Overview
- Headquarters
- Hollywood, FL
- Total Firm Assets
- $173 million
- Average High-Net-Worth Client Portfolio Size
- $3.1 million
- Stated Minimum Account Size
- $1,500,000
Fee Disclosure
BLUEKEY WEALTH ADVISORS, LLC FORM ADV PART 2A BROCHURE
| Min | Max | Disclosed Annual Rate |
|---|---|---|
| $0 | $1,000,000 | 1.00% |
| $1,000,001 | $2,000,000 | 0.80% |
| $2,000,001 | $3,000,000 | 0.75% |
| $3,000,001 | and above | 0.70% |
Stated Minimum Annual Fee: $10,000
Estimated Annual Advisory Fees
| Portfolio Value | Estimated Annual Fee | Effective Fee Rate |
|---|---|---|
| $1 million | Below minimum client size | |
| $5 million | $39,500 | 0.79% |
| $10 million | $74,500 | 0.74% |
| $50 million | $354,500 | 0.71% |
| $100 million | $704,500 | 0.70% |
Actual fees may vary; other investment costs may apply.
Clients
- High-Net-Worth Share of Firm Assets
- 89.31%
- Number of High-Net-Worth Clients
- 50
- Total Client Accounts
- 313
- Discretionary Accounts
- 291
- Non-Discretionary Accounts
- 22
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients
Regulatory Filings
- SEC CRD Number
- 139610
Primary Brochure: BLUEKEY WEALTH ADVISORS, LLC FORM ADV PART 2A BROCHURE (2026-06-23)
View Document Text
Cover Page - Item 1
Azzendo Wealth Advisors
3878 Sheridan Street, Suite A
Hollywood, FL 33021
Phone: (954) 986-0633
Fax: (954) 981-1403
https://www.azzendo.com
June 16, 2026
Form ADV Part 2A Brochure
Cifuentes Wealth Partners, LLC doing business as Azzendo Wealth Advisors is a registered investment
adviser registered. An "investment adviser" means any person who, for compensation, engages in the
business of advising others, either directly or through publications or writings, as to the value of securities
or as to the advisability of investing in, purchasing, or selling securities, or who, for compensation and as
part of a regular business, issues or promulgates analyses or reports concerning securities. Registration
with the SEC or any state securities authority does not imply a certain level of skill or training.
This brochure provides information about the qualifications and business practices of Azzendo Wealth
Advisors. If you have any questions about the contents of this brochure, please contact us at (954) 986-
0633. 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.
information about Azzendo Wealth Advisors
is available on the SEC’s website at
Additional
www.adviserinfo.sec.gov.
Azzendo Wealth Advisors
Form ADV Part 2A Brochure
Page 2
Material Changes - Item 2
The purpose of this page is to inform you of any material changes since the previous version of this brochure.
On March 23, 2026, we filed our annual updating amendment for fiscal year end 2025. We amended the Methods
of Analysis, Investment Strategies and Risk of Loss section (Item 8) of the document to disclose additional material
investment risks (Item 8) pertaining to Direct Indexing, and Artificial Intelligence ("AI") Risk.
We review and update our brochure at least annually to make sure that it remains current.
Azzendo Wealth Advisors
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Table of Contents - Item 3
Contents
Advisory Business - Item 4 ........................................................................................................................ 4
Fees and Compensation - Item 5 .............................................................................................................. 7
Performance-Based Fees and Side-By-Side Management - Item 6 ........................................................ 11
Types of Clients - Item 7.......................................................................................................................... 11
Methods of Analysis, Investment Strategies and Risk of Loss - Item 8 ................................................... 11
Disciplinary Information - Item 9 ............................................................................................................ 19
Other Financial Industry Activities or Affiliations - Item 10 .................................................................... 19
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Item 11 ........... 19
Brokerage Practices - Item 12 ................................................................................................................. 20
Review of Accounts - Item 13 ................................................................................................................. 22
Client Referrals and Other Compensation - Item 14 .............................................................................. 22
Custody - Item 15 .................................................................................................................................... 22
Investment Discretion - Item 16 ............................................................................................................. 23
Voting Client Securities - Item 17 ........................................................................................................... 23
Financial Information - Item 18 .............................................................................................................. 23
Requirements of State-Registered Advisers - Item 19 ............................................................................ 23
Additional Information ........................................................................................................................... 24
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Advisory Business - Item 4
Cifuentes Wealth Partners, LLC doing business as Azzendo Wealth Advisors (hereinafter “Azzendo Wealth
Advisors”) is a registered investment advisor based in Hollywood, Florida. We are a limited liability company under
the laws of the State of Florida. We have been providing investment advisory services since 2010. Amaury
Sanchez-Cifuentes, CFP®, CMP®, is the Managing Member and owner of Azzendo Wealth Advisors.
Currently, we offer the following investment advisory services, personalized to each individual client:
• Portfolio Management Services
•
Financial Planning Services
•
Selection of Third-Party Investment Advisers
The following paragraphs describe what we do and what we charge. Each investment advisory service is listed
below and describes how we tailor our advisory services to your individual needs. Also, you may see the term
Associated Person throughout this Brochure. As used in this Brochure, this term refers to anyone from our firm
who is an officer, employee, and all individuals providing investment advice on behalf of our firm. Such persons
are properly registered as investment adviser representatives in all required jurisdictions.
Portfolio Management Services
Portfolio management refers to the management of money, including investments. Assets are usually held in
what is called a portfolio. Determining the types and quantities of securities to hold in a portfolio is referred to as
portfolio management.
Our firm offers discretionary and non-discretionary portfolio management services to our clients. This means that
once the portfolio has been agreed upon, the ongoing supervision and management of the portfolio will be our
responsibility. This authority is granted to us by you in a written agreement. This allows our firm to decide on
specific securities, the quantity of the securities and placing buy or sell orders for your account without obtaining
your approval for each transaction. This type of authorization is done using either the investment advisory
agreement you sign with our firm, a limited power of attorney agreement, or trading authorization forms. You
may limit this authority by setting a limit on the type of securities that can be purchased for your account. Simply
provide us with your restrictions or guidelines in writing.
The non-discretionary portfolio management service means that we must obtain your approval prior to making
any transactions in your account.
Our investment advice is tailored to meet our clients’ needs and investment objectives. If you decide to hire our
firm to manage your portfolio, we will meet with you to gather your financial information, determine your goals,
and decide how much risk you should take in your investments. The information we gather will help us implement
an asset allocation strategy that will be specific to your goals, whether we are actively investing for you or simply
providing you with advice.
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There are a few ways we might create your investment portfolio depending on what we decide would work best
for you. We may customize a portfolio for you based the goals and risk we determined during the information
gathering process or we might use a predetermined strategy rather than choosing individual securities.
Our firm primarily uses individual equities, bonds, warrants, corporate debt securities, commercial paper,
certificates of deposit, municipal securities, United States government securities, exchange traded funds and
mutual funds in its portfolio management programs.
However we construct your investment portfolio, we will monitor your portfolio’s performance on an continuous
basis, and rebalance the portfolio whenever necessary, as changes occur in market conditions, your financial
circumstances, or both.
We recommend that you compare our invoices with the statement(s) you receive from the qualified custodian. If
you see something that is inaccurate, please call our main office number, located on the cover page of this
brochure.
