Overview
- Total Firm Assets
- $130 million
- Average High-Net-Worth Client Portfolio Size
- $6.4 million
- Stated Minimum Account Size
- $3,000,000
Fee Disclosure
PEARL WEALTH DISCLOSURE BROCHURE AND BROCHURE SUPPLEMENT
| Min | Max | Disclosed Annual Rate |
|---|---|---|
| $0 | $2,000,000 | 1.00% |
| $2,000,001 | $4,000,000 | 0.75% |
| $4,000,001 | and above | 0.50% |
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 | $40,000 | 0.80% |
| $10 million | $65,000 | 0.65% |
| $50 million | $265,000 | 0.53% |
| $100 million | $515,000 | 0.52% |
Actual fees may vary; other investment costs may apply.
Clients
- High-Net-Worth Share of Firm Assets
- 84.13%
- Number of High-Net-Worth Clients
- 17
- Total Client Accounts
- 102
- Discretionary Accounts
- 102
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Investment Advisor Selection
Regulatory Filings
- SEC CRD Number
- 296811
Additional Brochure: PEARL WEALTH DISCLOSURE BROCHURE AND BROCHURE SUPPLEMENT (2026-08-24)
View Document Text
Pearl Wealth LLC
Form ADV Part 2A – Disclosure Brochure
Effective: August 24, 2026
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business
practices of Pearl Wealth LLC (“Pearl Wealth” or the “Advisor”). If you have any questions about the content of
this Disclosure Brochure, please contact the Advisor at (303) 250-0036.
Pearl Wealth is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The
information in this Disclosure Brochure has not been approved or verified by the U.S. Securities and Exchange
Commission or by any state securities authority. Registration of an investment advisor does not imply any
specific level of skill or training. This Disclosure Brochure provides information about Pearl Wealth to assist you
in determining whether to retain the Advisor.
Additional information about Pearl Wealth and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching for the Advisor’s firm name or CRD# 296811.
Pearl Wealth LLC
2101 Pearl Street, Boulder, CO 80302
Phone: (303) 250-0036
http://pearlwealth.net
Item 2 – Material Changes
Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure
Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s
business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory
Persons of Pearl Wealth. For convenience, the Advisor has combined these documents into a single disclosure
document.
Pearl Wealth believes that communication and transparency are the foundation of its relationship with clients and
will continually strive to provide you with complete and accurate information at all times. Pearl Wealth
encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you
may have with the Advisor.
Material Changes
The following material changes have been made to this Disclosure Brochure since the annual amendment filing
on March 5, 2026.
• Effective April 1, 2026, the Advisor has moved primary address to 2101 Pearl Street, Boulder, CO
80302.
• The Advisor has updated its billing fee schedule. Please see Item 5 for additional information.
• The Advisor has amended its fixed fee language. Please see item 5 for additional information
• The Advisor has amended its minimum relationship size language. Please item 7 for additional
information.
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in our business practices,
changes in regulations or routine annual updates as required by the securities regulators. This complete
Disclosure Brochure or a Summary of Material Changes shall be provided to each Client annually and if a
material change occurs.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 296811. You
may also request a copy of this Disclosure Brochure at any time, by contacting the Advisor at (303) 250-0036.
Pearl Wealth LLC
2101 Pearl Street, Boulder, CO 80302
Phone: (303) 250-0036 | http://pearlwealth.net
Page 2
Item 3 – Table of Contents
Item 1 – Cover Page ............................................................................................................................................... 1
Item 2 – Material Changes ..................................................................................................................................... 2
Item 3 – Table of Contents .................................................................................................................................... 3
Item 4 – Advisory Services ................................................................................................................................... 4
Item 5 – Fees and Compensation ......................................................................................................................... 6
Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 8
Item 7 – Types of Clients ....................................................................................................................................... 8
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .......................................................... 9
Item 9 – Disciplinary Information ....................................................................................................................... 10
Item 10 – Other Financial Industry Activities and Affiliations ......................................................................... 10
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 11
Item 12 – Brokerage Practices ............................................................................................................................ 11
Item 13 – Review of Accounts ............................................................................................................................ 12
Item 14 – Client Referrals and Other Compensation ........................................................................................ 13
Item 15 – Custody ................................................................................................................................................ 13
Item 16 – Investment Discretion ......................................................................................................................... 14
Item 17 – Voting Client Securities ...................................................................................................................... 14
Item 18 – Financial Information .......................................................................................................................... 14
Form ADV Part 2B – Brochure Supplement ...................................................................................................... 15
Privacy Policy ...................................................................................................................................................... 18
Pearl Wealth LLC
2101 Pearl Street, Boulder, CO 80302
Phone: (303) 250-0036 | http://pearlwealth.net
Page 3
Item 4 – Advisory Services
Pearl Wealth LLC (“Pearl Wealth” or the “Advisor”) is a registered investment advisor with the SEC. Pearl Wealth
is organized as a limited liability company (“LLC”) under the laws of Colorado. Pearl Wealth was formed under
the business name DH2 Capital, LLC in April 2018 and changed its legal name to Pearl Wealth LLC in June
2018. Pearl Wealth became a registered investment advisor in June 2018. The Principal Officer of the Advisor is
Debra Herz Huttner (President and Chief Compliance Officer). This Disclosure Brochure provides information
regarding the qualifications, business practices, and the advisory services provided by Pearl Wealth.
