i 

This brochure provides information about the qualifications and business practices of Doench Wealth Management, 

LLC. If you have any questions about the contents of this brochure, please contact us at (843) 422-6478 or by email 

at: briandoench@gmail.com. The information in this brochure has not been approved or verified by the United States 

Securities and Exchange Commission or by any state securities authority. 

Additional information about Doench Wealth Management, LLC is also available on the SEC’s website at 

www.adviserinfo.sec.gov. Doench Wealth Management, LLC’s CRD number is: 171515.

1504 Bay Road, Suite 2901

Miami Beach, FL 33139

Main: (843) 422-6478

Fax: (843) 628-4855 

briandoench@gmail.com 

Registration does not imply a certain level of skill or training. 

Version Date: 12/19/2014 

Doench Wealth Management, LLC

Firm Brochure - Form ADV Part 2A

EXHIBIT "1"

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Item 2: Material Changes

Doench Wealth Management, LLC has not yet filed an annual updating amendment using the Form 

ADV Part 2A. Therefore there are no material changes to report.

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Item 3: Table of Contents

Item 1: Cover Page 

Item 2: Material Changes.......................................................................................................................................................................................... ii

Item 3: Table of Contents ......................................................................................................................................................................................... iii

Item 4: Advisory Business .........................................................................................................................................................................................2

A. Description of the Advisory Firm...................................................................................................................................................................2

B. Types of Advisory Services..............................................................................................................................................................................2

C. Client Tailored Services and Client Imposed Restrictions ..........................................................................................................................3

D. Wrap Fee Programs..........................................................................................................................................................................................3

E. Assets Under Management..............................................................................................................................................................................3

Item 5: Fees and Compensation................................................................................................................................................................................4

A. Fee Schedule......................................................................................................................................................................................................4

B. Payment of Fees.................................................................................................................................................................................................4

C. Client Responsibility For Third Party Fees....................................................................................................................................................4

D. Prepayment of Fees ..........................................................................................................................................................................................4

E. Outside Compensation For the Sale of Securities to Clients........................................................................................................................5

1. This is a Conflict of Interest................................................................................................................................................................5

2. Clients Have the Option to Purchase Recommended Products From Other Brokers ................................................................5

3. Commissions are not the Primary Source of Income for DWM....................................................................................................5

4. Advisory Fees in Addition to Commissions or Markups...............................................................................................................5

Item 6: Performance-Based Fees and Side-By-Side Management ........................................................................................................................5

Item 7: Types of Clients .............................................................................................................................................................................................6

Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss ...........................................................................................6

A. Methods of Analysis and Investment Strategies..................................................................................................................................6

B. Material Risks Involved ..........................................................................................................................................................................7

C. Risks of Specific Securities Utilized .......................................................................................................................................................8

Item 9: Disciplinary Information ..............................................................................................................................................................................9

A. Criminal or Civil Actions ........................................................................................................................................................................9

B. Administrative Proceedings ...................................................................................................................................................................9

C. Self-regulatory Organization (SRO) Proceedings ................................................................................................................................9

Item 10: Other Financial Industry Activities and Affiliations.............................................................................................................................10

A. Registration as a Broker/Dealer or Broker/Dealer Representative ................................................................................................10

B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor.................10

C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests............................................10

D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections ..................................10

Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading....................................................................11

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A. Code of Ethics.........................................................................................................................................................................................11

B. Recommendations Involving Material Financial Interests ...............................................................................................................11

C. Investing Personal Money in the Same Securities as Clients............................................................................................................11

D. Trading Securities At/Around the Same Time as Clients’ Securities .............................................................................................11

Item 12: Brokerage Practices....................................................................................................................................................................................12

A. Factors Used to Select Custodians and/or Broker/Dealers .............................................................................................................12

1. Research and Other Soft-Dollar Benefits ........................................................................................................................................12

2. Brokerage for Client Referrals .........................................................................................................................................................12

3. Clients Directing Which Broker/Dealer/Custodian to Use ........................................................................................................12

B. Aggregating (Block) Trading for Multiple Client Accounts .............................................................................................................13

Item 13: Reviews of Accounts .................................................................................................................................................................................13

