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Absher Wealth Management, LLC
1450 Raleigh Road, Suite 105
Chapel Hill, NC 27517
(919) 283-2340
Form ADV Part 2A
Brochure
September 26, 2025
This Brochure provides information about the qualifications and business practices of Absher
Wealth Management, LLC. If you have any questions about the contents of this brochure, please
contact us at (919) 283-2340 or kevin@absherwealth.com. The information in this Brochure has
not been approved or verified by the United States of America Securities and Exchange
Commission (“SEC”) or by any state securities authority.
Absher Wealth Management is a registered investment adviser. Registration of an investment
adviser does not imply any level of skill or training. Additional information about Absher Wealth
Management also is available on the SEC’s website at www.adviserinfo.sec.gov. You can search
this site by our firm name or by using a unique identifying number, known as a CRD number. The
CRD number for Absher Wealth Management is 304642.
Item 2 – Material Changes
This section of the Brochure discusses specific material changes that have been made. This Brochure,
dated September 26, 2025, replaces our most recent annual amendment dated March 28, 2025.
Key updates were made to the following section(s) since the last annual amendment:
September 26, 2025
•
Item 5-Fees and Compensation: Updated Other Types of Compensation We
Receive to disclose an Asset Match Program by Trade-PMR.
We encourage you to carefully review this Brochure prior to entering into an investment advisory
contract with our firm to understand your relationship with our firm and help you determine to hire
or retain us as your investment adviser. You may receive an updated copy of this brochure at any time
by contacting us at (919) 283-2340. Additionally, our Brochure is available on our web site,
https://absherwealth.com/ at no charge.
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Item 3 – Table of Contents
Item 2 – Material Changes ........................................................................................................... ii
Item 4 – Advisory Business ........................................................................................................... 4
Item 5 – Fees and Compensation .................................................................................................. 8
Item 6 – Performance-Based Fees and Side-By-Side Management ................................................ 11
Item 7 – Types of Clients ............................................................................................................ 11
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .......................................... 11
Item 9 – Disciplinary Information ............................................................................................... 13
Item 10 – Other Financial Industry Activities and Affiliations ...................................................... 14
Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading .................... 14
Item 12 – Brokerage Practices ..................................................................................................... 15
Item 13 – Review of Accounts .................................................................................................... 17
Item 14 – Client Referrals and Other Compensation .................................................................... 18
Item 15 – Custody ...................................................................................................................... 18
Item 16 – Investment Discretion ................................................................................................. 19
Item 17 – Voting Client Securities ............................................................................................... 19
Item 18 – Financial Information ................................................................................................. 19
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Item 4 – Advisory Business
About Our Firm
Absher Wealth Management, LLC (“Absher Wealth Management”) is a fee-only registered
investment adviser that provides investment management and financial advisory services to individual
investors to help them achieve their financial needs and goals. Founded in 2019, the firm is owned by
Mike Absher.
Our firm takes pride in providing personalized service to our clients and acknowledges that it is held
to a fiduciary standard of care.
Types of Advisory Services We Offer
Absher Wealth Management offers portfolio management and wealth management services, as well
as financial planning and consulting, to individuals, high net worth individuals, trusts, businesses and
corporations. We work with our clients to determine their investment objectives and risk profile and
develop a customized investment plan based on their individual needs and goals. Absher Wealth
Management will utilize the financial information provided by the client to analyze and develop
strategies and solutions to assist the client in meeting their financial goals.
Prior to Absher Wealth Management rendering any of the foregoing services, clients are required to
enter into one or more written advisory agreements with Absher Wealth Management setting forth
the relevant terms and conditions of the advisory relationship.
Portfolio and Wealth Management Services
Absher Wealth Management manages our clients’ portfolios on a discretionary and, in limited
circumstances, non-discretionary basis. Our portfolio and wealth management services are tailored to
the needs of our clients and are based on a comprehensive understanding of each client’s current
situation, past experiences, and future goals. With this acquired knowledge we create, analyze,
strategize, and implement goal-oriented investment solutions. These solutions become our clients’
investment policy. This policy and our matched strategies are designed to be risk appropriate, cost
effective and tax efficient.
Our wealth management services generally include a broad range of comprehensive financial planning
and/or consulting services, as well as discretionary or, in limited circumstances, non-discretionary
management of investment portfolios.