Pearl Wealth offers investment advisory services to individuals, high net worth individuals, families, trusts,
estates, foundations, retirement plans, and charitable organizations (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. Pearl Wealth’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For
more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in
Client Transactions and Personal Trading.
Investment Management Services
Pearl Wealth provides discretionary investment management and related advisory services for its Clients. Pearl
Wealth works closely with each Client to identify their investment goals and objectives as well as risk tolerance
and financial situation in order to create a portfolio strategy. Pearl Wealth will then construct a portfolio,
consisting primarily of exchange-traded funds (“ETFs”) and diversified mutual funds (including passive and
active) to achieve the Client’s investment goals. The Advisor may also utilize other types of investments, such as
alternatives, to meet the needs of Clients. The Advisor may retain other types of investments from the Client’s
legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified
between the Advisor and the Client.
Pearl Wealth’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate
positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. Pearl Wealth, in connection with the Client, will develop an Investment Policy Statement (“IPS”) that
describes the Client’s requirements and the Advisor’s approach. The Advisor will construct, implement and
monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the
Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be
held in their respective portfolio, subject to acceptance by the Advisor. Pearl Wealth evaluates and selects
investments for inclusion in Client portfolios only after applying its internal due diligence process. Pearl Wealth
may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Pearl Wealth may
recommend specific positions to increase sector, asset class or cash weightings. Pearl Wealth may recommend
selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or
sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the positions in
the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed
unacceptable for the Client’s risk tolerance.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over
the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based
account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a
new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll
over a retirement account to an account managed by the Advisor.
Pearl Wealth LLC
2101 Pearl Street, Boulder, CO 80302
Phone: (303) 250-0036 | http://pearlwealth.net
Page 4
Use of Independent Managers
Pearl Wealth may recommend that a Client utilize one or more unaffiliated investment managers or investment
platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio. In such
instances, the Client may be required to authorize and enter into an advisory agreement with the Independent
Manager[s] that defines the terms by which the Independent Manager[s] will provide investment management
and related services. The Advisor may also assist in the development of the initial policy recommendations and
managing the ongoing Client relationship. The Advisor will perform initial and ongoing oversight and due
diligence over the selected Independent Manager[s] to ensure the Independent Managers’ strategies and target
allocations remain aligned with its clients’ investment objectives and overall best interests. The Client, prior to
entering into an agreement with unaffiliated investment manager[s] or investment platforms, will be provided with
the Independent Manager's Form ADV 2A (or a brochure that makes the appropriate disclosures). Clients may
also elect to utilize an Independent Manager to provide due diligence and monitoring services regarding private
investment offerings. The Advisor in these engagements will contract directly with the Independent Manager on
the Client’s behalf.
At no time will Pearl Wealth accept or maintain custody of a Client’s funds or securities, except for the limited
authority as outlined in Item 15 – Custody. All Client assets will be managed within their designated account[s] at
the Custodian, pursuant to the Client investment advisory agreement. Please see Item 12 – Brokerage Practices.
Prior to engaging Pearl Wealth to provide investment advisory services, each Client is required to enter into one
or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the
Advisor and the Client. These services include:
• Establishing an Investment Strategy – Pearl Wealth, in connection with the Client, will develop an IPS
that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Pearl Wealth will develop a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – Pearl Wealth will develop a portfolio for the Client that is intended to meet the
stated goals and objectives of the Client.
•
Investment Management and Supervision – Pearl Wealth will provide investment management and
ongoing oversight of the Client’s investment portfolio.
Financial Planning Services
Pearl Wealth also provides a variety of financial planning and consulting services to Clients. Services may be
offered as a standalone engagement or included under an overall investment advisory relationship. Services are
offered in several areas relating to a Client’s financial situation, depending on their goals, objectives and financial
situation. Generally, such financial planning services involve preparing a formal financial plan or rendering a
specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting
may encompass one or more areas of need, including but not limited to, investment planning, retirement
planning, personal savings, education savings and other areas of a Client’s financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs.
Pearl Wealth may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique
situation. For certain financial planning engagements, the Advisor will provide a summary of the Client’s financial
situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not
provide a written summary. Plans or consultations are typically completed within six months of contract date,
assuming all information and documents requested are provided promptly.
Financial planning and consulting recommendations may pose a conflict between the interests of the Advisor and
the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the
Pearl Wealth LLC
2101 Pearl Street, Boulder, CO 80302
Phone: (303) 250-0036 | http://pearlwealth.net
Page 5
Advisor for investment management services or to increase the level of investment assets with the Advisor, as it
would increase the advisory fees paid to the Advisor. Clients have the right to choose whether to implement any
recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects
to act on any of the recommendations made by the Advisor, the Client has the right to choose whether to
implement the transaction through the Advisor or through another advisory firm or professional.
Prior to engaging Pearl Wealth to provide financial planning services, each Client is required to enter into an
agreement with the Advisor that defines the terms, conditions, authority and responsibilities of the Advisor and
the Client.