A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews...............................................................................13

B. Factors That Will Trigger a Non-Periodic Review of Client Accounts............................................................................................13

C. Content and Frequency of Regular Reports Provided to Clients.....................................................................................................13

Item 14: Client Referrals and Other Compensation .............................................................................................................................................13

A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) ......13

B. Compensation to Non – Advisory Personnel for Client Referrals...................................................................................................14

Item 15: Custody.......................................................................................................................................................................................................14

Item 16: Investment Discretion ...............................................................................................................................................................................14

Item 17: Voting Client Securities (Proxy Voting)..................................................................................................................................................14

Item 18: Financial Information................................................................................................................................................................................14

A. Balance Sheet ..........................................................................................................................................................................................14

B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients ...............................15

C. Bankruptcy Petitions in Previous Ten Years ......................................................................................................................................15

Item 19: Requirements For State Registered Advisers .........................................................................................................................................15

A. Principal Executive Officers and Management Persons; Their Formal Education and Business Background ..........................15

B. Other Businesses in Which This Advisory Firm or its Personnel are Engaged and Time Spent on Those (If Any)..................15

C. How Performance-based Fees are Calculated and Degree of Risk to Clients ................................................................................15

D. Material Disciplinary Disclosures for Management Persons of this Firm ......................................................................................15

E. Material Relationships That Management Persons Have With Issuers of Securities (If Any) .....................................................15

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Item 4: Advisory Business

Business Description

We provide services to individuals and high-net-worth individuals concerning mutual funds, 

fixed income securities, equities, ETFs (including ETFs in the gold and precious metal sectors) 

and non-U.S. securities. As a registered investment adviser, we are held to the highest standard 

of client care – a fiduciary standard. As a fiduciary, we always put our client’s interests first and 

must fully disclose any potential conflict of interest. We do not hold customer funds or securities.

A. Description of the Advisory Firm

Doench Wealth Management, LLC (hereinafter “DWM”) is a Limited Liability Company 

organized in the State of Florida. The firm was formed in April 2014, and the principal 

owner is Brian Harold Doench.

B. Types of Advisory Services

Portfolio Management Services

DWM offers ongoing portfolio management services based on the individual goals, 

objectives, time horizon, and risk tolerance of each client. DWM creates an Investment 

Policy Statement for each client, which outlines the client’s current situation (income, tax 

levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a 

portfolio that matches each client's specific situation. Portfolio management services 

include, but are not limited to, the following:

• Investment strategy • Personal investment policy

• Asset allocation • Asset selection

• Risk tolerance • Regular portfolio monitoring

DWM evaluates the current investments of each client with respect to their risk tolerance 

levels and time horizon. DWM will request discretionary authority from clients in order 

to select securities and execute transactions without permission from the client prior to 

each transaction. Risk tolerance levels are documented in the Investment Policy 

Statement, which is given to each client.

DWM seeks to provide that investment decisions are made in accordance with the 

fiduciary duties owed to its accounts and without consideration of DWM’s economic, 

investment or other financial interests. To meet its fiduciary obligations, DWM attempts 

to avoid, among other things, investment or trading practices that systematically 

advantage or disadvantage certain client portfolios, and accordingly, DWM’s policy is to 

seek fair and equitable allocation of investment opportunities/transactions among its 

clients to avoid favoring one client over another over time. It is DWM’s policy to allocate 

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investment opportunities and transactions it identifies as being appropriate and prudent 

among its clients on a fair and equitable basis over time.

Services Limited to Specific Types of Investments

DWM generally limits its investment advice to mutual funds, fixed income securities, 

equities, ETFs (including ETFs in the gold and precious metal sectors) and non-U.S. 

securities. DWM primarily recommends ETF’s and equity securities and will rarely invest 

in mutual funds, unless a client already holds them. Non-U.S. securities exposure is 

primarily through emerging market ETFs. ADRs make up a small percentage of the 

portfolio. DWM may use other securities as well to help diversify a portfolio when 

applicable.