Financial Planning Services
We offer broad based financial planning including tax planning, insurance planning, estate planning, disability
planning, business planning, retirement planning, education planning, and budgeting and cash flow analysis.
Azzendo Wealth Advisors strives to achieve a client’s long-term financial goals by implementing a financial
planning process that may include any or all of the following steps:
•
• Assessment of a client’s present financial situation by collecting information regarding net worth and
cash flow statements, tax returns, insurance policies, investment portfolios, pension plans, employee
benefit statements etc.
Identification of a client’s financial and personal goals and objectives. Goals or objectives may include
financing a child’s college education or retirement planning. The identified goals or objectives are
specific, realistic and measurable. All goals include time horizons.
•
•
•
• Resolution of finance related problems. Obstacles to achieving financial independence are identified so
that resolution may occur. Examples of problem areas can include too little or too much insurance
coverage, inadequate cash flow or a high tax burden.
Plan Design. A written financial plan is prepared that includes recommendations and solutions to any
financial related problems.
Implementation of the financial plan. The financial plan is finalized and agreed upon. The
recommendations and solutions are executed to reach the desired goals and objectives.
Evaluation of the financial plan is conducted periodically. The financial planning service provides the
option of conducting a periodic review and revision of the plan to ensure that the financial goals are
achieved. The client may be required to pay an additional fee to exercise this option.
Financial plans are based on your financial situation and the financial information you provide to our firm. If your
financial situation, goals, objectives, or needs change, you must notify us promptly.
We also provide financial planning services that cover a specific area, such as retirement or estate planning. We
offer consultative services where we set an appointment to meet with you for financial planning advice for an
hourly fee.
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You may choose to accept or reject our recommendations. If you decide to proceed with our recommendations,
you may do so either through our investment advisory services or by using the advisory/brokerage firm of your
choice.
Estate Planning Services
For clients in need of basic estate planning assistance, we provide access to the estate planning services of
Wealth.com. Wealth.com is an independent third-party firm that helps coordinate the creation of estate planning
documents based on information provided by the client through an online platform. This service is provided for
an additional fee.
Azzendo Wealth Advisors is not a law firm, does not provide legal advice, and does not prepare estate planning
documents. Clients are under no obligation to use Wealth.com and may work with any estate planning attorney
or service provider of their choice. We recommend that clients consult with a qualified attorney to review any
estate planning documents to ensure they meet the client’s specific needs and comply with applicable laws. If a
client chooses to speak directly with an estate planning attorney through Wealth.com, those attorney fees are
paid by the client.
Selection of Third-Party Investment Advisers
Azzendo Wealth Advisors has entered into agreements with various other third-party investment advisers for the
provision of certain investment advisory services. Factors considered in the selection of a third-party advisor
include but may not be limited to: i) Azzendo Wealth Advisors’ preference for a particular third party advisor; ii)
the client’s risk tolerance, goals and objectives, as well as investment experience; and, iii) the amount of client
assets available for investment. In order to assist clients in the selection of a third-party advisor, an Associated
Person of Azzendo Wealth Advisors will typically gather information from the client about the client’s financial
situation, investment objectives, and reasonable restrictions the client wants imposed on the management of the
account.
The third-party advisor may customize the client's portfolio by blending traditional investment strategies with an
allocation to asset classes. The investment strategy adopted by the third-party advisor may embrace value,
growth or contrarian investing styles. Generally, securities transactions will be decided upon and executed by
the third-party advisor on a discretionary basis. This means that the manager selected will have the ability to buy
and sell securities in your account without obtaining your approval. Azzendo Wealth Advisors and its Associated
Persons will not manage, or obtain discretionary authority over the assets in accounts participating in these
programs; however, clients may grant Azzendo Wealth Advisors the discretionary authority to hire and fire such
third-party managers. Generally, clients may not impose restrictions on investing in certain securities or types of
securities in accounts managed by a third-party advisor.
Associated Persons of Azzendo Wealth Advisors will periodically review reports provided to the client. An
Associated Person of Azzendo Wealth Advisors will contact the client at least annually, or more often as agreed
upon with each client, to review the client’s financial situation and objectives, communicate information to the
third-party advisor managing the account as necessary, and to assist the client in understanding and evaluating
the services provided by the third-party advisor. Clients will be expected to notify Azzendo Wealth Advisors of
any changes in their financial situation, investment objectives, or account restrictions.
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The third-party advisor may offer wrapped or non-wrapped pricing options. Wrap pricing structures allow the
client to pay an all-inclusive fee for management, brokerage, clearance, custody, and administrative services. In
a non-wrap pricing structure, the third-party advisor’s fee may be separated from the advisory fee charged by
Azzendo Wealth Advisors. Transaction costs may also be charged for the execution and clearance of advisory
transactions directed by such Third-Party Advisory Services. A complete description of the programs and services
provided, the amount of total fees, the payment structure, termination provisions and other aspects of each
program are detailed and disclosed in: i) the third-party advisor’s Form ADV Part 2A; ii) the program wrap
brochure (if applicable) or other applicable disclosure documents; iii) the disclosure documents of the portfolio
manager(s) selected; or, iv) the third-party advisor’s account opening documents. A copy of all relevant disclosure
documents of the third-party advisor and of the individual portfolio manager(s) will be provided to anyone
interested in these programs/managers.
Assets Under Management
As of December 31, 2025, we manage discretionary assets under management of $149,666,126 and non-
discretionary assets under management of approximately $23,428,500.
Fees and Compensation - Item 5
Azzendo Wealth Advisors charges a percentage of assets under management, hourly charges, fixed fees (not
including subscription fees) or other fees for its advisory services.
Portfolio Management Services
For portfolio management services, Azzendo Wealth Advisors charges an annual fee based upon a percentage of
the market value of the assets being managed. On an annualized basis, our fee for portfolio/asset management
services is set forth in the following blended fee schedule:
Assets Under Management
First $1,000,000
Next $1,000,000
Next $1,000,000
Next $2,000,000
Annual Fee
1.00% per year
0.80% per year
0.75% per year
0.70% per year
For example, a client with a managed account worth $3,000,000, will incur the following annual asset
management fee:
First $1,000,000 x 1.0%: $10,000
Next $1,000,000 x 0.80%: $8,000
Next $1,000,000 x 0.75%: $7,500
Total annual fee: $25,500
**For client relationships over $5 million, the following fee schedule is typically applied:
Assets Under Management
First $5,000,000
Next $5,000,000
Annual Fee
0.75% per year
0.55% per year
Azzendo Wealth Advisors
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Next $5,000,000
Next $5,000,000
Accounts over $20 million
0.45% per year
0.35% per year
Negotiable
Azzendo Wealth Advisors generally requires a minimum of $1,500,000 to open and maintain an individually
managed account. This account minimum may be waived at the discretion of the firm. Where the firm waives this
account minimum, the annual fee will be set at 1.50%, subject to a $10,000 minimum annual fee. The fee will not
exceed 3% of assets under management. In addition, legacy clients who have engaged our firm prior to 08/2023
will be subject to the fee schedule that was in effect at that time. In such cases, fees may be higher than the one
disclosed in the above fee schedule. In all cases, the exact fee payable by the client is clearly set forth in the
client’s advisory agreement.
Azzendo Wealth Advisors allows the accounts for members of the same household to be combined for fee-paying
purposes. We combine the account valuations to assist you in meeting fee breakpoints and therefore lowering
the overall fee level. Azzendo Wealth Advisors extends this option to all accounts residing in the same household.