Client assets are generally allocated among individual equity and debt securities in accordance with
the client's stated investment objective and risk/volatility parameters. Where appropriate, Absher
Wealth Management may also provide advice about many types of legacy positions or other
investments held in client portfolios. Clients may also engage Absher Wealth Management to manage
and/or advise on certain investment products that are not maintained at their primary custodian, such
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as variable life insurance and annuity contracts (to the extent permissible without an insurance license)
and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In
these situations, Absher Wealth Management will direct or make recommendations on a non-
discretionary basis for the allocation of client assets among the various investment options available
with the product. These assets are generally maintained at the underwriting insurance company or
custodian for the plan trustee or administrator and clients retain responsibility for effecting trades in
these accounts.
Clients may also retain Absher Wealth Management to provide advisory services for their retirement
plan account. When providing these services, the firm acts as an ERISA 3(21) fiduciary and is required
to act under the standard of care in ERISA that is generally a higher standard than imposed on our
firm under the Investment Advisers Act of 1940. Advisory services available to plan participants
include:
Investment performance reporting
• Non-discretionary investment advice
• Asset allocation models
• Strategic investment allocations
•
Absher Wealth Management consults with clients on an initial and ongoing basis to assess their
specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the
management of their portfolios. You should promptly notify us if there are changes in your financial
situation or if you wish to place any limitations on the management of your account. You may impose
reasonable restrictions or mandates on the management of your account if Absher Wealth
Management determines, in our sole discretion, the conditions would not materially impact the
performance of a management strategy or prove overly burdensome to the firm's management efforts.
Financial Planning and Consulting Services
Absher Wealth Management offers different levels of financial planning and consulting services to
help our clients identify, prioritize and work towards their goals and objectives. Our consulting
services give our clients the ability to receive a broad range of financial advice and services, including
specific security recommendations, for the duration of the advisory agreement.
Our process starts with an extensive review of a client's family situation, which includes assets and
liabilities as well as estate, tax, and insurance needs. We then employ a risk tolerance and risk capacity-
focused simulation to get a detailed cash flow analysis and proposed asset allocation. Together, this
information is analyzed to develop a proposed financial plan, which is designed to be dynamic in
nature, ever-evolving due to life changes, along with changes in cash flow needs, risk tolerance, time
horizon, or investment objectives.
Absher Wealth Management’s financial planning and consulting services may include any or all of
the following topics:
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• Cash Flow Analysis: Planning around one-time expenses, as well as ongoing distribution
needs and savings goals.
• Financial Record Organizing: Guidance with organizing important financial records so you
know what to keep.
• Estate Planning: Analyzing and suggesting wealth transfer strategies to meet your objectives,
as well as reviewing beneficiary designations and proper account titling.
• Charitable Giving: Discussing your desired social impact, exploring tax-appropriate vehicles
to accomplish your philanthropic objectives, and determining which assets to use for giving.
• Education Planning: Reviewing 529 plans and general assistance in preparing to meet
dependents’ continuing educational needs.
• Business Planning: Advice on how to structure an entity, reviewing cash flow expectations,
strategies for using debt effectively, succession and transition planning, and assistance with
office space decisions.
• Concentrated Stock: Managing the risk of owning highly appreciated investments, as well as
decisions concerning equity compensation offered through an employer.
• Federal Benefits & Health Care: Optimization of Social Security, Medicare and other Federal
Benefits, as well as navigating health care decisions before Medicare.
• Death & Disability: Evaluating cash needs at death, income needs of surviving dependents,
and disability income.
• Divorce Planning: Assisting with financial issues and decisions that couples face when going
through a divorce.
• Liability Management: Guidance on using debt productively and paying off strategically.
•
Investment Consulting: Analyzing investment allocations, possible alternatives to consider,
and their effect on your portfolio.
insurance coverage and, where appropriate,
• Tax Planning: Reviewing tax returns and proposing options for reducing tax liability.
•
Insurance Review: Analyzing current
recommending strategies to mitigate risks.
• Family Governance: Coordinating family meetings, formulating mission statements, helping
identify the purpose for the wealth, and reviewing how future generations might preserve and
continue the legacy.
• Retirement Plan Consulting and Employee Benefits Analysis
While each of these services is available on a stand-alone basis, certain of them may also be rendered
in conjunction with investment portfolio management services, as part of a comprehensive wealth
management engagement. In performing these services, Absher Wealth Management is not required
to verify any information received from the client or from the client's other professionals (e.g.,
attorneys, accountants, etc.), and is expressly authorized to rely on such information. Absher Wealth
Management may recommend clients engage the firm for additional related services, or we may
recommend other professionals to implement our recommendations. These additional services by
Absher Wealth Management or another professional are provided at an additional cost to you, which
is based on the nature, extent, complexity, and other characteristics of the services. This creates a
conflict of interest because the firm will have an incentive to recommend additional services based on
the compensation to be received, rather than solely based on your needs, and in some cases, based on
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the prospect of cross-referrals of advisory clients from the other professional or his or her firm.