Retirement Plan Advisory Services
Pearl Wealth provides 3(21) retirement plan advisory services on behalf of the retirement plans (each a “Plan”)
and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist
the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is
customized to the needs of the Plan and Plan Sponsor. Services generally include:
Investment Policy Statement (“IPS”) Design and Monitoring
Investment Monitoring
• Vendor Analysis
•
•
• Ongoing Investment Recommendation and Assistance
These services are provided by Pearl Wealth serving in the capacity as a fiduciary under the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2),
the Plan Sponsor is provided with a written description of Pearl Wealth’s fiduciary status, the specific services to
be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement.
Pearl Wealth does not manage or place Client assets into a wrap fee program. Investment management services
are provided directly by Pearl Wealth.
Assets Under Management - As of April 17, 2026, Pearl Wealth manages approximately $129,900,328 in
discretionary assets.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or
more written agreements with the Advisor.
Investment Management Services
Investment advisory fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the
investment advisory agreement. Fees are based on the market value of the Client’s account[s] on the last business
day of the prior calendar quarter. The market value of assets may include assets under management which are
held away from the Client’s Custodian. The investment advisory fee in the first quarter of service is prorated from
the inception date of the account[s] to the end of the first quarter.
The Advisor’s fees are based on the following schedule:
Assets Under Management
Up to $2,000,000
Next $2,000,000
Over $4,000,000
Annual Rate (%)
1.00%
0.75%
0.50%
Clients will incur a minimum annual fee of $10,000. The minimum fee is negotiable at the sole discretion of the
Advisor. The Advisor at its discretion may reduce and/or waive the minimum annual fee. Please see Item 7.
Unless otherwise instructed, the Client’s fees will take into consideration the aggregate assets under management
Pearl Wealth LLC
2101 Pearl Street, Boulder, CO 80302
Phone: (303) 250-0036 | http://pearlwealth.net
Page 6
with Advisor. All securities held in accounts managed by Pearl Wealth will be independently valued by the
Custodian. Certain clients of Pearl Wealth may be billed according to a prior fee schedule. Pearl Wealth will
conduct periodic reviews of the Custodian’s valuation to ensure accurate billing.
The Advisor’s fee is exclusive of, and in addition to, brokerage fees, transaction fees, and other related costs and
expenses, which may be incurred by the Client. However, the Advisor shall not receive any portion of these
commissions, fees, and costs charged by the Custodian.
Investment advisory fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at
the Custodian. The Custodian will then forward the investment advisory fee to the Advisor or deposit the fee into an
account designated by the Advisor. The Advisor shall send an invoice to the Custodian indicating the amount of the
fees to be deducted from the Client’s account[s] at the beginning of each quarter. The amount due is calculated by
applying the quarterly rate (annual rate divided by 4) to the total assets under management with Pearl Wealth on
the last business day of the prior calendar quarter. Clients will be provided with a statement, at least quarterly, from
the Custodian reflecting deduction of the investment advisory fee. It is the responsibility of the Client to verify the
accuracy of these fees as listed on the Custodian’s brokerage statement as the Custodian does not assume this
responsibility. Clients provide written authorization permitting Pearl Wealth to be paid directly from their account[s]
held by the Custodian as part of the investment advisory agreement and separate account forms provided by the
Custodian.
Pearl Wealth is compensated for its services in advance of the quarter in which investment advisory services are
rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance written
notice to the other party. The Client may also terminate the investment advisory agreement within five (5) business
days of signing the Advisor’s agreement without fee or penalty to the Client. Upon termination, the Advisor will
promptly refund any unearned, prepaid fees. The Client’s investment advisory agreement with the Advisor may not
be assigned without the Client’s prior consent.
Use of Independent Managers
For Clients referred by the Advisor to an Independent Manager, the Client’s fee will be separately billed or deducted
from the Client’s account[s] by the Independent Manager and the Advisor.
In the event that a Client should wish to terminate their relationship with the Independent Manager, the terms for
termination will be set forth in the respective agreements between the Client and that Independent Manager. Pearl
Wealth will assist the Client with the termination and transition as appropriate.
For Clients engaging with Advisor for Independent Manager due diligence and monitoring of private investments,
the fee is determined initially based on the services to be provided and annually thereafter. These fees are charged
quarterly in advance and deducted from the Client’s custodial account. The Advisor after deducting the fees for this
service will pay the Independent Manager directly. The Advisor does not retain any portion of the fees collected for
this service. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the
point of termination and such fees will be due and payable by the Client. The Advisor will refund any unearned,
prepaid fees from the effective date of termination to the end of the quarter.
Financial Planning Services
Clients may be offered financial planning services annually as part of the investment management fee. Planning
services outside the scope of the investment management fee will be billed at the Advisor’s hourly rate of $750 per
hour. Clients with less than $3 million under management may receive planning as part of their agreement, or they
may be offered financial planning services at an hourly rate or as a fixed engagement fee. Fixed fee engagements
are dependent upon variables including the specific needs of the Client, scope, complexity, estimated time,
duration, and personnel involved to provide services to you, among other factors Pearl Wealth deems relevant. For
any planning engagements where a fee will be charged, an estimate for total hours and/or costs will be determined
prior to engaging for these services.