Portfolio management fees are negotiable depending on factors such as the amount of assets under
management, range of investments, and complexity of the Client’s financial circumstances, among others. Since
this fee is negotiable, the exact fee paid by the client will be clearly stated in the advisory agreement signed by
the client and the firm. Fees are billed quarterly, in advance or in arrears, based on the amount of the assets
under management on the last day of the quarter.
Generally, the custodian holding the client’s account will deduct Azzendo Wealth Advisors’ fees from a designated
account to facilitate billing, provided the client has given written authorization. The qualified custodian will send
an account statement at least quarterly. This statement will detail all account activity. In limited circumstances,
at the sole discretion of Azzendo Wealth Advisors, we may agree to invoice you directly for our advisory fee or
we may negotiate other fee payment arrangements.
Our annual fee is exclusive of, and in addition to brokerage commissions, transaction fees, and other related costs
and expenses which will be incurred by the client. However, we will not receive any portion of the commissions,
fees, and costs. Please see Item 12 – Brokerage Practices for further information on brokerage and transaction
costs.
At the inception of investment management services, the first pay period’s fees will be calculated on a pro-rata
basis. The Advisory Agreement between Azzendo Wealth Advisors and the client will continue in effect until either
party terminates the Agreement in accordance with the terms of the Agreement. Azzendo Wealth Advisors’
annual fee will be pro-rated through the date of termination and all prepaid, unearned fees (if any) will be
refunded to the client in a timely manner.
Financial Planning Services
Azzendo Wealth Advisors may provide its clients with financial planning and consulting services. Azzendo Wealth
Advisors will charge a fixed fee and/or hourly fee for consulting services. Our consulting fees are negotiable and
are payable as invoiced. We utilize the following financial planning fee schedules:
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•
Fixed Fees: Azzendo Wealth Advisors will charge a fixed fee that ranges from $7,500.00 to $25,000.00,
for broad based planning services. In limited circumstances, the total cost could potentially exceed
$25,000.00. In these cases, we will notify the client and may request that the client pay an additional fee.
• Hourly Fees: Azzendo Wealth Advisors charges an hourly fee of $750 for clients who request specific
services (such as a modular plan or hourly consulting services) and do not desire a broad based written
financial plan. The estimated amount of time needed to complete the add on services will be calculated
and disclosed to the client at the inception of service.
If the client engages Azzendo Wealth Advisors for additional investment advisory services, Azzendo Wealth
Advisors may offset all or a portion of its fees for those services based upon the amount paid for planning or
consulting services.
Prior to engaging Azzendo Wealth Advisors to provide consulting services, the client will generally be required to
enter into a written Agreement with us. The Agreement will set forth the terms and conditions of the engagement
and describe the scope of the services to be provided and the portion of the fee that is due from the client.
Azzendo Wealth Advisors’ financial planning fees are payable upon completion of the contracted services.
Either party may terminate the Agreement by written notice to the other. In the event the client terminates
Azzendo Wealth Advisors’ consulting services, the balance of unearned fees (if any) shall be refunded to the client.
Estate Planning Services Fees
For estate planning services provided through Wealth.com, we charge a fee of up to $500. The exact fee, payment
arrangements and refund policies (if any) will be listed in a separate engagement letter that will be signed by the
client.
Third Party Adviser (TPAs) Fees
Azzendo Wealth Advisors will perform management searches of various independent registered investment
advisers for referral to Azzendo Wealth Advisors clients. Azzendo Wealth Advisors will share in the fee paid to the
TPA. The management fee is disclosed in the TPA's disclosure documents. These fees may or may not be
negotiable. Azzendo Wealth Advisors’ compensation may differ depending upon the firm’s individual agreement
with each TPA. Azzendo Wealth Advisors or its Associated Persons may have an incentive to recommend one TPA
over another TPA with whom it has less favorable compensation arrangements or other advisory programs
offered by TPAs with which it has no compensation arrangements.
IRA Rollover Considerations
As a normal extension of financial advice, we provide education or recommendations related to the rollover of an
employer-sponsored retirement plan. A plan participant leaving employment has several options. Each choice
offers advantages and disadvantages, depending on desired investment options and services, fees and expenses,
withdrawal options, required minimum distributions, tax treatment, and the investor's unique financial needs and
retirement plans. The complexity of these choices may lead an investor to seek assistance from us.
An Associated Person who recommends an investor roll over plan assets into an Individual Retirement Account
(“IRA”) may earn an asset-based fee as a result, but no compensation if assets are retained in the plan. Thus, we
have an economic incentive to encourage an investor to roll plan assets into an IRA. In most cases, fees and
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expenses will increase to the investor as a result because the above-described fees will apply to assets rolled over
to an IRA and outlined ongoing services will be extended to these assets.
We are fiduciaries under the Investment Advisers Act of 1940 which are laws governing retirement accounts. We
have to act in your best interests and not put our interest ahead of yours. At the same time, the way we make
money creates some conflicts with your interests.
Additional Fees and Expenses
The fees Azzendo Wealth Advisors charges are negotiable based on the amount of assets under management,
complexity of client goals and objectives, and level of services rendered. As described above, the fees are charged
as described and are not based on a share of capital gains of the funds of an advisory client.
All fees paid to Azzendo Wealth Advisors for investment advisory services are separate and distinct from the fees
and expenses charged by mutual funds or exchange traded funds to their shareholders. These fees and expenses
are described in each fund's prospectus. These fees generally include a management fee, other fund expenses,
and a possible distribution fee. If the fund also imposes sales charges, a client may pay an initial or deferred sales
charge.
A client could invest in a mutual fund directly, without the services of Azzendo Wealth Advisors. In that case, the
client would not receive the services provided by Azzendo Wealth Advisors which are designed, among other
things, to assist the client in determining which mutual fund or funds are most appropriate to each client's
financial condition and objectives. Accordingly, the client should review both the fees charged by the funds and
the fees charged by Azzendo Wealth Advisors to fully understand the total amount of fees to be paid by the client
and to thereby evaluate the advisory services being provided.
We strive to disclose all conflicts of interest between you, our firm, and the Associated Persons of our firm in this
Disclosure Brochure. If additional conflicts arise in the future, we will notify you in writing or supply you with an
updated Disclosure Brochure.
Negotiability of Fees
We allow Associated Persons servicing the account to negotiate the exact investment management fees within
the range disclosed in our Form ADV Part 2A Brochure. As a result, the Associated Person servicing your account
may charge more or less for the same service than another Associated Person of our firm. Further, our annual
investment management fee may be higher than that charged by other investment advisors offering similar
services/programs.
Billing on Cash Positions
The firm treats cash and cash equivalents as an asset class. Accordingly, unless otherwise agreed in writing, all
cash and cash equivalent positions (e.g., money market funds, etc.) are included as part of assets under
management for purposes of calculating the firm’s advisory fee. At any specific point in time, depending upon
perceived or anticipated market conditions/events (there being no guarantee that such anticipated market
conditions/events will occur), the firm may maintain cash and/or cash equivalent positions for defensive, liquidity,
or other purposes. While assets are maintained in cash or cash equivalents, such amounts could miss market
advances and, depending upon current yields, at any point in time, the firm’s advisory fee could exceed the
interest paid by the client’s cash or cash equivalent positions.