Implementation of financial planning recommendations is entirely at your discretion. You have
complete freedom in selecting a financial adviser to assist you with implementing the
recommendations made in your financial plan and are under no obligation to act on the advice of
Absher Wealth Management. Financial planning recommendations are of a generic nature and are
not limited to any specific product or service offered by a broker dealer or insurance company. Should
you choose to implement the recommendations contained in the plan, Absher Wealth Management
suggests you work closely with your attorney, accountant and/or insurance agent.
Absher Wealth Management will act solely in its capacity as a registered investment adviser and does
not provide any legal, accounting or tax advice. You should seek the counsel of a qualified accountant
and/or attorney when necessary. As part of our advisory services, we may assist clients with tax
harvesting and will work with the client’s tax specialist to answer any questions related to the client’s
portfolio.
Portfolio Management Services for Wrap Fee Program
Absher Wealth Management offers portfolio management services through the Absher Portfolio
Management program. A bundled or “wrap fee” program is an advisory fee program under which you
pay one bundled fee to compensate Absher Wealth Management for portfolio management and trade
execution. A wrap fee program may not be the lowest cost option if you would like to restrict your
investments to open-end mutual funds or other long-term investment products.
Retirement Plan Rollovers – No Obligation / Conflict of Interest
A client or prospective client leaving an employer has four options regarding an existing retirement
plan (and may engage in a combination of these options): (i) leave the money in the former employer’s
plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers
are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account
value (which could, depending upon the client’s age, result in adverse tax consequences). If Absher
Wealth Management recommends that a client roll over their retirement plan assets into an account
to be managed by Absher Wealth Management, such a recommendation creates a conflict of interest
if Absher Wealth Management will earn new (or increases its current) compensation as a result of the
rollover. No client is under any obligation to roll over retirement plan assets to an account managed by Absher
Wealth Management.
Amount of Assets We Manage
As of December 31, 2024, Absher Wealth Management managed approximately $1,007,711,675 on a
discretionary basis and $87,624,724 on a non-discretionary basis. Discretionary assets under
management are those for which we have an ongoing responsibility to select and make securities
recommendations that are in line with your financial needs and objectives and then effect those
securities transactions without first consulting you. Non-discretionary assets under management are
those for which we have an ongoing responsibility to select and make securities recommendations that
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are in line with your financial needs and objectives and then effect those securities transactions only
after consulting with you to inform you of the transaction(s) and obtaining your approval to move
forward.
Item 5 – Fees and Compensation
How We Are Compensated for Our Advisory Services
Absher Wealth Management offers its advisory services on a fee-only basis. Our fees vary among the
different types of advisory services we offer and may be negotiated at our sole discretion. The specific
fees and manner in which fees are charged and calculated are described in your investment advisory
agreement. You should carefully review the investment advisory agreement prior to signing it.
Fees for our advisory services may be higher or lower than fees charged by other advisers who offer
similar services. You may be charged different fees than similarly situated clients for the same services.
You should carefully review this brochure to understand the fees and other sources of compensation
that exist among our services prior to entering into an investment advisory contract with our firm.
Portfolio and Wealth Management Services
Absher Wealth Management offers investment and wealth management services for an annual fee
based on the amount of assets under the firm’s management. Fees are generally billed in advance each
calendar quarter based on the market value of the assets under management/advisement on the last
day of the previous calendar quarter. For investment and wealth management services Absher Wealth
Management provides with respect to certain client holdings (e.g., held-away assets, 529 plans, etc.),
we may negotiate a fee rate that differs from our standard fee schedule.
Our graduated fee schedule is as follows:
Assets Under Management
$0 to $1,000,000
$1,000,001 to $2,000,000
$2,000,001 to $3,000,000
$3,000,001 to $5,000,000
$5,000,001 to $10,000,000
More than $10,000,001
Annual Advisory Fee
1.10%
1.00%
0.90%
0.85%
0.80%
0.75%
This fee schedule may be based on cumulative household assets under management. However, certain
ERISA rules prevent householding corporate plans with personal assets for fee reductions. You should
refer to your advisory agreement for your specific fee rate(s).
