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John B. Lattarulod/b/a JBL Wealth Strategies9747 Businesspark Avenue, Suite 229San Diego, CA 92131(619) 218-2734www.jblwealthstrategies.comDate of Disclosure Brochure: March 8, 2017Part 2A of Form ADV (the “Brochure”) provides information about the qualifications and businesspractices of John B. Lattarulo, sole proprietor, doing business as JBL Wealth Strategies. If you have anyquestions about the contents of this Brochure, please contact John B. Lattarulo at (619) 218-2734 orjohn@jblwealthstrategies.com. The information in this Brochure has not been approved or verified by theUnited States Securities and Exchange Commission or by any state securities authority.JBL Wealth Strategies is registered as an investment adviser with the State of California; however, suchregistration does not imply a certain level of skill or training and no inference to the contrary should bemade.Additional information about JBL Wealth Strategies Advisor is also available on the Internet atwww.adviserinfo.sec.gov. You can view our firm’s information on this website by searching for JBLWealth Strategies’ CRD number: 165960.John B. LattaruloForm ADV Part 2A Disclosure BrochurePage 1
Item 2 – Material ChangesThis Brochure dated March 8, 2017 is prepared in accordance with the requirements and rulesadopted by the United States Securities and Exchange Commission (“SEC”) and the CaliforniaDepartment of Business Oversight (“DBO”). Part 2A of Form ADV requires investment advisers toprovide narrative, plain English disclosures regarding their advisory business in order to provideclients and prospective clients with more meaningful information about the adviser and its businesspractices.Because of the amount of details provided in the Brochure, JBL Wealth Strategies encourages eachclient to read this Brochure carefully and to call us with any questions you may have. In particular,please note that the following Items are either new additions to Form ADV Part 2A, contain additionalinformation not found in prior versions of the Brochure, or denote removal of items from previousBrochures:Item 1 – Advisory Business – updated to reflect the current assets under management of JBLWealth Strategies.JBL Wealth Strategies will ensure that you receive a summary of any material changes to this andsubsequent disclosure Brochures within 120 days after the proprietorship’s fiscal year ends. The fiscalyear ends on December 31, so you will receive the summary of material changes no later than April 30each year. At that time JBL Wealth Strategies will also offer or provide a copy of the most currentdisclosure Brochure. The sole proprietorship may also provide other ongoing disclosure informationabout material changes as necessary.John B. LattaruloForm ADV Part 2A Disclosure BrochurePage 2
Item 3 – Table of ContentsItem 1 – Cover Page . 1Item 2 – Material Changes . 2Item 3 – Table of Contents. 3Item 4 – Advisory Business. 4Introduction.4Description of Advisory Services . 4Limits Advice to Certain Types of Investments . 4Tailor Advisory Services to Individual Needs of Clients. 5Client Assets Managed by Advisor . 5Item 5 – Fees and Compensation . 6Asset Management Services . 6Financial Planning & Consulting Services . 8Item 6 – Performance-Based Fees and Side-By-Side Management. 12Item 7 – Types of Clients . 12Minimum Investment Amounts Required . 12Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss . 13Methods of Analysis . 13Investment Strategies . 14Risk of Loss. 15Item 9 – Disciplinary Information. 16Item 10 – Other Financial Industry Activities and Affiliations . 16Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading . 16Code of Ethics Summary . 16Affiliate and Employee Personal Securities Transactions Disclosure. 17Item 12 – Brokerage Practices. 18Best Execution . 18Directed Brokerage . 18Handling Trade Errors . 18Block Trading Policy. 19Agency Cross Transactions . 19Item 13 – Review of Accounts . 19Account Reviews and Reviewers. 19Account Reports. 19Item 14 – Client Referrals and Other Compensation . 19Item 15 – Custody . 20Item 16 – Investment Discretion . 20Item 17 – Voting Client Securities . 20Item 18 – Financial Information. 21Item 19 – Requirements for State-Registered Advisers . 21Item 20 -- Customer Privacy Policy Notice . 22John B. LattaruloForm ADV Part 2A Disclosure BrochurePage 3
Item 4 – Advisory BusinessJohn B. Lattarulo is a California sole proprietor registered as an investment advisor with the State ofCalifornia since November 2012. He does business as JBL Wealth Strategies (hereinafter “Advisor” “we”“us” or “our”).IntroductionOur investment advisory services are provided to you through John B. Lattarulo, the registeredinvestment advisor, or an appropriately licensed and qualified investment adviser representative(collectively, hereinafter “Representatives”).For all advisory services provided, you should be aware that a potential conflict of interest exists betweenour interests and your interests. You are under no obligation to act on our recommendations and, if youdo, are under no obligation to effect any transaction through us.Description of Advisory ServicesThe following are descriptions of Advisor’s primary advisory services. Additional information