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Periods of Portfolio Inactivity
The firm has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment
advisory services, the firm will review client portfolios on an ongoing basis to determine if any changes are
necessary based upon various factors, including but not limited to investment performance, fund manager tenure,
style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s
investment objectives. Based upon these and other factors, there may be extended periods of time when the firm
determines that changes to a client’s portfolio are neither necessary nor prudent. Notwithstanding, unless
otherwise agreed in writing, the firm’s annual investment advisory fee will continue to apply during these periods,
and there can be no assurance that investment decisions made by the firm will be profitable or equal any specific
performance level(s).
Performance-Based Fees and Side-By-Side Management - Item 6
Performance-based fees are fees that are based on a share of capital gains or capital appreciation of a client’s
account. Side-by-side management refers to the practice of managing accounts that are charged performance-
based fees while at the same time managing accounts that are not charged performance-based fees. We do not
accept performance-based fees or participate in side-by-side management. Our fees are calculated as described
in the Fees and Compensation section above, and are not charged on the basis of a share of capital gains upon, or
capital appreciation of, the funds in your advisory account.
Types of Clients - Item 7
We generally offer investment advisory services to individuals, pension and profit-sharing plans and participants,
trusts, estates, charitable organizations, corporations, and other business entities.
Azzendo Wealth Advisors requires a minimum of $1,500,000 to open and maintain an advisory account. At our
sole discretion we may waive this requirement. This requirement can be met by combining two or more accounts
owned by you or related family members. The account minimum may be waived at the discretion of the firm.
Where the firm waives this account minimum, the annual fee will be set at 1.50%, subject to a $10,000 minimum
annual fee. The fee will not exceed 3% of assets under management.
Methods of Analysis, Investment Strategies and Risk of Loss - Item 8
We may use one or more of the following methods of analysis and/or investment strategies when providing
investment advice to you:
• Fundamental Analysis – involves analyzing individual companies and their industry groups, such as a
company’s financial statements, details regarding the company’s product line, the experience and
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expertise of the company’s management, and the outlook for the company’s industry. The resulting data
is used to measure the true value of the company’s stock compared to the current market value. The
primary risk of fundamental analysis is that information obtained may be incorrect and the analysis may
not provide an accurate estimate of earnings, which may be the basis for a stock’s value. If securities
prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable
performance.
• Technical Analysis – technical analysis is a technique that relies on the assumption that current market
data (such as charts of price, volume, and open interest) can help predict future market trends, at least
in the short term. It assumes that market psychology influences trading and can predict when stocks will
rise or fall. Technical trading models are mathematically driven based upon historical data and trends of
domestic and foreign market trading activity, including various industry and sector trading statistics
within such markets. Technical trading models, through mathematical algorithms, attempt to identify
when markets are likely to increase or decrease and identify appropriate entry and exit points. The
primary risk of technical trading models is that historical trends and past performance cannot predict
future trends, and there is no assurance that the mathematical algorithms employed are designed
properly, updated with new data, and can accurately predict future market, industry, and sector
performance.
We may use one or more of the following investment strategies when advising you on investments:
Long Term Purchases – securities held for over a year.
Short Term Purchases – securities held for less than a year.
Trading – securities are sold within 30 days.
•
•
•
• Covered Options – covered option is a strategy in which an investor writes an option contract while at
the same time owning an equivalent number of shares of the underlying stock.
•
• Margin Transactions – margin strategies allow an investor to purchase securities on credit and to borrow
on securities already in their custodial account. Interest is charged on any borrowed funds for the period
of time that the loan is outstanding.
Short Sales – short selling is the selling of a stock that the seller doesn't own. More specifically, a short
sale is the sale of a security that isn't owned by the seller, but that is promised to be delivered.
The investment advice provided along with the strategies suggested by Azzendo Wealth Advisors will vary
depending on each client’s specific financial situation and goals. This brief statement does not disclose all of the
risks and other significant aspects of investing in financial markets. In light of the risks, you should fully understand
the nature of the contractual relationship(s) into which you are entering and the extent of your exposure to risk.
Certain investing strategies may not be suitable for many members of the public. You should carefully consider
whether the strategies employed will be appropriate for you in light of your experience, objectives, financial
resources and other relevant circumstances.
Investing in securities involves risk of loss that Clients should be prepared to bear.
Recommendation of Particular Types of Securities
As disclosed under the “Advisory Business” section in this Brochure, we provide advice on various types of
securities and we do not necessarily recommend one particular type of security over another since each client
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has different needs and different tolerance for risk. Each type of security has its own unique set of risks associated
with it and it would not be possible to list here all of the specific risks of every type of investment. Even within
the same type of investment, risks can vary widely. However, in very general terms, the higher the anticipated
return of an investment, the higher the risk of loss associated with it.
General Investment Risk: All investments come with the risk of losing money. Investing involves substantial risks,
including complete possible loss of principal plus other losses and may not be suitable for many members of the
public. Investments, unlike savings and checking accounts at a bank, are not insured by the government to protect
against market losses. Different market instruments carry different types and degrees of risk and you should
familiarize yourself with the risks involved in the particular market instruments in which you intend to invest.
Loss of Value: There can be no assurance that a specific investment will achieve its investment objectives and
past performance should not be seen as a guide to future returns. The value of investments and the income
derived may fall as well as rise and investors may not recoup the original amount invested. Investments may also
be affected by any changes in exchange control regulation, tax laws, withholding taxes, international, political and
economic developments, and governmental economic or monetary policies.
Interest Rate Risk: Fixed income securities and funds that invest in bonds and other fixed income securities may
fall in value if interest rates change. Generally, the prices of debt securities rise when interest rates fall, and their
prices fall when interest rates rise. Longer-term debt securities are usually more sensitive to interest rate changes.
Credit Risk: Investments in bonds and other fixed income securities are subject to the risk that the issuer(s) may
not make required interest payments. An issuer suffering an adverse change in its financial condition could lower
the credit quality of a security, leading to greater price volatility of the security. A lowering of the credit rating of
a security may also offset the security's liquidity, making it more difficult to sell. Funds investing in lower quality
debt securities are more susceptible to these problems and their value may be more volatile.
Foreign Exchange Risk: Foreign investments may be affected favorably or unfavorably by exchange control
regulations or changes in the exchange rates. Changes in currency exchange rates may influence the share value,
the dividends or interest earned and the gains and losses realized. Exchange rates between currencies are
determined by supply and demand in the currency exchange markets, the international balance of payments,
governmental intervention, speculation, and other economic and political conditions. If the currency in which a
security is denominated appreciates against the US Dollar, the value of the security will increase. Conversely, a
decline in the exchange rate of the currency would adversely affect the value of the security.
Risks Associated with Investing in Equities: Investments in equities generally refers to buying shares of stocks by
an individual or firms in return for receiving a future payment of dividends and capital gains if the value of the
stock increases. There is an innate risk involved when purchasing a stock that it may decrease in value and the
investment may incur a loss.
Risks Associated with Investing in Mutual Funds: Mutual funds are professionally managed collective investment
systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments,
other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the
fund's investments in accordance with the fund's investment objective. While mutual funds generally provide
diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market,
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primarily invests in small cap or speculative companies, uses leverage (i.e., borrows money) to a significant
degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different
types of securities. The returns on mutual funds can be reduced by the costs to manage the funds. In addition,
while some mutual funds are “no load” and charge no fee to buy into, or sell out of, other types of mutual funds
do charge such fees which can also reduce returns.