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Financial Planning and Consulting Services
Fees for financial planning and/or consulting services can be billed on an hourly rate, fixed rate, or
project basis in advance on a monthly or quarterly basis. There is no minimum fee required for
financial planning or consulting services; however financial planning and consulting fees shall
generally not exceed $20,000. Fees are due and payable as incurred. Absher Wealth Management may
agree with clients to charge fixed fees for consulting services.
Factors we consider when determining our financial planning and consulting fees include, but are not
limited to:
• The amount of time we expect to spend completing the financial planning or consulting
services and providing related advice;
• The complexity of your goals, issues and/or needs;
• The extensiveness and complexity of the data needed regarding your personal financial
information;
• Your net worth or the value of your investment accounts and/or other assets that are the
subject of the financial planning or consulting services; and/or
• Special circumstances related to life changes, marital status, health or special income needs,
or growth or decline of a personal business.
Absher Wealth Management may request a retainer to initiate financial planning and consulting
services. However, we will not request the prepayment of fees more than $1,200 in advisory fees more
than six months in advance.
You may engage Absher Wealth Management for additional investment management services to
assist with implementing one or more financial planning recommendations. You will incur additional
fees if you retain our firm for such services. You have complete freedom in selecting an investment
adviser to assist you in implementing any recommendations by Absher Wealth Management and are
under no obligation to act upon the advice we provide.
For consulting services, the investment advisory agreement between Absher Wealth Management and
the client will continue in effect until terminated by either party. For stand-alone financial planning
services, the agreement between Absher Wealth Management and the client will terminate upon
delivery of the plan or completion of the service.
Payment of Fees
Clients must authorize Absher Wealth Management to instruct the account custodian to directly debit
fees from the client’s account. Accounts initiated or terminated during a calendar quarter will be
charged a prorated fee.
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Fees for our advisory services generally require you to pay investment advisory fees in advance of
receiving services. Upon termination of your advisory agreement with our firm, we will promptly
refund any prepaid, unearned fees.
• For investment and wealth management services, refunds are calculated by taking the total
advisory fee billed for the calendar quarter, dividing that amount by the number of days in the
calendar quarter and multiplying that amount by the number of days services were not
provided during the calendar quarter.
• For financial planning and consulting services, refunds are calculated based on the value of
the services that were completed prior to termination of the advisory agreement.
Other Types of Fees and Expenses You May Incur
Absher Wealth Management’s fees are exclusive of brokerage commissions, transaction fees, and
other related costs and expenses which shall be incurred by the client. Clients may incur certain
charges imposed by custodians, brokers, third-party investments and other third parties, such as
custodial fees, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees
and taxes on brokerage accounts and securities transactions. Decisions to reallocate your account
assets may result in you incurring a redemption fee imposed by one or more mutual funds held in your
account. Mutual funds and exchange traded funds also charge internal management fees, which are
disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition
to Absher Wealth Management’s fee. Absher Wealth Management shall not receive any portion of
these commissions, fees, and costs, including any distribution or “12b-1” fees paid by the mutual funds
in which your account assets are invested.
Other Types of Compensation We Receive
Absher Wealth Management has contracted with Trade-PMR, Inc. (“Trade-PMR”) for brokerage
services, including trade processing, collection of management fees, marketing assistance and
research. Item 12 – Brokerage Practices further describes the factors that Absher Wealth Management
considers in selecting or recommending broker-dealers for client transactions and determining the
reasonableness of their compensation (e.g., commissions).
Trade-PMR, Inc, announced an Asset Match Program to match client deposits that will be active from
October 1, 2025, to March 31, 2026. Clients can receive a 50-basis point match (0.50%) on eligible
deposits into their Trade-PMR accounts, subject to some terms and conditions. This could create a
conflict of interest in that Absher’s asset management fees may increase due to additional deposits in
Trade-PMR accounts. Absher Wealth Management does not receive any additional proceeds from
Trade-PMR.
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Item 6 – Performance-Based Fees and Side-By-Side Management
Absher Wealth Management does not charge any performance-based fees or participate in side-by-
side management.
Item 7 – Types of Clients
Absher Wealth Management offers investment advisory services to a wide variety of clients, including
individuals, high net worth individuals and families, pension, profit-sharing and other employer
sponsored plans, trusts, estates, family entities, charitable institutions, foundations, corporations, and
other business entities.