Financial planning fees are invoiced by the Advisor upon completion of the engagement deliverable[s] and are due
upon receipt. Either party may terminate the financial planning agreement, at any time, by providing advance written
Pearl Wealth LLC
2101 Pearl Street, Boulder, CO 80302
Phone: (303) 250-0036 | http://pearlwealth.net
Page 7
notice to the other party. The Client may also terminate the financial planning agreement within five (5) business
days of signing the Advisor’s agreement without fee or penalty to the Client. After the five-day period, the Client will
incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and
payable by the Client. Upon termination, the Client shall be billed for actual hours worked or the percentage of the
engagement scope completed by the Advisor for fixed fee engagements. The Client’s financial planning agreement
with the Advisor may not be assigned without the Client’s prior consent.
Retirement Plan Advisory Services
Retirement plan advisory fees are charged an annual asset-based fee of up to 1%, billed quarterly, in advance of
each calendar quarter, pursuant to the terms of the retirement plan advisory agreement. Fees are based on the
market value of assets in the Plan at the end of the prior quarter. Fees may be directly invoiced to the Plan Sponsor
or deducted from the assets of the Plan, depending on the terms of the retirement plan advisory agreement.
Pearl Wealth is compensated for its services in advance of the quarter in which retirement plan advisory services
are rendered. Either party may terminate the retirement plan advisory agreement, at any time, by providing advance
written notice to the other party. The Client may also terminate the retirement plan advisory agreement within five
(5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client
will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due
and payable by the Client. The Advisor will refund any unearned, prepaid fees from the effective date of termination
to the end of the quarter. The Client’s retirement plan advisory agreement[s] with the Advisor is non-transferable
without the Client’s prior consent.
Other Costs
Clients may incur certain fees or charges imposed by third parties, other than Pearl Wealth, in connection with
investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities
execution fees charged by the Custodian, if applicable. The Advisor's recommended Custodian does not charge
securities transaction fees for ETF and equity trades in Client accounts but typically charges for mutual funds and
other types of investments. The fees charged by Pearl Wealth are separate and distinct from these custody and
execution fees. In addition, all fees paid to Pearl Wealth for investment advisory services are separate and
distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees
and expenses are described in each fund’s prospectus. These fees and expenses relate to management fees for
the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a
possible distribution fee. A Client may be able to invest in these products directly, without the services of Pearl
Wealth, but would not receive the services provided by Pearl Wealth which are designed, among other things, to
assist the Client in determining which products or services are most appropriate for each Client’s financial
situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees
charged by Pearl Wealth to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage
Practices for additional information.
Pearl Wealth does not receive any compensation for securities transactions in any Client account, other than the
investment advisory fees noted above.
Item 6 – Performance-Based Fees and Side-By-Side Management
Pearl Wealth does not charge performance-based fees for its investment advisory services and therefore does
not engage in side-by-side management.
Item 7 – Types of Clients
Pearl Wealth offers investment advisory services to individuals, high net worth individuals, families, trusts,
estates, foundations, retirement plans, and charitable organizations. Pearl Wealth generally requires a minimum
relationship size of $3,000,000 to effectively implement its investment process. This minimum may be waived at
the Advisor’s sole discretion.
Pearl Wealth LLC
2101 Pearl Street, Boulder, CO 80302
Phone: (303) 250-0036 | http://pearlwealth.net
Page 8
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Research and analysis from Pearl Wealth is derived from numerous sources, including financial media
companies, third-party research materials, Internet sources, and review of company activities, including annual
reports, prospectuses, press releases and research prepared by others. Pearl Wealth primarily employs a
fundamental analysis method in developing investment strategies for its Clients.
Fundamental analysis utilizes economic and business indicators as investment selection criteria. These criteria
are generally ratios and trends that may indicate the overall strength and financial viability of the entity being
analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment
with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential
investment, it does not guarantee that the investment will increase in value. Assets meeting the investment
criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The
Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate.
More details on the Advisor’s review process are included below in Item 13 – Review of Accounts.
As noted above, Pearl Wealth generally employs a long-term investment strategy for its Clients, as consistent
with their financial goals. Pearl Wealth will typically hold all or a portion of a security for more than a year, but
may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At
times, Pearl Wealth may also buy and sell positions that are more short-term in nature, depending on the goals
of the Client and/or the fundamentals of the security, sector or asset class. Clients should be aware that buying
and selling of positions that are more short-term in nature may result in additional securities transactions costs,
which may reduce the amount of returns on the investments.
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value.
Clients should be prepared to bear the potential risk of loss. Pearl Wealth will assist Clients in determining
an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no
guarantee that a Client will meet their investment goals.
While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that
the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis
may lose value and may have negative investment performance. The Advisor monitors these economic
indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s
review process are included below in Item 13 – Review of Accounts.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the
Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals
or other factors that may affect this analysis. Following are some of the risks associated with the Advisor’s
strategies.
The risks associated with a particular strategy are provided to each Client in advance of investing Client
accounts. The Advisor typically recommends long-term investment strategies.
The following are some investment risks the Client should understand and consider:
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
Pearl Wealth LLC
2101 Pearl Street, Boulder, CO 80302
Phone: (303) 250-0036 | http://pearlwealth.net
Page 9
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs
will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading
risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large
bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and
may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF
purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a
short time later.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of
the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a
mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the
same price as a mutual fund purchased later that same day.