Risks Associated with Investing in Exchange Traded Funds (ETF): Investing in stocks & ETF's carries the risk of
capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Investments in these
securities are not guaranteed or insured by the FDIC or any other government agency.
Risks Associated with Investing in Options: Transactions in options carry a high degree of risk. A relatively small
market movement will have a proportionately larger impact, which may work for or against the investor. The
placing of certain orders, which are intended to limit losses to certain amounts, may not be effective because
market conditions may make it impossible to execute such orders. Selling ("writing" or "granting") an option
generally entails considerably greater risk than purchasing options. Although the premium received by the seller
is fixed, the seller may sustain a loss well in excess of that amount. The seller will also be exposed to the risk of
the purchaser exercising the option and the seller will be obliged either to settle the option in cash or to acquire
or deliver the underlying investment. If the option is "covered" by the seller holding a corresponding position in
the underlying investment or a future on another option, the risk may be reduced.
Risks Associated with Investing in Alternative Investments: We may recommend to qualified clients the use of
alternative investments such as investments in real estate, private equity, or hedge funds. We may also
recommend a direct investment into a private company. Investments in such “alternative assets” are generally
illiquid, which will impair the ability of the client to exit such investments in times of adversity. Alternative
investments may utilize highly speculative investment techniques, including leverage, highly concentrated
portfolios, senior and/or subordinated securities positions, control positions and illiquid investments. In addition,
they may utilize derivative instruments to attempt to hedge the risks associated with certain of their investments.
Transactions in such derivative instruments may expose the assets of investment funds to the risks of material
financial loss, which in turn adversely affects the financial results of the client.
Risks Associated with Investing in Private Funds: Private Funds are not registered with the Securities and
Exchange Commission and may not be registered with any other regulatory authority. Accordingly, they are not
subject to certain regulatory restrictions and oversight to which other issuers are subject. There may be little
public information available about their investments and performance. Moreover, as sales of shares of private
investment companies are generally restricted to certain qualified purchasers, it could be difficult for a client to
sell its shares of a private investment company at an advantageous price and time. Since shares of private
investment companies are not publicly traded, it may be difficult to establish a fair value for the client’s
investment in these companies. Private Funds often engage in leveraging and other speculative investment
practices that increases the risk of investment loss. A Private Fund’s performance can be volatile. An investor
could lose all or a substantial portion of his or her investment. There may be no secondary market for the
investor’s interest in the fund. Private Funds can be highly illiquid and there may be restrictions on transferring
interests in the fund. Private Funds are not required to provide periodic pricing or valuation information to
investors. Private Funds may have complex tax structures. There may be delays in distributing important tax
information. Private Funds are not subject to the same regulatory requirements as mutual funds. Private Funds
often charge high fees. The fund's high fees and expenses may offset the fund's trading profits. Additional
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information about the risks associated with each Private Fund is available in the funds’ private placement
memorandum, and other subscription documents.
Concentrated Position Risk: Certain Associated Persons may recommend that clients concentrate account assets
in an industry or economic sector. In addition to the potential concentration of accounts in one or more sectors,
certain accounts may, or may be advised to, hold concentrated positions in specific securities. Therefore, at times,
an account may, or may be advised to, hold a relatively small number of securities positions, each representing a
relatively large portion of assets in the account. As a result, the account will be subject to greater volatility than
a more sector diversified portfolio. Investments in issuers within an industry or economic sector that experiences
adverse economic, business, political conditions or other concerns will impact the value of such a portfolio more
than if the portfolio’s investments were not so concentrated. A change in the value of a single investment within
the portfolio will affect the overall value of the portfolio and will cause greater losses than it would in a portfolio
that holds more diversified investments.
Preferred Securities Risk: Preferred Securities have similar characteristics to bonds in that preferred securities
are designed to make fixed payments based on a percentage of their par value and are senior to common stock.
Like bonds, the market value of preferred securities is sensitive to changes in interest rates as well as changes in
issuer credit quality. Preferred securities, however, are junior to bonds with regard to the distribution of corporate
earnings and liquidation in the event of bankruptcy. Preferred securities that are in the form of preferred stock
also differ from bonds in that dividends on preferred stock must be declared by the issuer’s board of directors,
whereas interest payments on bonds generally do not require action by the issuer’s board of directors, and
bondholders generally have protections that preferred stockholders do not have, such as indentures that are
designed to guarantee payments – subject to the credit quality of the issuer – with terms and conditions for the
benefit of bondholders. In contrast preferred stocks generally pay dividends, not interest payments, which can
be deferred or stopped in the event of credit stress without triggering bankruptcy or default. Another difference
is that preferred dividends are paid from the issue’s after-tax profits, while bond interest is paid before taxes.
Cybersecurity Risks: Our firm and our service providers are subject to risks associated with a breach in
cybersecurity. Cybersecurity is a generic term used to describe the technology, processes, and practices designed
to protect networks, systems, computers, programs, and data from cyber-attacks and hacking by other computer
users, and to avoid the resulting damage and disruption of hardware and software systems, loss or corruption of
data, and/or misappropriation of confidential information. In general, cyber-attacks are deliberate; however,
unintentional events may have similar effects. Cyber-attacks may cause losses to clients by interfering with the
processing of transactions, affecting the ability to calculate net asset value or impeding or sabotaging trading.
Clients may also incur substantial costs as the result of a cybersecurity breach, including those associated with
forensic analysis of the origin and scope of the breach, increased and upgraded cybersecurity, identity theft,
unauthorized use of proprietary information, litigation, and the dissemination of confidential and proprietary
information. Any such breach could expose our firm to civil liability as well as regulatory inquiry and/or action. In
addition, clients could be exposed to additional losses as a result of unauthorized use of their personal
information. While our firm has established a business continuity plan and systems designed to prevent cyber-
attacks, there are inherent limitations in such plans and systems, including the possibility that certain risks have
not been identified. Similar types of cyber security risks are also present for issuers of securities, investment
companies and other investment advisers in which we invest, which could result in material adverse
consequences for such entities and may cause a client's investment in such entities to lose value.
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Pandemic Risk: Large-scale outbreaks of infectious disease can greatly increase morbidity and mortality over a
wide geographic area, crossing international boundaries, and causing significant economic, social, and political
disruption. It is difficult to predict the long-term impact of such events because they are dependent on a variety
of factors including the global response of regulators and governments to address and mitigate the worldwide
effects of such events. Workforce reductions, travel restrictions, governmental responses and policies and
macroeconomic factors will negatively impact investment returns.
Recommendation of Other Advisers: In the event we recommend a third-party investment adviser to manage all
or a portion of your assets, we will advise you on how to allocate your assets among various classes of securities
or third-party investment managers, programs, or managed model portfolios. As such, we will primarily rely on
investment model portfolios and strategies developed by the third-party investment advisers and their portfolio
managers. If there is a significant deviation in characteristics or performance from the stated strategy and/or
benchmark, we may recommend changing models or replacing a third-party investment adviser. The primary risks
associated with investing with a third party is that while a particular third party may have demonstrated a certain
level of success in the past; it may not be able to replicate that success in future markets. In addition, as we do
not control the underlying investments in third party model portfolios, there is also a risk that a third party may
deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for
our clients. To mitigate this risk, we seek third parties with proven track records that have demonstrated a
consistent level of performance and success over time. A third party’s past performance is not a guarantee of
future results and certain market and economic risks exist that may adversely affect an account’s performance
that could result in capital losses in your account. Please refer to the third-party investment adviser’s advisory
agreements, Form ADV Brochure, and associated disclosure documents for details on their specific investment
strategies, methods of analysis, and associated risks.