Absher Wealth Management generally requires a minimum initial investment of $500,000 for the
Absher Portfolio Management (APM) program. The firm, in its sole discretion, may accept clients
with smaller portfolios based upon each client’s particular circumstances.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis and Investment Strategies
Absher Wealth Management carefully constructs a tax-efficient and cost-effective asset allocation
strategy based on a client’s unique cash flow needs, stated return and risk profile. Security selection is
based on qualitative, quantitative, technical, and relative strength metrics. Portfolios holdings are
constantly monitored and adjusted as market conditions and our clients’ circumstances dictate. Clients
may hold or retain other types of assets as well, and Absher Wealth Management may offer advice
regarding those various assets as part of our services. Advice regarding such assets generally will not
involve portfolio management services.
Our core belief is that wealth is created over time by investing in high-quality businesses and
participating in the long-term growth of those businesses. We employ a value methodology that
focuses on a company’s history of producing predictable free cash flow, high profit margins or market
share compared to their competitors, a conservative balance sheet compared to their peers and a
history of increasing dividends over time. Client assets are primarily allocated among stocks and
bonds, however individual client circumstances may dictate the use of other types of securities,
including but not limited to master limited partnership units, exchange-traded funds, mutual funds
and cash alternatives.
Risk of Loss
Investing in securities involves risk of loss that you should be prepared to bear. All investments present
the risk of loss of principal – the risk that the value of securities (e.g., stocks, bonds, ADRs, etc.), when
sold or otherwise disposed of, may be less than the price paid for the securities. Even when the value
of the securities when sold is greater than the price paid, there is the risk that the appreciation will be
less than inflation. In other words, the purchasing power of the proceeds may be less than the
purchasing power of the original investment. There is no guarantee that investment recommendations
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made by Absher Wealth Management will be accurate. We cannot assure that your account will
increase, preserve capital or generate income, nor can we assure that your investment objectives will
be realized. Although all investments involve risk, our investment advice seeks to limit risk through
diversification among various asset classes.
Described below are the material risks associated with investing in the types of securities we generally
use in client accounts:
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Equity Securities
In general, prices of equity securities (common, convertible preferred stocks and other securities whose
values are tied to the price of stocks, such as rights, warrants and convertible debt securities) are more
volatile than those of fixed-income securities. The prices of equity securities could decline in value if
the issuer’s financial condition declines or in response to overall market and economic conditions.
Investments in smaller companies and mid-size companies may involve greater risk and price volatility
than investments in larger, more mature companies.
Fixed-Income Securities
The return and principal value of bonds fluctuate with changes in market conditions. Fixed-income
securities are subject to interest rate risk and credit quality risk. The market value of fixed-income
securities generally declines when interest rates rise, and an issuer of fixed-income securities could
default on its payment obligations. Changes in interest rates generally have a greater effect on bonds
with longer maturities than on those with shorter maturities. If bonds are not held to maturity, they
may be worth more or less than their original value. Credit risk refers to the possibility that the issuer
of a bond will not be able to make principal and/or interest payments. High yield bonds, also known
as “junk bonds,” carry higher risk of loss of principal and income than higher rated investment grade
bonds.
International Investing
The risks of investing in foreign securities include loss of value as a result of political or economic
instability; nationalization, expropriation or confiscatory taxation; changes in foreign exchange rates
and foreign exchange restrictions; settlement delays; and limited government regulation (including
less stringent reporting, accounting, and disclosure standards than are required of U.S. companies).
These risks may be greater with investments in emerging markets. Certain investments utilized by
Absher Wealth Management may also contain international securities.
Cash and Cash Equivalents
A portion of your assets may be invested in cash or cash equivalents to achieve your investment
objective, provide ongoing distributions and/or take a defensive position. Cash holdings may result in
a loss of market exposure.
Item 9 – Disciplinary Information
As a registered investment adviser, Absher Wealth Management is required to disclose all material
facts regarding any legal or disciplinary events that would be material to your evaluation of our firm
or the integrity of our management. Absher Wealth Management has no disciplinary information to
report.
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Item 10 – Other Financial Industry Activities and Affiliations
Absher Wealth Management has no other financial industry activities or affiliations.
Item 11 – Code of Ethics, Participation in Client Transactions and Personal
Trading
Our Code of Ethics
Absher Wealth Management is committed to providing investment advice with the utmost
professionalism and integrity. Our firm strives to identify, manage and/or mitigate conflicts of interest
and has adopted policies, procedures and oversight mechanisms to address conflicts of interest. We
have adopted a Code of Ethics that emphasizes our fiduciary obligation to put client interests first and
is designed to ensure personal securities transactions, activities, and interests of employees will not
interfere with the responsibilities to make decisions in the best interest of clients. All supervised persons
of our firm must acknowledge and comply with our Code of Ethics.
