone:
Facsimile:(650) 344-1600(650) 745-7347

February 13, 2024

This Brochure Supplement provides information about James Griffin that supplements the Occidental AssetManagement, LLC Brochure. You should have received a copy of that Brochure. Please contact us at the above
telephone number if you did not receive our Brochure or if you have any questions about the content of this
supplement.
Additional information about James Griffin is also available on the SEC’s website at www.adviserinfo.sec.gov.

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
February 13, 2024
-5-

Item 2

Educational Background and Business Experience

James Griffin was born in 1986. He received a Bachelor of Business Administration from the University ofNorth Texas in 2009. He holds a Master of Business Administration from the University of North Texas in2015.He holds the Certified Financial Planner® designation.
Mr. Griffin has been a Managing Partner of Occidental Asset Management, LLC since January 2024. Mr. Griffin
was an investment adviser and registered representative with Charles Schwab & Co., Inc. from February 2022
to January 2024. He previously served as a Client Service Representative of TD Ameritrade from June 2006 to
February 2022.
Mr. Griffin’s principal duties include portfolio management and diversification services for high net worth
individuals and other clients.

Item 3

Disciplinary Information

Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary
actions that would be material to your evaluation of each investment advisor representative providing
investment advice to you. There is no information of this type to report.

Item 4

Other Business Activities

Mr. Griffin is not involved in any other business activities material to his relationship with advisory clients.

Item 5Additional Compensation

Mr. Griffin does not receive any economic benefit from any non-client for providing advisory services.

Item 6

Supervision

Nathan H. Walsh, Chief Compliance Officer and Managing Principal of Occidental Asset Management, LLC,
is responsible for the supervision of Mr. Griffin. His telephone number is (650) 344-1600.

Occidental Asset Management, LLC also doing business as OCCAM and YMW Advisors
CRD: 168650
February 13, 2024-6-