C. Client Tailored Services and Client Imposed Restrictions

DWM will tailor a program for each individual client. Beyond a risk tolerance appraisal, 

DWM considers the client's investment time horizon along with near- and longer-term 

liquidity needs and the tax implications of various investment transactions. This will 

include an interview session to get to know the client’s specific needs and requirements

as well as a plan that will be executed by DWM on behalf of the client. DWM may use 

“model portfolios” together with a specific set of recommendations for each client based 

on their personal restrictions, needs, and targets. Clients may impose restrictions in 

investing in certain securities or types of securities in accordance with their values or 

beliefs. However, if the restrictions prevent DWM from properly servicing the client 

account, or if the restrictions would require DWM to deviate from its standard suite of 

services, DWM reserves the right to end the relationship.

D. Wrap Fee Programs

A wrap fee program is an investment program where the investor pays one stated fee that 

includes management fees, transaction costs, fund expenses, and other administrative 

fees. DWM does not participate in any wrap fee programs.

E. Assets Under Management

DWM has the following assets under management:

Discretionary Amounts: Non-discretionary Amounts: Date Calculated:

$0 $0 May 2014

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Item 5: Fees and Compensation

A. Fee Schedule

Asset-Based Fees for Portfolio Management

Total Assets Under Management Annual Fee

Up to $1,000,000 1.50%

$1,000,001 - $2,000,000 1.25%

$2,000,001 - and up 1.00%

These fees are generally negotiable and the final fee schedule is attached as Exhibit II of 

the Investment Advisory Contract. Clients may terminate the agreement without penalty 

for a full refund of DWM's fees within five business days of signing the Investment 

Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract 

generally with 14 days' written notice.

DWM uses the client’s account balance at the end of the month or quarter, based on client's 

preference, for purposes of determining the market value of the assets upon which the

advisory fee is based, after taking into account deposits and withdrawals.

B. Payment of Fees

Payment of Asset-Based Portfolio Management Fees

Asset-based portfolio management fees are withdrawn directly from the client's accounts 

with client's written authorization on a monthly or quarterly basis, depending on client 

preference. Fees are paid in arrears.

C. Client Responsibility For Third Party Fees

Clients are responsible for the payment of all third party fees (i.e. custodian fees, 

brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and 

distinct from the fees and expenses charged by DWM. Please see Item 12 of this brochure 

regarding broker-dealer/custodian.

D. Prepayment of Fees

DWM collects its fees in arrears. It does not collect fees in advance.

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E. Outside Compensation For the Sale of Securities to Clients

Brian Harold Doench, in his role as a licensed insurance agent, accepts compensation for 

the sale of securities to DWM clients.

1. This is a Conflict of Interest

The supervised persons will accept compensation for the sale of securities or other 

investment products, including asset based sales charges or service fees from the sale 

of mutual funds to its clients. This presents a conflict of interest and gives the 

supervised person an incentive to recommend products based on the compensation 

received rather than on the client’s needs. When recommending the sale of securities 

or investment products for which the supervised persons receives compensation, they 

will document the conflict of interest in the client file and inform the client of the 

conflict of interest. 

2. Clients Have the Option to Purchase Recommended Products From Other 

Brokers

Clients always have the option to purchase DWM recommended products through 

other brokers or agents that are not affiliated with DWM.

3. Commissions are not the Primary Source of Income for DWM

Commissions are not DWM’s primary source of compensation.

4. Advisory Fees in Addition to Commissions or Markups

Advisory fees that are charged to clients are not reduced to offset the commissions or 

markups on securities or investment products recommended to clients.

Item 6: Performance-Based Fees and Side-By-Side Management

DWM does not accept performance-based fees or other fees based on a share of capital gains on 

or capital appreciation of the assets of a client.

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Item 7: Types of Clients

DWM generally provides advisory services to the following types of clients:

 Individuals

 High-Net-Worth Individuals

Minimum Account Size for Portfolio Management

There is an account minimum of $5,000, which may be waived by DWM in its discretion.

Item 8: Methods of Analysis, Investment Strategies, and Risk of 

Investment Loss

A. Methods of Analysis and Investment Strategies

Methods of Analysis

DWM’s methods of analysis include charting analysis, fundamental analysis, technical 

analysis, cyclical analysis, quantitative analysis and modern portfolio theory.