Alternative Investments (Limited Partnerships)
The performance of alternative investments (including limited partnerships, BDCs and other) can be volatile and
may have limited liquidity. An investor could lose all or a portion of their investment. Such investments often have
concentrated positions and investments that may carry higher risks. Client should only have a portion of their
assets in these investments.
Real Estate Investment Trusts (“REITs”)
Investing in Real Estate Investment Trusts (“REITs”) involves certain distinct risks in addition to those risks
associated with investing in the real estate industry in general. For Example, equity REITs may be affected by
changes in the value of the underlying property owned by the REITs, while mortgage REITs may be affected by
the quality of credit extended. REITs are subject to heavy cash flow dependency, default by borrowers and self-
liquidation. REITs, especially mortgage REITs, are also subject to interest rate risk (i.e., as interest rates rise, the
value of the REIT may decline).
Interest-rate Risk
Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise,
yields on existing bonds become less attractive, causing their market values to decline.
Digital Assets Risks
Digital assets are highly speculative and volatile investments that may become illiquid at any time. Digital assets
are loosely regulated. A Client could lose the entire value of their investment in digital assets and is only suitable
for Clients with a high risk tolerance.
Past performance is not a guarantee of future returns. Investing in securities and other investments
involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to
discuss these risks with the Advisor.
Item 9 – Disciplinary Information
There are no legal, regulatory or disciplinary events involving Pearl Wealth or its owner. Pearl Wealth
values the trust you place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence
on any advisor or service provider that the Client engages. The backgrounds of the Advisor and its Advisory
Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by
searching with the Advisor’s firm name or CRD# 296811.
Item 10 – Other Financial Industry Activities and Affiliations
The sole business of Pearl Wealth is to provide advisory services to its Clients. Neither Pearl Wealth nor its
owner are involved in other business endeavors. Pearl Wealth does not maintain any affiliations with other firms,
other than contracted service providers to assist with the servicing of its Client’s accounts.
Pearl Wealth LLC
2101 Pearl Street, Boulder, CO 80302
Phone: (303) 250-0036 | http://pearlwealth.net
Page 10
Use of Independent Managers
As noted in Item 4, the Advisor may select Independent Managers to assist with the implementation of a Client’s
investment strategy. In such arrangements, the Advisor and Independent Manager will collect their investment
advisory fees individually.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
Pearl Wealth has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to
each Client. This Code applies to all persons associated with Pearl Wealth (“Supervised Persons”). The Code
was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to the
Client. Pearl Wealth and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each
Client. It is the obligation of Pearl Wealth’s Supervised Persons to adhere not only to the specific provisions of
the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address
employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (303) 250-
0036.
Pearl Wealth allows Supervised Persons to purchase or sell the same securities that may be recommended to
and purchased on behalf of Clients. Pearl Wealth does not act as principal in any transactions. In addition, the
Advisor does not act as the general partner of a fund or advise an investment company. Pearl Wealth does not
have a material interest in any securities traded in Client accounts.
Pearl Wealth allows Supervised Persons to purchase or sell the same securities that may be recommended to
and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to
Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigate through
policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material
non-public information controls); gifts and entertainment; outside business activities and personal securities
reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the
same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are
made with more advantageous terms than Client trades, or by trading based on material non-public information.
This risk is mitigated by Pearl Wealth conducting a coordinated review of personal accounts and the accounts of
the Clients. The Advisor has also adopted written policies and procedures to detect the misuse of material, non-
public information.
While Pearl Wealth allows Supervised Persons to purchase or sell the same securities that may be
recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or
traded afterwards. At no time will Pearl Wealth, or any Supervised Person of Pearl Wealth, transact in any
security to the detriment of any Client.
Item 12 – Brokerage Practices
Pearl Wealth does not have discretionary authority to select the broker-dealer/custodian for custody and
execution services, except for the authorized trade-away transactions for certain fixed income trades. The Client
will engage the Custodian (herein the "Custodian") to safeguard Client assets and authorize Pearl Wealth to
direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, Pearl Wealth does
not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis at
the Custodian.
Pearl Wealth does not exercise discretion over the selection of the Custodian. Pearl Wealth does recommend the
Custodian to Clients for custody and execution services. Pearl Wealth will typically recommend that Clients
establish their account[s] at Charles Schwab & Co., Inc. (“Schwab”), a FINRA-registered broker-dealer and
member SIPC and a “qualified custodian”. Pearl Wealth maintains an institutional relationship with Schwab,
whereby the Advisor receives economic benefits from Schwab as detailed below. Clients are not obligated to use
the recommended Custodian and will not incur any extra fee or costs from the Advisor associated with using a
custodian not recommended by Pearl Wealth. However, if Schwab is not utilized, the Advisor may have
limitations in the services it can offer comparable to other Clients. recommends Schwab due to the
Pearl Wealth LLC
2101 Pearl Street, Boulder, CO 80302
Phone: (303) 250-0036 | http://pearlwealth.net
Page 11
reasonableness of commissions charged to the Client, services made available to the Client, its reputation,
and/or the quality of its trade execution. Pearl Wealth will periodically compare Schwab to other providers.
