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Securities Disclosures

Category: Standards Published: Thursday, 26 May 2011 Written by Administrator

Steven D. Wightman

Wightman Financial Network, LLC

1 Aaron Road; Lexington MA 02421

(781) 862-6642

February 28, 2011

This Brochure provides information about the qualifications and business practices of Wightman Financial, LLC. If you have any questions about the contents of this Brochure, please contact us at (781) 862-6642 or This email address is being protected from spambots. You need JavaScript enabled to view it.. 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 Steven D. Wightman also is available on the SEC’s website at

Item 2 – Material Changes

On July 28, 2010, the United States Securities and Exchange Commission published “Amendments to Form ADV” which amends the disclosure document that we provide to clients as required by SEC Rules. This Brochure dated February 28, 2011 is a new document prepared according to the SEC’s new requirements and rules. As such, this Document is materially different in structure and requires certain new information that our previous brochure did not require.

In the future, this Item will discuss only specific material changes that are made to the Brochure and will provide clients with a summary of such changes. We will also reference the date of our last annual update of our brochure.

In the past we have offered or delivered information about our qualifications and business practices to clients on at least an annual basis. Pursuant to new SEC Rules, we will ensure that you receive a summary of any materials changes to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. We may further provide other ongoing disclosure information about material changes as necessary.

We will further provide you with a new Brochure as necessary based on changes or new information, at any time, without charge.

Currently, our Brochure may be requested by contacting Steven D. Wightman, Manager at (781) 862-6642 or This email address is being protected from spambots. You need JavaScript enabled to view it..

Additional information about Steven D. Wightman is also available via the SEC’s web site.

The last changes made to Wightman Financial Network, LLC’s brochure were dated March 2011.

Item 4 – Advisory Business

Wightman Financial Network, LLC offers fee-only financial planning services to clients. Steven D. Wightman is the principal owner with no other subsidiaries or intermediate subsidiaries.

Wightman Financial Network, LLC specializes in personalized college planning services, investment planning, retirement planning, risk management, and financial planning. We specialize in working with women and high net-worth individuals. We do tailor our services to fit the individual needs of clients depending on their interest level. We have had clients who chose to focus on just one area of our services, i.e. college planning, and we are happy to help them reach their goals in any area they need our expertise in.

The Registrant estimates that most of the comprehensive financial planning services offered to clients will not involve investment advice. The areas of financial planning other than investment advice include consultations with a client’s attorneys, accountants, and other sources; risk management analysis, budgeting, tax planning and estate planning and employee benefits. Once these matters are reviewed, a strategy is proposed and a financial plan draft is written and presented to a client for approval. At the client’s request, the Registrant then works with the client to implement the financial plan with the goal of improving his or her financial situation.

Wightman Financial Network, LLC provides advice in equity securities, warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities, variable life insurance, variable annuities, mutual fund shares, and US government securities. He also offers options contracts on securities and commodities, futures contracts on tangibles and intangibles, and interests in investing in real estate and oil and gas interests.

As part of the financial planning process the Registrant will advise clients as to the appropriateness of a specific security or their portfolio as a whole. Such advice will take into account the information gathered by the Registrant, combined with information developed in a current financial plan, should one exist. Analysis is based upon the criteria outlined in a client’s stated goals, risks, investment time horizon, economic environment, and valuation of securities using standard valuation models such as price over earnings or cash flow, tax efficiencies, and cash distributions versus price ratio analysis.

Our current assets under management are zero; this includes both discretionary and non-discretionary funds. This is as of March 1, 2011.

Item 5 – Fees and Compensation

Rolling Fee Schedule for Managed Clients

1.00% per annum of household net worth defined as a reasonable valuation of all assets minus all liabilities. Determination of net worth is computed by tallying all statements of assets and liabilities issued by independent parties such as appraisers, custodians, insurance companies, and taxing authorities.

How Managed Fees are Accounted

Fees will be billed to the custodian holding client’s investments and deducted from the client’s account and paid on a monthly basis in accordance with the client’s written instructions to the custodian. Management fees are computed based upon 1/12 of 1% of client’s household net worth in accordance with the above fee schedule. Monthly billing statements explaining how fees are computed are sent to clients for all managed accounts. Clients may elect to be billed directly by e-mail and via PayPal.