Charting analysis involves the use of patterns in performance charts. DWM uses this 

technique to search for patterns used to help predict favorable conditions for buying 

and/or selling a security.

Fundamental analysis involves the analysis of financial statements, the general financial 

health of companies, and/or the analysis of management or competitive advantages.

Technical analysis involves the analysis of past market data; primarily price and volume.

Cyclical analysis involves the analysis of business cycles to find favorable conditions for 

buying and/or selling a security.

Quantitative analysis deals with measurable factors as distinguished from qualitative 

considerations such as the character of management or the state of employee morale, such 

as the value of assets, the cost of capital, historical projections of sales, and so on.

Modern portfolio theory is a theory of investment that attempts to maximize portfolio 

expected return for a given amount of portfolio risk, or equivalently minimize risk for a 

given level of expected return, each by carefully choosing the proportions of various asset.

Investment Strategies

DWM uses long term trading, short term trading and options trading (which will consist 

of covered calls and cash secured puts and spreads, but never naked calls).

Investing in securities involves a risk of loss that you, as a client, should be prepared 

to bear.

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B. Material Risks Involved

Methods of Analysis

Charting analysis strategy involves using and comparing various charts to predict long 

and short term performance or market trends. The risk involved in using this method is 

that only past performance data is considered without using other methods to crosscheck 

data. Using charting analysis without other methods of analysis would be making the 

assumption that past performance will be indicative of future performance. This may not 

be the case.

Fundamental analysis concentrates on factors that determine a company’s value and 

expected future earnings. This strategy would normally encourage equity purchases in 

stocks that are undervalued or priced below their perceived value. The risk assumed is 

that the market will fail to reach expectations of perceived value.

Technical analysis attempts to predict a future stock price or direction based on market 

trends. The assumption is that the market follows discernible patterns and if these

patterns can be identified then a prediction can be made. The risk is that markets do not 

always follow patterns and relying solely on this method may not take into account new 

patterns that emerge over time.

Cyclical analysis assumes that the markets react in cyclical patterns which, once 

identified, can be leveraged to provide performance. The risks with this strategy are twofold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors 

begin to implement this strategy, then it changes the very cycles these investors are trying 

to exploit.

Quantitative Model Risk: Investment strategies using quantitative models may perform 

differently than expected as a result of, among other things, the factors used in the models, 

the weight placed on each factor, changes from the factors’ historical trends, and technical 

issues in the construction and implementation of the models.

Modern Portfolio Theory assumes that investors are risk adverse, meaning that given 

two portfolios that offer the same expected return, investors will prefer the less risky one. 

Thus, an investor will take on increased risk only if compensated by higher expected 

returns. Conversely, an investor who wants higher expected returns must accept more 

risk. The exact trade-off will be the same for all investors, but different investors will 

evaluate the trade-off differently based on individual risk aversion characteristics. The 

implication is that a rational investor will not invest in a portfolio if a second portfolio 

exists with a more favorable risk-expected return profile – i.e., if for that level of risk an 

alternative portfolio exists which has better expected returns.

Investment Strategies

DWM's use of options trading generally holds greater risk, and clients should be aware 

that there is a material risk of loss using any of those strategies.

Long term trading is designed to capture market rates of both return and risk. Due to its 

nature, the long-term investment strategy can expose clients to various types of risk that 

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will typically surface at various intervals during the time the client owns the investments. 

These risks include but are not limited to inflation (purchasing power) risk, interest rate 

risk, economic risk, market risk, and political/regulatory risk.

Short term trading risks include liquidity, economic stability, and inflation, in addition to 

the long term trading risks listed above. Frequent trading can affect investment 

performance, particularly through increased brokerage and other transaction costs and 

taxes.

Options transactions involve a contract to purchase a security at a given price, not 

necessarily at market value, depending on the market. This strategy includes the risk that 

an option may expire out of the money resulting in minimal or no value, as well as the 

possibility of leveraged loss of trading capital due to the leveraged nature of stock options.

Investing in securities involves a risk of loss that you, as a client, should be prepared 

to bear.

C. Risks of Specific Securities Utilized

DWM's use of options trading generally holds greater risk of capital loss. Clients should 

be aware that there is a material risk of loss using any investment strategy. The investment 

types listed below are not guaranteed or insured by the FDIC or any other government 

agency.

Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may 

lose money investing in mutual funds. All mutual funds have costs that lower investment 

returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” 

nature (mentioned below).

Equity investment generally refers to buying shares of stocks in return for receiving a 

future payment of dividends and/or capital gains if the value of the stock increases. The 

value of equity securities may fluctuate in response to specific situations for each 

company, industry conditions and the general economic environments.

Fixed income investments generally pay a return on a fixed schedule, though the amount 

of the payments can vary. This type of investment can include corporate and government 

debt securities, leveraged loans, high yield, and investment grade debt and structured 

products, such as mortgage and other asset-backed securities, although individual bonds 

may be the best known type of fixed income security. In general, the fixed income market 

is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond 

prices usually fall, and vice versa. This effect is usually more pronounced for longer-term 

securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and 

credit and default risks for both issuers and counterparties. The risk of default on treasury 

inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting 

(extremely unlikely); however, they carry a potential risk of losing share price value, albeit 

rather minimal. Risks of investing in foreign fixed income securities also include the 

general risk of non-U.S. investing described below.

Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, 

similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% 

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loss in the case of a stock holding bankruptcy). Areas of concern include the lack of 

transparency in products and increasing complexity, conflicts of interest and the 

possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver, 

or Palladium Bullion backed “electronic shares” not physical metal) specifically may be 

negatively impacted by several unique factors, among them (1) large sales by the official 

sector which own a significant portion of aggregate world holdings in gold and other 

precious metals, (2) a significant increase in hedging activities by producers of gold or 

other precious metals, (3) a significant change in the attitude of speculators and investors.

Options are contracts to purchase a security at a given price, risking that an option may 

expire out of the money resulting in minimal or no value. DWM will not invest in 

uncovered call options. Spread option positions entail buying and selling multiple options 

on the same underlying security, but with different strike prices or expiration dates, which 

helps limit the risk of other option trading strategies. Option transactions also involve 

risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk, 

political/regulatory risk, inflation (purchasing power) risk and interest rate risk.

Non-U.S. securities present certain risks such as currency fluctuation, political and 

economic change, social unrest, changes in government regulation, differences in 

accounting and the lesser degree of accurate public information available. Exposure to 

non-U.S. securities is primarily through ETFs. 

An American depositary receipt (ADR) is a negotiable security that represents securities 

of a non-US company that trades in the US financial markets, which has certain of the 

same risks as investing directly in non-U.S. securities.

Past performance is not indicative of future results. Investing in securities involves a 

risk of loss that you, as a client, should be prepared to bear.

Item 9: Disciplinary Information

A. Criminal or Civil Actions

There are no criminal or civil actions to report.

B. Administrative Proceedings

There are no administrative proceedings to report.

C. Self-regulatory Organization (SRO) Proceedings

There are no self-regulatory organization proceedings to report.

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Item 10: Other Financial Industry Activities and Affiliations

A. Registration as a Broker/Dealer or Broker/Dealer Representative

Neither DWM nor its representatives are registered as, or have pending applications to 

become, a broker/dealer or a representative of a broker/dealer.

B. Registration as a Futures Commission Merchant, Commodity Pool 

Operator, or a Commodity Trading Advisor

Neither DWM nor its representatives are registered as or have pending applications to 

become either a Futures Commission Merchant, Commodity Pool Operator, or 

Commodity Trading Advisor or an associated person of the foregoing entities.

C. Registration Relationships Material to this Advisory Business and 

Possible Conflicts of Interests

Brian Harold Doench is a licensed insurance agent. From time to time, he will offer clients 

advice or products from those activities. Clients should be aware that these services pay 

a commission or other compensation and involve a conflict of interest, as commissionable 

products conflict with the fiduciary duties of a registered investment adviser. DWM

always acts in the best interest of the client; including the sale of commissionable products 

to advisory clients. Clients are in no way required to purchase such services or products 

through any representative of DWM in such individual’s outside capacities.

Mr. Doench also owns a rental property through which he receives rental income.

D. Selection of Other Advisers or Managers and How This Adviser is 

Compensated for Those Selections

DWM does not utilize nor select third-party investment advisers. All assets are managed 

by DWM.