Trade-Away Transactions
As noted above, the Advisor may obtain an additional authorization to trade-away from the Custodian for access
to fixed income securities. In such instances, the Client will complete additional authorizations with the Custodian
for the discretionary authority to trade away from the Custodian. The Client may be charged a trade-away fee by
the Custodian. The Advisor does not receive any additional compensation for such trades.
1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor
enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and
other services. Pearl Wealth does not participate in soft dollar programs sponsored or offered by any
broker-dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian.
Please see Item 14 below.
2. Brokerage Referrals – Pearl Wealth does not receive any compensation from any third party in connection
with the recommendation for establishing an account.
3. Directed Brokerage – The Advisor will place trades within the established account[s] at the Custodian
designated by the Client, unless separately authorized by the Client. Further, all Client accounts are traded within
their respective brokerage account[s] at the Custodian. The Advisor will not engage in any principal transactions
(i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts
(i.e., purchase of a security into one Client account from another Client’s account[s]). The Advisor will not be
obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest
available transaction costs. These costs are determined by the Custodian.
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the
most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of
execution, 4) confidentiality and 5) skill required of the Custodian. Pearl Wealth will execute its transactions
through the Custodian as authorized by the Client. Pearl Wealth may aggregate orders in a block trade or trades
when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same
trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased
or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-
allocation or other written statement. This must be done in a way that does not consistently advantage or
disadvantage any particular Clients’ accounts.
Item 13 – Review of Accounts
Securities in Client accounts are monitored on a regular and continuous basis by Ms. Huttner. Formal reviews
with the Client are generally conducted at least annually or more frequently depending on the needs of the Client.
Formal reviews are also conducted when a Client’s financial situation changes or as a result of major changes in
economic conditions, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to
notify Pearl Wealth if changes occur in the Client’s personal financial situation that might adversely affect the
Client’s investment plan. Additional reviews may be triggered by material market, economic or political events.
The Client will receive statements no less than quarterly, but typically monthly, from the Custodian. These
statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to
the Custodian’s website so that the Client may view these reports and their account activity. Client statements
will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide
Clients with periodic reports regarding their holdings, allocations, and performance.
Pearl Wealth LLC
2101 Pearl Street, Boulder, CO 80302
Phone: (303) 250-0036 | http://pearlwealth.net
Page 12
Item 14 – Client Referrals and Other Compensation
Pearl Wealth is a fee-based advisory firm, that is compensated solely by its Clients and not from any investment
product. Pearl Wealth does not receive commissions or other compensation from product sponsors, broker-dealers
or any unrelated third party. Pearl Wealth may refer Clients to various unaffiliated, non-advisory professionals (e.g.
attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its
Clients. Likewise, Pearl Wealth may receive non-compensated referrals of new Clients from various third parties.
The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for
Client referrals.
The Advisor may be indirectly compensated by an Independent Manager as described in Item 5 above and does
not receive any other forms of compensation with such arrangements.
Pearl Wealth has established an institutional relationship with Schwab through its “Schwab Advisor Services”
unit, a division of Schwab dedicated to serving independent advisory firms like Pearl Wealth. As a registered
investment advisor participating on the Schwab Advisor Services platform, Pearl Wealth receives access to
software and related support without cost because the Advisor renders investment management services to
Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and
many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor
endeavors at all times to act in the best interest of its Clients. Clients should be aware, however, that the receipt
of economic benefits from Schwab creates a conflict of interest since these benefits may influence the Advisor's
recommendation of Schwab over a custodian that does not furnish similar software, systems support, or
services. To mitigate this conflict, Pearl Wealth will periodically compare Schwab to other providers to assess its
services, fees, trade execution and other factors.
Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of Client’s funds and securities. Through
Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be
able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds
and other investments without having to adhere to investment minimums that might be required if the Client were
to directly access the investments.
Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to
technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for
Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its
relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for
its Clients but may not directly benefit all Clients.
Services that May Only Benefit the Advisor – Schwab also offers other services and financial support to Pearl
Wealth that may not benefit the Client, including: educational conferences and events, financial start-up support,
consulting services and discounts for various service providers. Access to these services creates a financial
incentive for the Advisor to recommend Schwab, which results in a potential conflict of interest. Pearl Wealth
believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients.
Item 15 – Custody
The Advisor is authorized to deduct its fees from the Client’s account[s] at the Custodian. The Client must place
all assets with a “qualified custodian”. The Client is required to engage the Custodian to retain all funds and
securities and direct the Advisor to utilize that Custodian for security transactions in the account[s]. The Client
should review statements provided by the Custodian and compare to any reports provided by Pearl Wealth to
ensure accuracy, as the Custodian does not perform this review. For more information about custodians and
brokerage practices, see Item 12 – Brokerage Practices
Pearl Wealth LLC
2101 Pearl Street, Boulder, CO 80302
Phone: (303) 250-0036 | http://pearlwealth.net
Page 13
As the Advisor has custody of the funds and securities solely as a consequence of its authority to make
withdrawals from Client accounts to collect its fees, the Advisor is required to meet the following criteria:
• The Advisor receives written authorization from the Client to deduct advisory fees from the Client’s
account[s] held with the Custodian.