Cryptocurrency Risk: Cryptocurrency (e.g., bitcoin and ether), often referred to as “virtual currency”, “digital
currency,” or “digital assets,” is designed to act as a medium of exchange. Cryptocurrency is an emerging asset
class. There are thousands of cryptocurrencies, the most well-known of which is bitcoin. Certain of the firm’s
clients may have exposure to bitcoin or another cryptocurrency, directly or indirectly through an investment such
as an ETF or other investment vehicles. Cryptocurrency operates without central authority or banks and is not
backed by any government. Cryptocurrencies may experience very high volatility and related investment vehicles
may be affected by such volatility. As a result of holding cryptocurrency, certain of the firm’s clients may also
trade at a significant premium or discount to NAV. Cryptocurrency is also not legal tender. Federal, state or foreign
governments may restrict the use and exchange of cryptocurrency, and regulation in the U.S. is still developing.
The market price of many cryptocurrencies, including bitcoin, has been subject to extreme fluctuations. If
cryptocurrency markets continue to be subject to sharp fluctuations, investors may experience losses if the value
of the client’s investments decline. Similar to fiat currencies (i.e., a currency that is backed by a central bank or a
national, supra-national or quasi-national organization), cryptocurrencies are susceptible to theft, loss and
destruction. Cryptocurrency exchanges and other trading venues on which cryptocurrencies trade are relatively
new and, in most cases, largely unregulated and may therefore be more exposed to fraud and failure than
established, regulated exchanges for securities, derivatives and other currencies. The SEC has issued a public
report stating U.S. federal securities laws require treating some digital assets as securities.
Cryptocurrency exchanges may stop operating or permanently shut down due to fraud, technical glitches, hackers
or malware. Due to relatively recent launches, most cryptocurrencies have a limited trading history, making it
difficult for investors to evaluate investments. Generally, cryptocurrency transactions are irreversible such that
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an improper transfer can only be undone by the receiver of the cryptocurrency agreeing to return the
cryptocurrency to the original sender. Digital assets are highly dependent on their developers and there is no
guarantee that development will continue or that developers will not abandon a project with little or no notice.
Third parties may assert intellectual property claims relating to the holding and transfer of digital assets, including
cryptocurrencies, and their source code. Any threatened action that reduces confidence in a network’s long-term
ability to hold and transfer cryptocurrency may affect investments in cryptocurrencies.
Many significant aspects of the U.S. federal income tax treatment of investments in cryptocurrency are uncertain
and an investment in cryptocurrency may produce income that is not treated as qualifying income for purposes
of the income test applicable to regulated investment companies. Certain cryptocurrency investments may be
treated as a grantor trust for U.S. federal income tax purposes, and an investment by the firm’s clients in such a
vehicle will generally be treated as a direct investment in cryptocurrency for tax purposes and “flow-through” to
the underlying investors.
Direct Indexing: Direct indexing strategies seek to replicate the performance of a market index by directly holding
the individual securities, or a representative sample of the individual securities, that make up the index. Direct
indexing can provide a more tax efficient means of investing, and allows for more customized investment
allocations, than investing in a fund or other commingled product that seeks to replicate the index. The potential
benefits of direct indexing, however, will not necessarily be realized if a client does not take advantage of tax
planning or impose account restrictions, such as account level security or sector-based restrictions or
customizations based on specific tax, Environmental, Social, and Governance or other preferences. Fees and
expenses for the direct indexing strategy in some cases will be higher than the fees and expenses associated with
alternative index products. Higher fees and expenses could adversely impact account performance. The size of
the account and the number of securities in the index the account seeks to replicate also limit the ability of the
account to replicate the index. As a result, the direct indexing strategy introduces the risk of tracking error relative
to the index and can cause a portfolio to underperform the index, including as a result of customization.
Artificial Intelligence ("AI") Risk: We may rely on programs and systems that utilize AI, machine learning,
probabilistic modeling, and other data science technologies ("AI Tools") when delivering our services. AI Tools are
also used to record and transcribe client meetings. Clients should note that AI Tools are highly complex, and are
known to have been flawed, hallucinate, reflect biases included in the data on which such tools are trained, be of
poor quality, or be otherwise harmful. AI Tools present Cybersecurity Risk. The U.S. and global legal and regulatory
environment relating to the use of AI Tools is uncertain and rapidly evolving, and could require changes in the
firm’s implementation of AI Tools and increase compliance costs and the risk of non-compliance. Further, the firm
may rely on AI Tools developed by third parties, and the firm has limited control over the accuracy and
completeness of such AI Tools. Clients who do not want us to record their meetings have the option to opt out at
the time of the meeting.
Environmental, Social, and Governance Investment Criteria Risk: If a portfolio is subject to certain
environmental, social and governance (ESG) investment criteria it may avoid purchasing certain securities for ESG
reasons when it is otherwise economically advantageous to purchase those securities, or may sell certain
securities for ESG reasons when it is otherwise economically advantageous to hold those securities. In general,
the application of the portfolio’s ESG investment criteria may affect the portfolio’s exposure to certain issuers,
industries, sectors and geographic areas, which may affect the financial performance of the portfolio, positively
or negatively, depending on whether these issuers, industries, sectors or geographic areas are in or out of favor.
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An adviser can vary materially from other advisers with respect to its methodology for constructing ESG portfolios
or screens, including with respect to the factors and data that it collects and evaluates as part of its process. As a
result, an adviser’s ESG portfolio or screen may materially differ from or contradict the conclusions reached by
other ESG advisers concerning the same issuers. Further, ESG criteria are dependent on data and are subject to
the risk that such data reported by issuers or received from third-party sources may be subjective, or it may be
objective in principle but not verified or reliable.
Structured Notes: Below are some specific risks related to the structured notes recommended by our firm:
•
Complexity: Structured notes are complex financial instruments. Clients should understand the reference
asset(s) or index(es) and determine how the note’s payoff structure incorporates such reference asset(s)
or index(es) in calculating the note’s performance. This payoff calculation may include leverage
multiplied by the performance of the reference asset or index, protection from losses should the
reference asset or index produce negative returns, and/or fees. Structured notes may have complicated
payoff structures that can make it difficult for clients to accurately assess their value, risk and potential
for growth through the term of the structured note. Determining the performance of each note can be
complex and this calculation can vary significantly from note to note depending on the structure. Notes
can be structured in a wide variety of ways. Payoff structures can be leveraged, inverse, or inverse-
leveraged, which may result in larger returns or losses. Clients should carefully read the prospectus for a
structured note to fully understand how the payoff on a note will be calculated and discuss these issues
with our firm.
