Pendulum Wealth Partners is a investment adviser based in Itasca, IL, that holds a 90.5/100 Fidelon TransparencyScore (th percentile), with 9 registered advisors. Score based on public SEC and FINRA filings.
Pendulum Wealth Partners
Ejmk Ventures · CRD #335762
A fee-only investment adviser with a clean regulatory record and fiduciary commitment.
Fidelon Fact Sheet
Pendulum Wealth Partners is an investment adviser that reports a clean regulatory record with zero complaints or fines. The firm is based in Itasca, Illinois and serves a mainly retail client base. It used to operate under the names EJMK Ventures LLC and Pendulum Partners. The firm manages investment portfolios, helps plan for retirement, and offers estate and tax planning. It charges asset-based fees that start at 1.25 percent for accounts between $500,000 and $750,000, billed monthly in advance. The firm also charges fixed fees and reports that it holds or can access client funds.
Peer Context
How This Firm Works
Registration & Standard of Care
Investment Adviser — this firm is a registered investment adviser, held to a fiduciary standard — legally required to act in clients' best interests.
How This Firm Gets Paid
- Charges a percentage of assets under management
- Charges fixed fees for specific services
- Does not earn commissions on product sales
What you’d pay
Your balance falls in the $500,000 - $750,000 band, charged at 1.25% on the full amount.
This fee is negotiable
Pendulum Wealth Partners states in its Form ADV that advisory fees may be negotiated.
From their Form ADV Part 2A. Most investors never ask.
Not included above
- • Clients may incur custody fees, securities execution fees, mutual fund expenses, and other charges imposed by third parties
- • Advisory Persons may receive commissions from broker-dealer or insurance activities.
Estimated from the firm’s Form ADV Part 2A brochure — not a quote. Actual fees are set in your agreement and may differ. Costs charged by others (custodians, fund managers) are not included.
What This Firm Charges
| Account Size | Annual Fee |
|---|---|
| $500,000 - $750,000 | 1.25% |
Billed monthly in advance
Extracted from Form ADV Part 2A brochure
Specializations
Extracted from Form ADV Part 2A brochure
Who They Typically Serve
Extracted from Form ADV Part 2A brochure
Key Findings
Strengths
- Fee-only compensation — no commission income reported
- Registered as investment adviser with fiduciary obligation
- No broker-dealer registration — advisory services only
- Clean regulatory record — no disclosures, arbitrations, or fines
- Transparent fee structure — charges advisory fees, no commissions
Conflict Audit
Zero material conflicts identified in regulatory filings.
Source: Form ADV Part 1, Items 6-8; Part 2A, Items 10-14
What this firm says about how it gets paid
“This presents a conflict of interest as we are financially incentivized to encourage you to place more assets in your advisory account as you will ultimately pay more in advisory fees.”
“Some of our financial professionals are registered representatives of Purshe Kaplan Sterling Investments, Inc. (“PKS”), a registered broker-dealer.”
Source: the firm’s own Form CRS, filed 2025-05-13 — quoted directly
Regulatory Track Record
0
Disclosures
Clean record — no disclosures found
$0
Total Fines
Clean record — no fines found
Regulatory Events
TransparencyScore Dimensions
Disclosure Record
Customer complaints, arbitrations, and fines. Frequency and recency matter.
100/100
Strong
Avg for investment adviser firms: 82.6 | Top 10%: 99.5
Filing Quality
How clearly the firm describes services, fees, and investment approach in regulatory filings.
85/100
Strong
Avg for investment adviser firms: 84.1 | Top 10%: 100
Conflict Disclosure
How openly the firm explains who pays it and what it's paid to sell. The conflict isn't the problem — hiding it is.
86/100
Strong
Avg for investment adviser firms: 54 | Top 10%: 67
Enforcement History
Self-reported legal and disciplinary history from Form ADV Item 11.
100/100
Strong
Avg for investment adviser firms: 99.7 | Top 10%: 100
Next Steps
Advisor Roster
9 advisors
| Advisor | CRD | Score | Grade |
|---|---|---|---|
| Jeffrey Thrana | 3191738 | — | — |
| Colleen Nesslar | 2367170 | — | — |
| Ryan Richard Vance | 8223903 | — | — |
| Gino Poli | 6945254 | — | — |
| Alison Leigh Brandt | 2876957 | — | — |
| Mark Richard Stephens | 7224162 | — | — |
| Thomas Allan Parker | 6239027 | — | — |
| Shawn L Kennedy | 4197128 | — | — |
| Matthew Kerry Mc Wherter | 5142155 | — | — |
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Frequently Asked Questions
What does the TransparencyScore measure?
The TransparencyScore measures how clearly and completely an advisor or firm discloses important information in their regulatory filings — things like fees, conflicts of interest, disciplinary history, and business practices. A higher score means better disclosure quality, not better investment performance.
Where does this data come from?
All data comes from public regulatory filings: SEC Form ADV (Parts 1, 2, and 3), FINRA BrokerCheck, and the SEC's Investment Adviser Public Disclosure (IAPD) database. These are official filings that firms and advisors are legally required to submit.
Does a low score mean they're a bad advisor?
Not necessarily. A low score means the firm's public filings are less transparent — they may use vague language about fees, skip details about conflicts, or have a more complex regulatory history. Some excellent advisors work at firms with poor disclosure practices. The score measures the filing, not the person.
How often is this data updated?
Fidelon refreshes data from SEC and FINRA sources on a regular schedule. Form ADV filings are updated annually by firms (with amendments throughout the year), and BrokerCheck data is updated as events are reported. Scores are recalculated after each data refresh.
Can an advisor or firm improve their score?
Yes. Scores are based on what's in public filings. A firm that rewrites its ADV brochure in clearer language, discloses conflicts more specifically, or resolves outstanding regulatory issues will see its score improve at the next refresh. The incentive structure is intentional.
Data Sources
Scores are generated using Fidelon's published scoring methodology and reflect the quality of public disclosures, not the quality of investment advice. A firm that improves its disclosures will see its score improve. Fidelon does not provide investment advice.
Verify on SEC IAPD
Last scored: · Score version: 3.9 · CRD #335762