Fees are assessed for two distinct services:

1) The creation of a financial plan
2) Ongoing asset management and total wealth management services

1. For authoring a financial plan, Wightman Financial Network, LLC will charge a fee (fixed fee and/or hourly) for financial planning services and consulting services. Registrant’s fees are negotiable, but hourly fees generally range from $250 to $500, depending upon the level and scope of the services required. Registrant’s minimum hourly charge is $250. The first hour of consultation is $250. The Registrant will require $5,000 retainer paid in advance of providing financial planning services. This retainer will cover the cost of analyzing a client’s financial situation and the authoring of a written financial plan and a planning meeting to fully review the written financial plan by clients. The Registrant charges a flat fee of $5,000 to write a comprehensive financial plan and he will provide monthly statements to clients. If a client’s financial plan is not completed within 150 days from the commencement of the engagement, funds held on account will be returned to the client, after a deduction for services already provided by the Registrant, but not yet billed and credited to the client’s account.

2. Asset management and total wealth management services are charged 1.00% per annum of household net worth defined as a reasonable valuation of all assets minus all liabilities. Determination of net worth is computed by tallying all statements of assets and liabilities issued by independent parties such as appraisers, custodians, insurance companies, and taxing authorities. A minimum $5,000 retainer is charged upon engagement. Thereafter clients may elect monthly, quarterly, or annual billing periods. In addition to being invoiced and writing a check directly to Wightman Financial Network, LLC, they also may elect and authorize automatic payment from their accounts under management from their separate asset custodian on a monthly, quarterly, or annual payment schedule.

Financial planning clients and asset management clients may terminate their agreements with the Registrant upon 30 business days' written notice delivered by certified mail. Fees for work already performed will be deducted from the retainer and the balance returned to the client within thirty days of notice of termination along with a statement of services, fees and any remaining balance or credit due.

Both asset management fees and hourly rates may be negotiable depending upon the complexity of an individual client’s case and/or portfolio. The Registrant further reserves the right to adjust the above referenced fees based upon individual client circumstances.

Clients may incur certain charges imposed by custodians, brokers, third party investment and other third parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees, and commissions are exclusive of and in addition to Registrant’s fee, and Registrant shall not receive any portion of these commissions, fees, and costs.

The Registrant offers investment advisory services for clients. For clients who have committed to completing a comprehensive financial plan, or those who seek investment advice, the Registrant will assist clients in implementing their investment strategies. In addition, the Registrant will review managed accounts and suggest any needed changes at least on an annual basis based upon risk tolerances, goals, tax liabilities, and needs identified in the financial planning process. Hourly fees may be waived for clients with assets under management for all financial planning services provided beginning on the date clients engage for asset management services.

Item 12 further describes the factors that Wightman Financial Network, LLC considers in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation (e.g., commissions).

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

Wightman Financial Network, LLC does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client).

Item 7 – Types of Clients

Steven D. Wightman provides portfolio management services to individuals and high net worth individuals, and the ability to provide said services to corporate qualified pension and profit-sharing plans.

Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss

Investing in securities involves risk of loss that clients should be prepared to bear. Methods of analysis include charting, fundamental strategies, and technical strategies. Sources of information include financial newspapers and magazines; corporate rating services; Steele Mutual Fund Database, company press releases; annual reports, prospectuses, filing with the Securities and Exchange Commission; and research materials prepared by others.

Investment Strategies used to implement any investment advice given to clients include long term purchases (securities held at least a year), short term purchases (securities sold within a year), trading (securities sold within 30 days), hedging strategies including short sales, margin transactions, and option writing (including covered options, uncovered options, or spreading strategies).

Item 9 – Disciplinary Information

Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of Steven D. Wightman or the integrity of Steven D. Wightman’s management. Steven D. Wightman has no information applicable to this Item.

Item 10 – Other Financial Industry Activities and Affiliations

The Registrant has established a non-exclusionary business relationship with TD Ameritrade and E-Trade, as an independent investment advisor. These organizations act as a custodian, where clients may establish accounts to hold securities such as stocks, bonds, insurance products, and no-load mutual funds. Both TD Ameritrade and E-Trade also offer retirement account custody and discount brokerage services. For continuing updates, clients may review services and products via their custodian’s website.

Item 11 – Code of Ethics

Steven D. Wightman has adopted a Code of Ethics for all supervised persons of the firm describing its high standard of business conduct, and fiduciary duty to its clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. All supervised persons at Wightman Financial Network, LLC must acknowledge the terms of the Code of Ethics annually, or as amended.

Steven D. Wightman anticipates that, in appropriate circumstances, consistent with clients’ investment objectives, it will cause accounts over which Wightman Financial Network, LLC has management authority to effect, and will recommend to investment advisory clients or prospective clients, the purchase or sale of securities in which Wightman Financial Network, LLC its affiliates and/or clients, directly or indirectly, have a position of interest. Wightman Financial Network’s employees and persons associated with Steven D. Wightman are required to follow Wightman Financial Network’s Code of Ethics. Subject to satisfying this policy and applicable laws, officers, directors and employees of [“ADVISER”] and its affiliates may trade for their own accounts in securities which are recommended to and/or purchased for Wightman Financial Network’s clients. The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of the employees of Wightman Financial Network will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts.