Absher Wealth Management will provide a copy of our Code of Ethics to any client or prospective
client, upon request, by contacting us at (919) 283-2340.
Participation in Client Transactions
Absher Wealth Management does not affect principal or agency cross-securities transactions for client
accounts. Absher Wealth Management also does not cross trades between client accounts. Principal
transactions are generally defined as transactions where an adviser, acting as principal for its own
account or the account of an affiliated broker-dealer, buys from or sells a security to an advisory client.
An agency cross transaction is defined as a transaction where a person acts as an investment adviser
in relation to a transaction in which the investment adviser, or any person controlled by or under
common control with the investment adviser, acts as broker for both the advisory client and for
another person on the other side of the transaction. Agency cross transactions may arise where an
adviser is dually registered as a broker-dealer or has an affiliated broker-dealer.
Employee Personal Trading
Supervised persons of Absher Wealth Management may purchase or sell the same security that we
recommend for investment in client accounts. This creates a conflict of interest as there is a possibility
that employees of our firm might benefit from market activity by a client in a security held by the
employee. Our Code of Ethics is designed to assure that the personal securities transactions, activities
and interests of the employees of Absher Wealth Management will not interfere with making decisions
in the best interest of advisory clients and implementing such decisions while, at the same time,
allowing employees to invest for their own accounts. Under the Code of Ethics, certain classes of
securities have been designated as exempt transactions, based upon a determination that these would
not materially interfere with the best interest of Absher Wealth Management’s clients. Our Code of
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Ethics also places restrictions on our employees’ personal trading activities. These restrictions include,
but are not limited to, a prohibition on trading based on non-public information and pre-clearance
requirements for certain types of transactions. Employee trading is continually monitored under the
Code of Ethics in an effort to prevent conflicts of interest between Absher Wealth Management and
our clients.
Certain affiliated accounts may trade in the same securities with client accounts on an aggregated basis
when consistent with Absher Wealth Management's obligation of best execution. In such
circumstances, the affiliated and client accounts will share commission costs equally and receive
securities at a total average price. Absher Wealth Management will retain records of the trade order
(specifying each participating account) and its allocation, which will be completed prior to the entry
of the aggregated order. Completed orders will be allocated as specified in the initial trade order.
Partially filled orders will be allocated on a pro rata basis. Any exceptions will be explained on the
order.
Item 12 – Brokerage Practices
Selection and Recommendation of Broker-Dealers
Though Absher Wealth Management recommends brokers with which we’ve negotiated pricing on
behalf of our clients, we do not have discretionary authority to select brokers. We endeavor to
recommend broker-dealers that will provide the best services at the lowest commission rates possible.
The reasonableness of commissions is based on the broker's ability to provide professional services,
competitive commission rates, research and other services that will help our firm provide investment
management services to clients. Absher Wealth Management may recommend brokers who provide
useful research and securities transaction services even though a lower commission may be charged
by a broker who offers no research services and minimal securities transaction assistance.
We have negotiated competitive pricing and services with Trade-PMR for brokerage back-office and
trade execution services and First Clearing for clearing and custodial services. First Clearing is a trade
name used by Wells Fargo Clearing Services, LLC., a non-bank affiliate of Wells Fargo & Company.
Trade-PMR and First Clearing are members of SIPC and are unaffiliated registered broker-dealers and
FINRA members. The brokerage commissions and/or transaction fees charged by Trade-PMR or any
other designated broker-dealer are exclusive of and in addition to Absher Wealth Management’s
advisory fee. Absher Wealth Management regularly reviews the reasonableness of the compensation
received by the broker-dealers used for executing client transactions in an effort to ensure that our
clients receive favorable execution consistent with our fiduciary duty. Factors which Absher Wealth
Management considers in recommending Trade-PMR and First Clearing or any other broker-dealer
to clients include, but is not limited to, their respective financial strength, reputation, execution,
pricing, research, and service. The commissions and/or transaction fees charged by these brokers may
be higher or lower than those charged by other broker-dealers.
In addition, Trade-PMR provides Absher Wealth Management with access to its institutional trading
and custody services, which are typically not available to retail investors. These brokerage services
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include the execution of securities transactions, custody, research, and access to mutual funds and
other investments that are otherwise generally available only to institutional investors or would require
a significantly higher minimum initial investment. Other benefits we may receive include receipt of
duplicate client confirmations and bundled duplicate statements; access to a trading desk that
exclusively services its participants; access to block trading which provides the ability to aggregate
securities transactions and then allocates the appropriate shares to client accounts; and access to an
electronic communication network for client order entry and account information. Trade-PMR also
provided Absher Wealth Management with nominal funding to assist with startup expenses
establishing the business entity.