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Item 11: Code of Ethics, Participation or Interest in Client 

Transactions and Personal Trading

A. Code of Ethics

DWM has a written Code of Ethics that covers the following areas: Prohibited Purchases 

and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, 

Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, 

Service on a Board of Directors, Compliance Procedures, Compliance with Laws and 

Regulations, Procedures and Reporting, Certification of Compliance, Reporting 

Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual 

Review, and Sanctions. DWM's Code of Ethics is available free upon request to any client 

or prospective client.

B. Recommendations Involving Material Financial Interests 

DWM does not recommend that clients buy or sell any security in which a related person 

to DWM or DWM has a material financial interest.

C. Investing Personal Money in the Same Securities as Clients 

From time to time, representatives of DWM may buy or sell securities for themselves that 

they also recommend to clients. This may provide an opportunity for representatives of 

DWM to buy or sell the same securities before or after recommending the same securities 

to clients resulting in representatives profiting off the recommendations they provide to 

clients. Such transactions may create a conflict of interest. DWM will always document 

any transactions that could be construed as conflicts of interest and will never engage in 

trading that operates to the client’s disadvantage when similar securities are being bought 

or sold.

D. Trading Securities At/Around the Same Time as Clients’ Securities 

From time to time, representatives of DWM may buy or sell securities for themselves at 

or around the same time as clients. This may provide an opportunity for representatives 

of DWM to buy or sell securities before or after recommending securities to clients 

resulting in representatives profiting off the recommendations they provide to clients. 

Such transactions may create a conflict of interest; however, DWM will never engage in 

trading that operates to the client’s disadvantage if representatives of DWM buy or sell 

securities at or around the same time as clients.

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Item 12: Brokerage Practices

A. Factors Used to Select Custodians and/or Broker/Dealers

Custodians/broker-dealers will be recommended based on DWM’s duty to seek “best 

execution,” which is the obligation to seek execution of securities transactions for a client 

on the most favorable terms for the client under the circumstances. Clients will not 

necessarily pay the lowest commission or commission equivalent, and DWM may also 

consider the market expertise and research access provided by the brokerdealer/custodian, including but not limited to access to written research, oral 

communication with analysts, admittance to research conferences and other resources 

provided by the brokers that may aid in DWM's research efforts. DWM will never charge 

a premium or commission on transactions, beyond the actual cost imposed by the brokerdealer/custodian. DWM requires clients to use TD Ameritrade Institutional, a division of 

TD Ameritrade, Inc. Member FINRA/SIPC/NFA.

1. Research and Other Soft-Dollar Benefits 

While DWM has no formal soft dollars program in which soft dollars are used to pay 

for third party services, DWM may receive research, products, or other services from 

custodians and broker-dealers in connection with client securities transactions (“soft 

dollar benefits”). DWM may enter into soft-dollar arrangements consistent with (and 

not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange 

Act of 1934, as amended. There can be no assurance that any particular client will 

benefit from soft dollar research, whether or not the client’s transactions paid for it, 

and DWM does not seek to allocate benefits to client accounts proportionate to any 

soft dollar credits generated by the accounts. DWM benefits by not having to produce 

or pay for the research, products or services, and DWM will have an incentive to 

recommend a broker-dealer based on receiving research or services. Clients should be 

aware that DWM’s acceptance of soft dollar benefits may result in higher commissions 

charged to the client.

2. Brokerage for Client Referrals 

DWM receives no referrals from a broker-dealer or third party in exchange for using 

that broker-dealer or third party.

3. Clients Directing Which Broker/Dealer/Custodian to Use 

DWM will require clients to use a specific broker-dealer (the custodian, TD 

Ameritrade Institutional) to execute transactions.

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B. Aggregating (Block) Trading for Multiple Client Accounts

If DWM buys or sells the same securities on behalf of more than one client, then it may 

(but would be under no obligation to) aggregate or bunch such securities in a single 

transaction for multiple clients in order to seek more favorable prices, lower brokerage 

commissions, or more efficient execution. In such case, DWM would place an 

aggregate order with TD Ameritrade Institutional on behalf of all such clients in order 

to ensure fairness for all clients; provided, however, that trades would be reviewed 

periodically to ensure that accounts are not systematically disadvantaged by this 

policy. DWM would determine the appropriate number of shares and select the 

appropriate brokers consistent with its duty to seek best execution, except for those 

accounts with specific brokerage direction (if any).