•
•
•
• Market risk. Some structured notes provide for the repayment of principal at maturity, which is often
referred to as “principal protection.” This principal protection is subject to the credit risk of the issuing
financial institution. Many structured notes do not offer this feature. For structured notes that do not
offer principal protection, the performance of the linked asset or index may cause clients to lose some,
or all, of their principal. Depending on the nature of the linked asset or index, the market risk of the
structured note may include changes in equity or commodity prices, changes in interest rates or foreign
exchange rates, and/or market volatility.
Issuance price and note value: The price of a structured note at issuance will likely be higher than the fair
value of the structured note on the date of issuance. Issuers now generally disclose an estimated value
of the structured note on the cover page of the offering prospectus, allowing investors to gauge the
difference between the issuer’s estimated value of the note and the issuance price. The estimated value
of the notes is likely lower than the issuance price of the note to investors because issuers include the
costs for selling, structuring, and/or hedging the exposure on the note in the initial price of their notes.
After issuance, structured notes may not be re-sold on a daily basis and thus may be difficult to value
given their complexity.
Liquidity: The ability to trade or sell structured notes in a secondary market is often very limited, as
structured notes (other than exchange-traded notes known as ETNs) are not listed for trading on
securities exchanges. As a result, the only potential buyer for a structured note may be the issuing
financial institution’s broker-dealer affiliate or the broker-dealer distributor of the structured note. In
addition, issuers often specifically disclaim their intention to repurchase or make markets in the notes
they issue. Clients should, therefore, be prepared to hold a structured note to its maturity date or risk
selling the note at a discount to its value at the time of sale.
Credit risk: Structured notes are unsecured debt obligations of the issuer, meaning that the issuer is
obligated to make payments on the notes as promised. These promises, including any principal
protection, are only as good as the financial health of the structured note issuer. If the structured note
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issuer defaults on these obligations, investors may lose some, or all, of the principal amount they
invested in the structured notes as well as any other payments that may be due on the structured notes.
Disciplinary Information - Item 9
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events
that would be material to your evaluation of Azzendo Wealth Advisors’ advisory business or of the integrity of its
management personnel. We have no material history of legal or disciplinary events to report under this item.
Information regarding management persons of our firm and Azzendo Wealth Advisors can be found at
www.adviserinfo.sec.gov.
Other Financial Industry Activities or Affiliations - Item 10
Mr. Sanchez-Cifuentes is a non-producing manager for Alterra Home Loans a division of Alterra Group LLC
hereafter called "Alterra". Alterra will, if appropriate, recommend Azzendo Wealth Advisors to lending customers
in need of advisory services. Azzendo Wealth Advisors will, if appropriate, recommend Alterra to advisory clients
in need of lending services. Lending services provided by Alterra are separate and distinct from the advisory
services of Azzendo Wealth Advisors, and are provided for separate and typical compensation. There are no
referral fee arrangements between Azzendo Wealth Advisors and Alterra for these recommendations.
The compensation received by Mr. Sanchez-Cifuentes in his separate capacity as a non-producing manager is
separate and distinct from the advisory fees charged by Azzendo Wealth Advisors for portfolio management
services. No Azzendo Wealth Advisors client is obligated to use Alterra for any lending services and, conversely,
no lending customer is obligated to use the advisory services provided by Azzendo Wealth Advisors.
While Mr. Sanchez-Cifuentes endeavors at all times to put the interest of the clients first as part of Azzendo
Wealth Advisors’ fiduciary duty, clients should be aware that the potential receipt of additional compensation
itself creates a conflict of interest.
Recommendation of Other Advisors
We may recommend that you use a third-party advisor (TPA) as part of our asset allocation and investment
strategy. Azzendo Wealth Advisors will share in the compensation received by the TPA for managing your account.
The compensation arrangement presents a conflict of interest due to a financial incentive to recommend the
services of the third-party advisor. You are not required to use the services of any TPA we recommend.
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Item 11
Description of Our Code of Ethics
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Azzendo Wealth Advisors has adopted a Code of Ethics (the “Code”) to address investment advisory conduct. The
Code focuses primarily on fiduciary duty, personal securities transactions, insider trading, gifts, and conflicts of
interest. The Code includes Azzendo Wealth Advisors’ policies and procedures developed to protect client’s
interests in relation to the following topics:
▪
▪
▪
▪
▪
The duty at all times to place the interests of clients first;
The requirement that all personal securities transactions be conducted in such a manner as to be
consistent with the code of ethics.
The responsibility to avoid any actual or potential conflict of interest or misuse of an employee’s
position of trust and responsibility;
The fiduciary principle that information concerning the identity of security holdings and financial
circumstances of clients is confidential; and
The principle that independence in the investment decision-making process is paramount.
A copy of Azzendo Wealth Advisors’ Code of Ethics is available upon request to the Chief Compliance Officer at
Azzendo Wealth Advisors’ principal office address.
Personal Trading Practices
At times Azzendo Wealth Advisors and/or its Advisory Representatives may take positions in the same securities
as clients, which may pose a conflict of interest with clients. Azzendo Wealth Advisors and its Advisory
Representatives will generally be “last in” and “last out” for the trading day when trading occurs in close proximity
to client trades. We will not violate our fiduciary responsibilities to our clients. Front running (trading shortly
ahead of clients) is prohibited. Should a conflict occur because of materiality (i.e., a thinly traded stock), disclosure
will be made to the client(s) at the time of trading. Incidental trading not deemed to be a conflict (i.e., a purchase
or sale which is minimal in relation to the total outstanding value, and as such would have negligible effect on the
market price), would not be disclosed at the time of trading.
Brokerage Practices - Item 12
We recommend and request our clients to implement trades and maintain custody of assets through the Schwab
Institutional division of Charles Schwab & Co., Inc. (“Schwab”). Schwab is an independent and unaffiliated SEC-
registered broker-dealer and member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities
Investor Protection Corporation (“SIPC”). We have entered an Agreement with Schwab to recommend that you
establish brokerage accounts with either of them to maintain custody of your assets and to effect trades for your
accounts.
We are not affiliated with Schwab. Our Investment Adviser Representatives are not registered representatives of
Schwab and do not receive commissions or other compensation from recommending these services.
Research and Other Soft Dollar Benefits Received from Schwab
Schwab Institutional provides us with access to its institutional trading and operational services, which are
typically not available to Schwab retail investors. The services generally are available at no charge so long as we
maintain a minimum of $10 million of account assets with them. Schwab Institutional services include research,
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brokerage, custody, access to mutual funds and other investments that are otherwise available only to
institutional investors. Schwab Institutional also makes available other products and services that benefit the
administration of our accounts. These include software, client account access technology, trade confirmations
and account statements, trade execution and aggregated trade order allocation technology, back-office support,
recordkeeping, and client reporting. Schwab Institutional also provides us with business enterprise services.
These services include consulting, publications and practice management presentations, information technology,
business succession, regulatory compliance, and marketing information and best practices. Schwab may make
available, arrange and/or pay independent third parties for these types of services. Schwab Institutional may
discount, waive or pay all or part of the third party fees for services provided. There are no contingencies or
business volume requirements (assets in custody or trading) associated with the availability of the foregoing
products and services.
Although not considered “soft dollar” compensation, we may receive benefits from Schwab for research services
that include reports, software, and institutional trading support. See the Schwab disclosure above.
We understand our duty for best execution and consider all factors in making recommendations to you. The
research services received from Schwab may be useful in servicing you. While we may not always obtain the
lowest commission rate, we believe the rate is reasonable relative to the value of the brokerage and research
services provided.