Under the Code certain classes of securities have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interest of Wightman Financial Network’s clients. In addition, the Code requires pre-clearance of many transactions, and restricts trading in close proximity to client trading activity. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is continually monitored under the Code of Ethics, and to reasonably prevent conflicts of interest between Steven D. Wightman and its clients.

Certain affiliated accounts may trade in the same securities with client accounts on an aggregated basis when consistent with Steven D. Wightman's obligation of best execution. In such circumstances, the affiliated and client accounts will share commission costs equally and receive securities at a total average price. Wightman Financial Network will retain records of the trade order (specifying each participating account) and its allocation, which will be completed prior to the entry of the aggregated order. Completed orders will be allocated as specified in the initial trade order. Partially filled orders will be allocated on a pro rata basis. Any exceptions will be explained on the Order.

Wightman Financial Network’s clients or prospective clients may request a copy of the firm's Code of Ethics by contacting Steven D. Wightman.

It is Wightman Financial Network’s policy that the firm will not affect any principal or agency cross securities transactions for client accounts. Steven D. Wightman will also not cross trades between client accounts. Principal transactions are generally defined as transactions where an adviser, acting as principal for its own account or the account of an affiliated broker-dealer, buys from or sells any security to any advisory client. A principal transaction may also be deemed to have occurred if a security is crossed between an affiliated hedge fund and another client account. An agency cross transaction is defined as a transaction where a person acts as an investment adviser in relation to a transaction in which the investment adviser, or any person controlled by or under common control with the investment adviser, acts as broker for both the advisory client and for another person on the other side of the transaction. Agency cross transactions may arise where an adviser is dually registered as a broker-dealer or has an affiliated broker-dealer.

The Registrant may from time to time take positions in his own account in publicly traded equity securities, bonds or mutual funds. It is possible that the registrant may recommend the purchase or sale of the same equity securities, bonds, or mutual funds with respect to his client’s positions. Under no circumstances will the Registrant hold positions in such securities in any magnitude so as to impact on the price or market movement of such securities. Furthermore, while it is extremely unlikely that any transaction the Registrant may consider effecting for his own account will have any impact upon the positions held by his clients, the Registrant will not engage in any trading activity ahead of or in a manner adverse to his client’s interest.

Item 12 – Brokerage Practices

The Registrant may suggest discount brokerages to clients with the goal of finding the best service or price. The Registrant has the authority to determine, without obtaining specific client consent, the securities to be bought and sold. The Registrant does not have the authority to determine, without obtaining specific client consent, the amount of the securities to be bought or sold, the broker or dealer to be used, and the commission rates to be paid.

Item 13 – Review of Accounts

Reviews are offered quarterly during the first year of services to each client and then at least annually thereafter. The reviews focus on actual risk and performance experienced and the degree to which investments are on track toward reaching client’s stated goals revealed in the first pre-engagement meeting with us. We review the Investment Policy Statement, IPS, annually and compare the asset allocation, the client situation, and the expected investment performance with the actual to determine if any adjustments are needed.

The only reviewer is Steven D. Wightman, CFP who reviews according to the prior criteria and for no more than 30 clients per year.

TD Ameritrade and Nebraska College Savings Plan send statements directly to clients at least quarterly unless the client opts out in accordance with procedures governed by the custodian and between the custodian and the client.

Item 14 – Client Referrals and Other Compensation

The Registrant is not paid cash or receives economic benefit from a non-client in connection with giving advice to clients. The Registrant has paid NAPFA and the FPA a fee to have the registrant’s website listed on the NAPFA and FPA websites. This fee is an annual fee and is not dependent upon the number of referrals received as a result of the listing. The only restriction regarding ongoing listing is continued membership in good standing with these organizations. In addition, several other web sites provide free links to the registrant.

Item 15 – Custody

Clients should receive at least quarterly statements from the broker dealer, bank or other qualified custodian that holds and maintains client’s investment assets. Steven D. Wightman urges you to carefully review such statements and compare such official custodial records to any account statements that we may provide to you. Our statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities.

Item 16 – Investment Discretion

Steven D. Wightman usually receives discretionary authority from the client at the outset of an advisory relationship to select the identity and amount of securities to be bought of sold. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular client account.

When selecting securities and determining amounts, Steven D. Wightman observes the investment policies, limitations and restrictions of the clients for which he advises. For registered investment companies, Steven D. Wightman’s authority to trade securities may also be limited by certain federal securities and tax laws that require diversification of investments and favor the holding of investments once made.

Investment guidelines and restrictions must be provided to Steven D. Wightman in writing.