• Each time a fee is directly deducted from a Client’s account[s], the Advisor concurrently sends the
qualified custodian an invoice or statement of the amount of the fee to be deducted from the Client's
account[s].
• The Advisor sends the Client an invoice or statement itemizing the fee, including the formula used to
calculate the fee, the value of the assets under management on which the fee is based, and the time
period covered by the fee.
Item 16 – Investment Discretion
Pearl Wealth requires discretion over the selection and amount of securities to be bought or sold in Client
accounts without obtaining prior consent or approval from the Client, unless the Advisor is managing a qualified
participant level account for the Client. However, these purchases or sales are subject to specified investment
objectives, guidelines, or limitations previously set forth by the Client and agreed to by Pearl Wealth. The Client
provides written authorization to provide the Advisor with discretionary authority over the Account[s] by executing
an investment advisory agreement. All discretionary trades made by Pearl Wealth will be in accordance with
each Client's investment objectives and goals.
Item 17 – Voting Client Securities
Pearl Wealth does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements
directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client
retains the sole responsibility for proxy decisions and voting.
Item 18 – Financial Information
Neither Pearl Wealth, nor Ms. Huttner, have any adverse financial situations that would reasonably impair the
ability of Pearl Wealth to meet all obligations to its Clients. Neither Pearl Wealth, nor any of its advisory persons,
has been subject to a bankruptcy or financial compromise. Pearl Wealth is not required to deliver a balance
sheet along with this Disclosure Brochure as the Advisor does not collect fees of $1,200 or more for services to
be performed six months or more in advance.
Pearl Wealth LLC
2101 Pearl Street, Boulder, CO 80302
Phone: (303) 250-0036 | http://pearlwealth.net
Page 14
Form ADV Part 2B – Brochure Supplement
for
Debra Herz Huttner, CFP®
President and Chief Compliance Officer
Effective: August 24, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Debra Herz Huttner, CFP® CRD# 6244041) in addition to the information contained in the Pearl Wealth LLC
(“Pearl Wealth” or the “Advisor”, CRD# 296811) Disclosure Brochure. If you have not received a copy of the
Disclosure Brochure or if you have any questions about the contents of the Pearl Wealth Disclosure Brochure or
this Brochure Supplement, please contact the Advisor at (303) 250-0036.
Additional information about Ms. Huttner is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 6244041.
Pearl Wealth LLC
2101 Pearl Street, Boulder, CO 80302
Phone: (303) 250-0036 | http://pearlwealth.net
Page 15
Item 2 – Educational Background and Business Experience
Debra Herz Huttner, CFP®, born in 1970, is dedicated to advising Clients of Pearl Wealth as its President and
Chief Compliance Officer. Ms. Huttner earned her JD from New York University School of Law in 1997 and an
MBA from NYU Stern School of Business in 1997. In addition, Ms. Huttner earned a B.A. in English Literature
from Brown University in 1992.
Additional information regarding Ms. Huttner’s employment history is included below.
Employment History:
President, Pearl Wealth LLC
Financial Advisor, Colorado Capital Management, Inc.
Attorney, Private Practice
Attorney, O'Brien Braun, P.C.
06/2018 to Present
08/2013 to 06/2018
01/2013 to 08/2013
01/2011 to 12/2012
CERTIFIED FINANCIAL PLANNER® Professional
I am certified for financial planning services in the United States by Certified Financial Planner Board of
Standards, Inc. (“CFP Board”). Therefore, I may refer to myself as a CERTIFIED FINANCIAL PLANNER®
professional or a CFP® professional, and I may use these and the other certification marks (the “CFP Board
Certification Marks”) that Certified Financial Planner Board of Standards Center for Financial Planning, Inc. has
licensed to CFP Board in the United States. The CFP® certification is voluntary. No federal or state law or
regulation requires financial planners to hold the CFP® certification. You may find more information about the
CFP® certification at www.cfp.net.
CFP® professionals have met CFP Board’s high standards for education, examination, experience, and ethics.
To become a CFP® professional, an individual must fulfill the following requirements:
• Education – Earn a bachelor’s degree or higher from an accredited college or university and complete
CFP Board-approved coursework at a college or university through a CFP Board Registered Program.
The coursework covers the financial planning subject areas CFP Board has determined are necessary
for the competent and professional delivery of financial planning services, as well as a comprehensive
financial plan development capstone course. A candidate may satisfy some of the coursework
requirement through other qualifying credentials. CFP Board implemented the bachelor’s degree or
higher requirement in 2007 and the financial planning development capstone course requirement in
March 2012. Therefore, a CFP® professional who first became certified before those dates may not have
earned a bachelor’s or higher degree or completed a financial planning development capstone course.
• Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to
assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in the
context of real-life financial planning situations.
• Experience – Complete 6,000 hours of professional experience related to the personal financial
planning process, or 4,000 hours of apprenticeship experience that meets additional requirements.
• Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP®
Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and
Standards of Conduct (“Code and Standards”), which sets forth the ethical and practice standards for
CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements to
remain certified and maintain the right to continue to use the CFP Board
Pearl Wealth LLC
2101 Pearl Street, Boulder, CO 80302
Phone: (303) 250-0036 | http://pearlwealth.net
Page 16
Certification Marks:
• Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment to
CFP Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of the
client, at all times when providing financial advice and financial planning. CFP Board may sanction a
CFP® professional who does not abide by this commitment, but CFP Board does not guarantee a CFP®
professional's services. A client who seeks a similar commitment should obtain a written engagement
that includes a fiduciary obligation to the client.
• Continuing Education – Complete 30 hours of continuing education every two years to maintain
competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with
developments in financial planning. Two of the hours must address the Code and Standards.
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Ms. Huttner. Ms. Huttner has never
been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits,
arbitration claims or administrative proceedings against Ms. Huttner.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Ms. Huttner.
However, we do encourage you to independently view the background of Ms. Huttner on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD#
6244041.
Item 4 – Other Business Activities
Ms. Huttner is dedicated to the investment advisory activities of Pearl Wealth’s Clients. Ms. Huttner does not
have any other business activities.
Item 5 – Additional Compensation
Ms. Huttner is dedicated to the investment advisory activities of Pearl Wealth’s Clients. Ms. Huttner does not
receive any additional forms of compensation.
Item 6 – Supervision
Ms. Huttner serves as the President and Chief Compliance Officer of Pearl Wealth. Ms. Huttner can be reached
at (303) 250-0036.
Pearl Wealth has implemented a Code of Ethics an internal compliance document that guides Ms. Huttner in
meeting fiduciary obligations to Clients of Pearl Wealth. Further, Pearl Wealth is subject to regulatory oversight
by various agencies. These agencies require registration by Pearl Wealth and Ms. Huttner. As a registered entity,
Pearl Wealth is subject to examinations by regulators, which may be announced or unannounced. Pearl Wealth
is required to periodically update the information provided to these agencies and to provide various reports
regarding the business activities and assets of the Advisor.
Pearl Wealth LLC
2101 Pearl Street, Boulder, CO 80302
Phone: (303) 250-0036 | http://pearlwealth.net
Page 17
Privacy Policy
Effective: August 24, 2026
Our Commitment to You
Pearl Wealth LLC (“Pearl Wealth” or the “Advisor”) is committed to safeguarding the use of personal information
of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here
in our Privacy Policy (“Policy”).
Our relationship with you is our most important asset. We understand that you have entrusted us with your
private information, and we do everything that we can to maintain that trust. Pearl Wealth (also referred to as
"we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements
controls to ensure that such information is used for proper business purposes in connection with the
management or servicing of our relationship with you.
Pearl Wealth does not sell your non-public personal information to anyone. Nor do we provide such information
to others except for discrete and reasonable business purposes in connection with the servicing and
management of our relationship with you, as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are set
forth in this Policy.
Why you need to know?
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing
your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose
how we collect, share, and protect your personal information.
What information do we collect from you?
Driver’s license number
Date of birth
Social security or taxpayer identification number Assets and liabilities
Name, address and phone number[s]
Income and expenses
E-mail address[es]
Investment activity
Account information (including other institutions)
Investment experience and goals
What Information do we collect from other sources?
Custody, brokerage and advisory agreements
Other advisory agreements and legal documents
Transactional information with us or others
Account applications and forms
Investment questionnaires and suitability
documents
Other information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use we maintain physical, procedural and
electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a
secure office environment. Our technology vendors provide security and access control over personal
information and have policies over the transmission of data. Our associates are trained on their responsibilities to
protect Client’s personal information.
We require third parties that assist in providing our services to you to protect the personal information they
receive from us.
Pearl Wealth LLC
2101 Pearl Street, Boulder, CO 80302
Phone: (303) 250-0036 | http://pearlwealth.net
Page 18
How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list some
reasons we may share your personal information.
Basis For Sharing
Do we share?
Can you limit?
Yes
No
No
Not Shared
Yes
Yes
No
Not Shared
Servicing our Clients
We may share non-public personal information with non-affiliated third
parties (such as administrators, brokers, custodians, regulators, credit
agencies, other financial institutions) as necessary for us to provide
agreed upon services to you, consistent with applicable law, including but
not limited to: processing transactions; general account maintenance;
responding to regulators or legal investigations; and credit reporting.
Marketing Purposes
Pearl Wealth does not disclose, and does not intend to disclose, personal
information with non-affiliated third parties to offer you services. Certain
laws may give us the right to share your personal information with
financial institutions where you are a customer and where Pearl Wealth
or the client has a formal agreement with the financial institution. We will
only share information for purposes of servicing your accounts, not
for marketing purposes.
Authorized Users
Your non-public personal information may be disclosed to you and
persons that we believe to be your authorized agent[s] or
representative[s].
Information About Former Clients
Pearl Wealth does not disclose and does not intend to disclose, non-
public personal information to non-affiliated third parties with respect to
persons who are no longer our Clients.
Changes to our Privacy Policy
We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.
Periodically we may revise this Policy, and will provide you with a revised Policy if the changes materially alter
the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public
personal information other than as described in this notice unless we first notify you and provide you with an
opportunity to prevent the information sharing.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by
contacting us at (303) 250-0036.
Pearl Wealth LLC
2101 Pearl Street, Boulder, CO 80302
Phone: (303) 250-0036 | http://pearlwealth.net
Page 19