concerningdetails of our advisory services and the fees for these services is provided to clients and prospectiveclients (hereinafter “clients” or “you”) in Item 5, Fees and Compensation. A written agreement detailingthe exact terms of the service must be signed by you and Advisor before any services can be provided.Asset Management ServicesWe offer asset management services providing you with continuous and on-going supervision over youraccounts. This means that we continuously monitor your account and make trades in that account whennecessary. Our services are offered through a traditional management program, which means thatadvisory services are provided for a fee but transaction services are billed separately on a per-transactionbasis.Financial Planning & Consulting ServicesWe offer advisory services in the form of full and modular (segmented) financial plans. These services donot involve implementing any transaction on a client’s behalf or the active and ongoing monitoring ormanaging of a client’s investments or accounts. Clients are solely responsible for determining whether toimplement our recommendations. Instead, full planning services focus on a client’s overall financialsituation while modular planning services focus on specific areas of client concern.Consultation services can be on any topic or topics of interest or concern to clientsWhen providing financial planning and consulting services, the role of the representative is to find ways tohelp clients understand their overall financial situation and help them set financial objectives. To theextent that clients want to implement any of our investment recommendations through us or retain us toactively monitor their investments, they must execute a separate written agreement with us for thoseseparate services.Limits Advice to Certain Types of InvestmentsAdvisor provides investment advice on the following types of investments: Mutual FundsExchange Traded Funds (ETFs)Exchange-listed SecuritiesJohn B. LattaruloForm ADV Part 2A Disclosure BrochurePage 4
Securities Traded Over-the-CounterForeign IssuesWarrantsCorporate Debt SecuritiesCommercial PaperCertificates of DepositMunicipal SecuritiesUS Government SecuritiesOptions Contracts on SecuritiesOptions Contracts on CommoditiesFutures Contracts on TangiblesFutures Contracts on IntangiblesInterests in Partnerships Investing in Real EstateInterests in Partnerships Investing in Oil and Gas InterestsSecurities Properly Exempted from RegistrationHedge FundsWe reserve the right to offer advice on any investment product that may be suitable for each client’sspecific circumstances, needs, goals and objectives.It is not our typical investment strategy to attempt to time the market, but we may increase cash holdingsmodestly as deemed appropriate based on your risk tolerance and our expectations of market behavior.We may modify our investment strategy to accommodate special situations such as low basis stock, stockoptions, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations.Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for moreinformation.Tailor Advisory Services to Individual Needs of ClientsAdvisor’s services are always provided based on your individual needs. This means, for example, thatwhen we provide asset management services you are given the ability to impose restrictions on theaccounts we manage for you, including specific investment selections and sectors. We work with you ona one-on-one basis through interviews and questionnaires to determine your investment objectives andsuitability information.We will not enter into an investment adviser relationship with a prospective client whose investmentobjectives may be considered incompatible with our investment philosophy or strategies or where theprospective client seeks to impose unduly restrictive investment guidelines.Client Assets Managed by AdvisorAs of the date of March 7, 2017, the following represents the approximate amount of assets managed byAdvisor on a discretionary and non-discretionary basis:Type of AccountDiscretionaryNon-DiscretionaryTotal:Assets Managed by Advisor 13,675,885 1,013,573 14,689,458The Advisor will update this information in future amendments to this Form ADV Part 2A.John B. LattaruloForm ADV Part 2A Disclosure BrochurePage 5
Item 5 – Fees and CompensationIn addition to the information provided in Item 4 – Advisory Business, this section provides additionaldetails regarding Advisor’s services along with descriptions of each service’s fees and compensationarrangements. The exact fees and other terms will be outlined in the agreement between you andAdvisor. If you do not receive a copy of this Disclosure Brochure at least 48 hours in advance of signingthe client agreement, you have five business days to terminate that agreement without any advisory feecharges.We believe our fees for advisory services are reasonable with respect to the services provided and thefees charged by other investment advisors offering similar services. However, lower fees for comparableservice may be available from other sources.Asset Management ServicesWe offer asset management services, which involve providing you with continuous and ongoingsupervision over your specified accounts (collectively, the “account”). Your account is