Brokerage for Client Referrals
We do not receive client referrals from broker-dealers and custodians in which we have an institutional advisory
arrangement. Also, we do not receive other benefits from a broker-dealer in exchange for client referrals.
Directed Brokerage
The client may direct brokerage to a specified broker-dealer other than the firm recommended by Azzendo
Wealth Advisors. It is up to the client to negotiate the commission rate, as Azzendo Wealth Advisors will not. The
client may not be able to negotiate the most competitive rate. As a result, the client may pay more than the rate
available through the broker-dealer used by Azzendo Wealth Advisors. In client directed brokerage
arrangements, the client may not be able to participate in aggregated (“blocked”) trades, which may help reduce
the cost of execution. Where the client does not otherwise designate a broker-dealer, Azzendo Wealth Advisors
recommends a broker-dealer with competitive commission rates.
Trade Aggregation
While individual client advice is provided to each account, client trades may be executed as a block trade. Azzendo
Wealth Advisors encourages its existing and new clients to use Schwab. Only accounts in the custody of Schwab
would have the opportunity to participate in aggregated securities transactions. All trades using Schwab will be
aggregated and done in the name Azzendo Wealth Advisors. The executing broker will be informed that the
trades are for the account of Azzendo Wealth Advisors’ clients and not for Azzendo Wealth Advisors itself. No
advisory account within the block trade will be favored over any other advisory account, and thus, each account
will participate in an aggregated order at the average share price and receive the same commission rate. The
aggregation should, on average, reduce slightly the costs of execution, and Azzendo Wealth Advisors will not
aggregate a client's order if in a particular instance Azzendo Wealth Advisors believes that aggregation would
cause the client's cost of execution to be increased. Schwab will be notified of the amount of each trade for each
account. Azzendo Wealth Advisors and/or its Associated Persons may participate in block trades with clients, and
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may also participate on a pro rata basis for partial fills, but only after the determination has been made that
clients will receive fair and equitable treatment.
Review of Accounts - Item 13
Portfolio Management Account Reviews
Amaury Sanchez-Cifuentes, Member, or the Associated Person assigned to the account, monitor Client accounts
on a continuous basis and conducts account reviews at least quarterly.
Additional reviews may be offered in certain circumstances. Triggering factors that may stimulate additional
reviews include, but are not limited to, changes in economic conditions, changes in the Client’s financial situation
or investment objectives, or a Client’s request.
A financial plan is a snapshot in time and no ongoing reviews are conducted. We recommend clients engage us
on an annual basis to update the financial plan.
Azzendo Wealth Advisors provides clients with a written quarterly account performance/holdings report. The
report may be delivered electronically. Additionally, Clients will receive statements directly from their account
custodian(s) on at least a quarterly basis.
Client Referrals and Other Compensation - Item 14
Apart from the additional benefits received from Schwab, Azzendo Wealth Advisors does not receive economic
benefits, sales awards or other prizes from third parties in exchange for providing investment advice or other
advisory services to our clients.
Azzendo Wealth Advisors does not currently have any Client referral or compensation agreements with outside
parties.
Custody - Item 15
Azzendo Wealth Advisors is deemed to have custody of client funds because of the fee deduction authority
granted by the client in the Advisory Agreement.
Clients will receive account statements at least quarterly from the broker-dealer or other qualified custodian.
Clients are urged to compare custodial account statements for accuracy. Minor variations may occur because of
reporting dates, accrual methods of interest and dividends, and other factors. The custodial statement is the
official record of your account for tax purposes.
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Investment Discretion - Item 16
Azzendo Wealth Advisors offers Portfolio Management Services to its advisory clients on both a discretionary and
non-discretionary basis. Azzendo Wealth Advisors will manage client accounts on a discretionary basis if the client
has granted discretionary authority in the client Advisory Agreement. Discretionary authority extends to the type
and amount of securities to be bought and sold and do not require advance client approval. However, Azzendo
Wealth Advisors does not have the ability to withdraw funds or securities from the client’s account.
In a non-discretionary account, an Associated Person of Azzendo Wealth Advisors recommends the purchase or
sale of securities for review and approval by their clients. Azzendo Wealth Advisors will only purchase or sell
securities which have been approved by clients in advance.
If you wish, you may limit our discretionary authority by, for example, setting a limit on the type of securities that
can be purchased for your account. Simply provide us with your restrictions or guidelines in writing. Please refer
to the “Advisory Business” section in this Brochure for more information on our discretionary management
services.
Voting Client Securities - Item 17
Proxy Voting
Azzendo Wealth Advisors does not vote proxies. It is the client's responsibility to vote proxies. Clients will receive
proxy materials directly from the custodian. Questions about proxies may be made via the contact information
on the cover page.
Financial Information - Item 18
Our firm does not have any financial conditions or impairments that would prevent us from meeting our
contractual commitments to you. We do not take physical custody of client funds or securities, or serve as trustee
or signatory for client accounts, and, we do not require the prepayment of more than $1,200 in fees six or more
months in advance. Therefore, we are not required to include a financial statement with this brochure.
Requirements of State-Registered Advisers - Item 19
This section is not applicable because our firm is SEC registered.
Azzendo Wealth Advisors
Form ADV Part 2A Brochure
Page 24
Additional Information
Class Action Lawsuits
From time to time, securities held in the accounts of clients will be the subject of class action lawsuits. Azzendo
Wealth Advisors has no obligation to determine if securities held by the client are subject to a pending or resolved
class action lawsuit. It also has no duty to evaluate a client’s eligibility or to submit a claim to participate in the
proceeds of a securities class action settlement or verdict. Furthermore, the firm has no obligation or
responsibility to initiate litigation to recover damages on behalf of clients who may have been injured as a result
of actions, misconduct, or negligence by corporate management of issuers whose securities are held by clients.
Where the firm receives written or electronic notice of a class action lawsuit, settlement, or verdict affecting
securities owned by a client, it will forward all notices, proof of claim forms, and other materials, to the client.
Electronic mail is acceptable where appropriate, and the client has authorized contact in this manner.
Confidentiality
Azzendo Wealth Advisors views protecting its customers’ private information as a top priority and, pursuant to
the requirements of the Gramm-Leach-Bliley Act, the firm has instituted policies and procedures to ensure that
customer information is kept private and secure.
Azzendo Wealth Advisors does not disclose any nonpublic personal information about its customers or former
customers to any nonaffiliated third parties, except as permitted by law. In the course of servicing a client account,
Azzendo Wealth Advisors may share some information with its service providers, such as transfer agents,
custodians, broker-dealers, accountants, and lawyers.
Azzendo Wealth Advisors restricts internal access to nonpublic personal information about its clients to those
employees who need to know that information in order to provide products or services to the client. Azzendo
Wealth Advisors maintains physical and procedural safeguards that comply with state and federal standards to
guard a client’s nonpublic personal information and ensure its integrity and confidentiality. As emphasized above,
it has always been and will always be the firm’s policy never to sell information about current or former customers
or their accounts to anyone. It is also the firm’s policy not to share information unless required to process a
transaction, at the request of the client, or as required by law.
A copy of the firm’s privacy policy notice will be provided to each client prior to, or contemporaneously with, the
execution of the Advisory Agreement. If you have any questions on this policy, please contact Amaury Sanchez-
Cifuentes, Managing Member at (954) 986-0633.