Item 17 – Voting Client Securities

As a matter of firm policy and practice, Steven D. Wightman does not have any authority to and does not vote proxies on behalf of advisory clients. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in client portfolios. Steven D. Wightman may provide advice to clients regarding the clients’ voting of proxies.

Item 18 – Financial Information

Registered investment advisers are required in this Item to provide you with certain financial information or disclosures about Steven D. Wightman’s financial condition. Steven D. Wightman has no financial commitment that impairs his ability to meet contractual and fiduciary commitments to clients, and has not been the subject of a bankruptcy proceeding.

Item 19 – Requirements for State-Registered Advisers

Steven D. Wightman, CFP born Feb. 28, 1947 is a Certified Financial Planner, registered with the Board of Certified Financial Planners, Washington DC. He graduated in October 1994. He also received a Bachelor of Science from Rivier College in Nashua NH in 1979.



1995 – 2003: Principal, Lexington Financial Management. Practicing fee-only financial planning since 1994. Wightman Financial Network, LLC is a Service Disabled Veteran Owned Business (SDVOB). The Registrant is a member of and currently serves as a trustee and Veteran Service Officer for the Lexington MA Veterans of Foreign Wars. He is also serving as a philanthropy chair of an advisory committee for the Hanscom Federal Credit Union and he has provided pro bono financial education to pre and post deployment National Guard and Reserve units from 2003-2010 under the jurisdiction of the Massachusetts Financial Planning Association, FPA. He is founder of Business Network International, Lexington, MA Chapter. He is a veteran member of Toastmasters International. He enjoys speaking on veteran and family financial planning concerns. He is a contributing author to Tips From The Top, Targeted Advice From America’s Top Money Minds, 2003, by Alpha Publishers and author of Women, Wealth and Wisdom, C. 2011. Professional memberships include the National Association of Personal Financial Advisors (NAPFA). Past affiliations include the Boston Estate Planning Council. National Institute of Certified College Planners the Institute of Certified Financial Planners, the Lexington Chamber of Commerce, and Sports Financial Advisors Association. Annual Question & Answer Session with Dallas Scoffield and Steven Wightman, CFP, Principal

The Value of Your Personal Financial Advisor

  • Investment management services. Implementing an investment program requires giving careful thought to risk, time frame, goals, taxes, choosing a strategy, doing the investment research, and implementing and monitoring the strategy. Most people who seek out financial advisors don't want to take the time to do this regardless of whether they believe they are capable of doing it or not. Hiring an advisor is a time-saver.
  • Handholding and discipline. Many people seek out advisors because they are not confident in investing by themselves. While there are a growing number of sources of easy-to-follow advice, (e.g. on-line advice, newsletters, and fund company asset allocation services) many people are not confident in assessing whether these are right for them. Our experience suggests that many people really value the human connection they get from the advisor and it is this connection that is the source of the trust and confidence they need to commit to and stick with an investment program.
  • Competitive performance. It is our experience over many years that the majority of clients arewith competitive performance and don't necessarily expect their advisor to deliver consistently market-beating performance, provided that they are properly educated. They recognize that the advisor adds value by delivering competitive performance at appropriate risk levels and by bringing discipline to the table, helps to avoid significant mistakes. Of course, there is some subset of the client market that is very performance oriented. This is why it is so important for clients to make sure they understand our investment philosophy and that they have realistic expectations. We don’t over-promise. We focus on helping clients have the highest degrees of probability of achieving their goals within their time horizons.
  • Fees must be reasonable to allow for competitive performance. Fees on a typical qualified plan are taken from fund performance and not transparent to the consumer. These opaque fees reduce return on investments by up to 10% annually. We believe total investment costs over 3% make it extremely difficult to deliver competitive performance. In our platinum financial advisory practice we charge 1% of net worth. Further, with lower holding costs typically to less than 1% for investments we select. The typical 2% + investment cost savings combined with our confidence of our fund due diligence, tax savings though tax efficient investments, our asset class research and our proactive investment management style can more than make up for the fee over the long run, regardless of the return environment.
  • The value of an advisor is greater in a low-return environment. We realize that clients might not easily recognize this, but nevertheless it is true. It becomes an issue of understanding the difference between what the market is providing and what the advisor is providing. In a high-return environment, the absolute returns easily cover the fees but require little work. When the market isn’t just handing out high returns, the value of investment picking is amplified. Obsessively thorough due diligence conducted with a high level of intellectual integrity is, we believe, even more important and can add more value. In addition, our asset allocation approach, which allows us to look at many asset classes, gives us a fairly wide array of investment opportunities to pursue. Note that past performance is no guarantee of future results. Further, each client portfolio is unique to that individual’s needs.

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