managed by usbased on your financial situation, investment objectives and risk tolerance. We actively monitor theaccount and provide advice regarding buying, selling, reinvesting or holding securities, cash or otherinvestments of the account.You must appoint our firm as your investment adviser of record on your specified account. The accountconsists only of separate account(s) held by a qualified custodian under your name. We require thatmanaged accounts be held at Scottrade Advisor Services (“Scottrade”) and assist you in establishing anaccount at Scottrade. Advisor requires a minimum of 50,000 in order to open an account, althoughexceptions to this minimum can be granted based upon the relationship of the client (i.e., to Advisor or toan existing client). In addition, clients can household or aggregate accounts to reach the requiredminimum. Scottrade maintains custody of your funds and securities. Neither we nor our representativesact as custodian and we do not have access to your funds and securities except to have advisory feesdeducted from your account by the custodian with your prior written authorization and then paid to us.You retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxyvoting and receive transaction confirmations) of the account.We need to obtain certain information from you to determine your financial situation and investmentobjectives. You are responsible for notifying us of any updates regarding your financial situation, risktolerance or investment objective and whether you wish to impose or modify existing investmentrestrictions; however we contact you at least annually to discuss any changes or updates regarding yourfinancial situation, risk tolerance or investment objectives. We are always reasonably available to consultwith you relative to the status of your account. You have the ability to impose reasonable restrictions onthe management of your accounts, including the ability to instruct us not to purchase certain securities.We manage investments for other clients and may give them advice or take actions for them or for ourpersonal accounts that is different from the advice we provide to you or actions taken for you. We are notobligated to buy, sell or recommend to you any security or other investment that we may buy, sell orrecommend for any other clients or for our own accounts.Conflicts may arise in the allocation of investment opportunities among accounts that we manage. Westrive to allocate investment opportunities believed to be appropriate for your account(s) and otheraccounts advised by us among such accounts equitably and consistent with the best interests of allaccounts involved. However, there can be no assurance that a particular investment opportunity thatcomes to our attention will be allocated in any particular manner. If we obtain material, non-publicinformation about a security or its issuer that we may not lawfully use or disclose, we have absolutely noobligation to disclose the information to any client or use it for any client’s benefit.John B. LattaruloForm ADV Part 2A Disclosure BrochurePage 6
You grant us trading authorization on your accounts, and we provide management services on adiscretionary basis only. This means we can make all decisions to buy, sell or hold securities, cash orother investments in the managed account in our sole discretion without consulting with you beforemaking any transactions. See Item 16, Investment Discretion, for additional discussion ondiscretionary and non-discretionary authority.Fees charged for our asset management services are charged based on a percentage of assets undermanagement:Assets Under ManagementUp to 1,000,000 1,000,001 – 3,000,000 3,000,001 – 5,000,000Over 5,000,001Annual Fees0.95%0.80%0.70%0.50%At Advisor’s sole discretion, the above fees are negotiable based on the type of client, the complexity ofthe client's situation, the composition of the client's account (i.e., equities versus mutual funds), thepotential for additional account deposits and the relationship of the client with the representative.Fees are billed quarterly in advance on a calendar basis and calculated based on the fair market value ofthe account as of the last business day of the previous billing period. For accounts created mid-quarter,fees are prorated based on the number of days service is provided during the initial billing period. Thatinitial partial quarter is billed in arrears at the same time as the next full quarterly advance fee is billed.Advisor believes that its annual fee is reasonable in relation to services provided and the fees charged byother investment advisers offering similar services/programs. However, our annual investment advisoryfee may be higher than that charged by other investment advisers offering similar services/programs. Inaddition to our compensation, you may also incur charges imposed at the mutual fund level (e.g., advisoryfees and other fund expenses).Fees can be deducted from your account or billed directl
managed accounts be held at Scottrade Advisor Services (“Scottrade”) and assist you in establishing an account at Scottrade. Advisor requires a minimum of 50,000 in order to open an account, although exceptions to this minimum can be granted based upon the relationship of the client (i.e