Item 13: Reviews of Accounts

A. Frequency and Nature of Periodic Reviews and Who Makes Those 

Reviews

All client portfolio management accounts are reviewed at least quarterly by Brian H 

Doench with regard to clients’ respective investment policies and risk tolerance levels. All 

accounts at DWM are assigned to this reviewer.

B. Factors That Will Trigger a Non-Periodic Review of Client Accounts 

Reviews may be triggered by material market, economic or political events, or by changes 

in client's financial situations (such as retirement, termination of employment, physical 

move, or inheritance).

C. Content and Frequency of Regular Reports Provided to Clients 

Each client will receive a monthly report detailing the client’s account, including assets 

held, asset value, and calculation of fees. This written report will come from the custodian.

Item 14: Client Referrals and Other Compensation

A. Economic Benefits Provided by Third Parties for Advice Rendered 

to Clients (Includes Sales Awards or Other Prizes)

DWM does not receive any economic benefit, directly or indirectly from any third party 

for advice rendered to DWM's clients.

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B. Compensation to Non – Advisory Personnel for Client Referrals

DWM does not directly or indirectly compensate any person who is not advisory 

personnel for client referrals.

Item 15: Custody

When advisory fees are deducted directly from client accounts at client's custodian, DWM will 

be deemed to have limited custody of client's assets and must have written authorization from 

the client to do so. Clients will receive all account statements and billing invoices that are required 

in each jurisdiction, and they should carefully review those statements for accuracy.

Item 16: Investment Discretion

DWM provides discretionary and non-discretionary investment advisory services to clients. The 

Investment Advisory Contract established with each client sets forth the discretionary authority 

for trading. Where investment discretion has been granted, DWM generally manages the client’s 

account and makes investment decisions without consultation with the client as to when the 

securities are to be bought or sold for the account, the total amount of the securities to be 

bought/sold, what securities to buy or sell, or the price per share. In some instances, DWM’s 

discretionary authority in making these determinations may be limited by conditions imposed 

by a client (in investment guidelines or objectives, or client instructions otherwise provided to 

DWM.)

Item 17: Voting Client Securities (Proxy Voting)

DWM will not ask for, nor accept voting authority for client securities. Clients will receive proxies 

directly from the issuer of the security or the custodian. Clients should direct all proxy questions 

to the issuer of the security.

Item 18: Financial Information

A. Balance Sheet

DWM neither requires nor solicits prepayment of more than $500 in fees per client, six 

months or more in advance, and therefore is not required to include a balance sheet with 

this brochure.

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B. Financial Conditions Reasonably Likely to Impair Ability to Meet 

Contractual Commitments to Clients 

Neither DWM nor its management has any financial condition that is likely to reasonably 

impair DWM’s ability to meet contractual commitments to clients.

C. Bankruptcy Petitions in Previous Ten Years 

DWM has not been the subject of a bankruptcy petition in the last ten years.

Item 19: Requirements For State Registered Advisers

A. Principal Executive Officers and Management Persons; Their 

Formal Education and Business Background 

DWM currently has only one management person: Brian Harold Doench. Education and 

business background can be found on the individual's Form ADV Part 2B brochure 

supplement.

B. Other Businesses in Which This Advisory Firm or its Personnel are 

Engaged and Time Spent on Those (If Any)

Other business activities for each relevant individual can be found on the Form ADV Part 

2B brochure supplement for each such individual.

C. How Performance-based Fees are Calculated and Degree of Risk to 

Clients 

DWM does not accept performance-based fees or other fees based on a share of capital 

gains on or capital appreciation of the assets of a client.

D. Material Disciplinary Disclosures for Management Persons of this 

Firm

There are no civil, self-regulatory organization, or arbitration proceedings to report under 

this section.

E. Material Relationships That Management Persons Have With 

Issuers of Securities (If Any)

See Item 10.C and 11.B.

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