The commissions paid by Absher Wealth Management’s clients are intended to be consistent with our
duty to obtain “best execution.” However, a client may pay a commission that is higher than what
another qualified broker-dealer might charge to affect the same transaction when Absher Wealth
Management determines, in good faith, that the commission is reasonable in relation to the value of
the brokerage and research services received. In seeking best execution, the determinative factor is not
the lowest possible cost, but whether the transaction represents the best qualitative execution, taking
into consideration the full range of a broker-dealer’s services, including among others, execution
capability, commission rates, and responsiveness. Consistent with the foregoing, while Absher Wealth
Management will seek competitive rates, it may not necessarily obtain the lowest possible commission
rates for client transactions.
Research and Other Soft Dollar Benefits
Absher Wealth Management does not participate in soft-dollar relationships.
Brokerage for Client Referrals
When selecting broker-dealers for the execution of client securities transactions, Absher Wealth
Management does not consider whether we will receive any client referrals from the broker-dealer or
any other third-party.
Directed Brokerage
As Absher Wealth Management will not request discretionary authority to determine the broker-
dealer to be used or the commission rates to be paid, clients must direct Absher Wealth Management
as to the broker-dealer to be used. The commissions and transaction fees charged by these broker-
dealers could be higher or lower than those charged by other custodians and broker-dealers. In
directing the use of a particular broker-dealer, it should be understood that Absher Wealth
Management will not have authority to negotiate commissions among various broker-dealers or obtain
volume discounts. As such, best execution may not be achieved. Not all investment advisers require
clients to direct the use of specific broker-dealers
Aggregation of Orders
Absher Wealth Management will generally block trades where possible and when advantageous to
clients. Certain trades will be effected independently. The blocking of trades permits the trading of
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aggregate blocks of securities composed of assets from multiple client accounts where transaction costs
are shared equally and on a pro-rated basis between all accounts included in the block. Block trading
allows us to execute equity or fixed income trades in a timely, equitable manner and to reduce overall
commission charges to clients. Clients who do not provide Absher Wealth Management with
discretion will not participate in block trades, and their trades in similar securities will be placed with
brokers after trades for discretionary accounts. Accounts owned by supervised persons of our firm
may participate in block trading with your accounts; however, these individuals will not be given
preferential treatment of any kind.
Item 13 – Review of Accounts
Accounts at Absher Wealth Management are reviewed at least quarterly. This informal review
includes assessing client goals and objectives, monitoring the account and addressing the need to
rebalance, as necessary. Individual securities held in client accounts are periodically monitored by
Absher Wealth Management’s Investment Adviser Representatives (“IARs”). Accounts are reviewed
in the context of each client’s stated investment objectives and guidelines. More frequent reviews may
be requested by the client or triggered by material changes to a client’s individual circumstances,
market conditions, or the political or economic environment.
Absher Wealth Management may also review tax-planning needs, cash-flow needs, as well as
charitable giving, insurance, and estate planning as part of our ongoing client reviews. Reviews are
tailored to the services we provide to you, as well as your individual needs and goals. We encourage
you to discuss your needs, goals, and objectives with us and keep us informed of any changes. If you
engage our firm for ongoing investment advisory services, we will contact you at least annually to
determine whether there have been any changes to your financial situation or investment objectives
and whether you wish to impose any reasonable restrictions on the management of your account or
reasonably modify any existing restrictions. At this time, we will advise you of any account changes
we feel are necessary to help you stay on track with meeting your financial goals and consider whether
the current services provided by our firm continue to be suitable for your needs.
In addition to the account statements you receive for your account custodian at least quarterly, Absher
Wealth Management may also provide you with written quarterly performance reports for your
account that provide details on account holdings and performance. As a convenience to our clients,
in addition to reporting on clients’ financial assets, at a client’s request we may prepare a global
consolidated report that also includes certain non-financial assets (e.g., real assets). In such instances,
Absher Wealth Management relies on the client to provide current and accurate price or other
valuation information for those assets to be included in the client’s consolidated account report. In no
instance are non-financial assets included in performance reporting. Absher Wealth Management does
not independently verify, and expressly disclaims responsibility for, the accuracy of any non-financial
asset values clients provided to us to include in their reporting.
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Item 14 – Client Referrals and Other Compensation
Other Compensation Arrangements
Absher Wealth Management receives compensation from Trade-PMR, Inc., the broker-dealer used
for your account, and your account custodian in the form of access to electronic systems that assist us
in the management of client accounts, as well as research, software and other technology that provide
access to client account data (such as trade confirmations and account statements), pricing information
and other market data, facilitate trade execution (and allocation of aggregated trade orders for multiple
client accounts), and client reporting capabilities. Trade-PMR provided our firm with nominal funding
to assist with startup expenses establishing our business entity. Your account custodian also offers
Absher Wealth Management discounts for products and services offered by vendors and third-party
service providers, such as software and technology solutions. These economic benefits create a conflict
of interest in that it gives our firm an incentive to recommend one broker-dealer or custodian over
another that does not provide similar electronic systems, support or services. We address this conflict
of interest by disclosing to our clients the types of compensation that our firm receives so clients can
consider this when evaluating our firm. It is important that you consider the fees, level of service and
investment strategies, among other factors, when selecting an investment manager.
Client Referrals
Absher Wealth Management does not pay any referral fees to other individuals for referring clients to
our firm.
Item 15 – Custody
When you establish a relationship with our firm for investment management services, your assets will
be maintained by a bank, broker -dealer, mutual fund transfer agent or other such institution deemed
a ‘qualified custodian’ by the SEC. We rely on the custodian to price and value assets, execute and
clear transactions, maintain custody of assets in your account and perform other custodial functions.
Absher Wealth Management does not maintain physical possession of any client account assets. We
utilize First Clearing as the qualified custodian for client accounts.
Absher Wealth Management can access client accounts through its ability to debit advisory fees and
is therefore considered to have “soft” custody of client assets. In addition, Absher Wealth
Management is deemed to have custody due to its authority over certain accounts to distribute assets
subject to a third-party standing letter of authorization (“SLOAs”). The firm relies on the seven
requirements outlined in the SEC’s No-Action Letter to the Investment Advisers Associated, dated
February 21, 2017, which provides relief from an annual surprise custody examination by an
independent public accountant.
You will receive monthly and/or quarterly account statements directly from the qualified custodian.
Absher Wealth Management may also provide you with written quarterly performance reports for
your account. We urge you to carefully review your account statements and compare the account
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balances with the balances reflected on any performance report you may receive from our firm for
accuracy. Balances on our reports may vary slightly from custodial statements due to differences in
accounting procedures, reporting dates, valuation methodologies of certain securities or other
operational factors. You should promptly notify us if you do not receive account statements from your
custodian at least quarterly or if you believe the information on your account statements is inaccurate.
Item 16 – Investment Discretion
Absher Wealth Management typically has investment discretion over clients’ securities accounts.
Investment discretion is the authority to determine the securities or other assets to purchase or sell on
behalf of an account. Investment discretion may also include the authority to select or terminate an
Independent Manager. This authority is exercised in a manner consistent with your stated investment
objective for the particular account. You must provide written authorization to our firm before we can
assume discretionary authority over your account. Any investment guidelines or restrictions you
would like to place on your account must be provided to Absher Wealth Management in writing.
Item 17 – Voting Client Securities
As a general policy, Absher Wealth Management will retain proxy voting authority for clients that
have given us the authority to do so. For these purposes, Absher Wealth Management has contracted
with Broadridge Financial Solutions and will use their Proxy Edge® platform (“Proxy Edge”) to
provide proxy voting support with regard to casting votes and keeping voting records. Under the terms
of its arrangement with Broadridge, Absher Wealth Management will generally follow the Glass
Lewis recommendations.
Where Absher Wealth Management has proxy voting authority for securities of its advisory clients,
we will vote such securities for the exclusive benefit, and in the best interest, of those clients and their
beneficiaries, as determined by us in good faith, subject to any restrictions or directions from a client.
Absher Wealth Management maintains and will follow the guidelines outlined in our Proxy Voting
Policies and Procedures. You may obtain a copy of our Proxy Voting Policies and Procedures and/or
a record of ballots voted upon by contacting us at (919) 283-2340.
Item 18 – Financial Information
As a registered investment adviser, Absher Wealth Management is required to provide you with
certain financial information about our firm.
Prepayment of Fees
We do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in
advance.
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Our Financial Condition
We do not have any financial commitment that is reasonably likely to impair our contractual
commitments to our clients, nor has our firm ever been the subject of a bankruptcy proceeding.
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