Overview
- Headquarters
- Las Vegas, NV
- Total Firm Assets
- $214 million
- Average High-Net-Worth Client Portfolio Size
- $3.5 million
- Minimum Account Size
- $500,000
Fee Structure
Primary Fee Schedule (2026 ADV PART 2)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $250,000 | 1.60% |
| $250,001 | $500,000 | 1.20% |
| $500,001 | $1,000,000 | 0.90% |
| $1,000,001 | $5,000,000 | 0.85% |
| $5,000,001 | $10,000,000 | 0.75% |
| $10,000,001 | $25,000,000 | 0.55% |
| $25,000,001 | $50,000,000 | 0.35% |
| $50,000,001 | and above | 0.25% |
Minimum Annual Fee: $7,500
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $11,500 | 1.15% |
| $5 million | $45,500 | 0.91% |
| $10 million | $83,000 | 0.83% |
| $50 million | $253,000 | 0.51% |
| $100 million | $378,000 | 0.38% |
Clients
- High-Net-Worth Share of Firm Assets
- 91.97%
- Number of High-Net-Worth Clients
- 56
- Total Client Accounts
- 414
- Discretionary Accounts
- 379
- Non-Discretionary Accounts
- 35
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Investment Advisor Selection
Regulatory Filings
- SEC CRD Number
- 111243
Primary Brochure: 2026 ADV PART 2 (2026-06-04)
View Document Text
10091 W Park Run Dr, Suite 110
Las Vegas, NV 89145
Telephone: 800 683 5800
Email: info@aweadvisors.com
Web Address: www.aweadvisors.com
3/23/2026
Part 2A of Form ADV: Firm Brochure
This brochure provides information about the qualifications and business practices of
Adaptive Wealth Engineering. If you have any questions about the contents of this
brochure, please contact us at 800 683-5800 or i n f o @a w e a d v i s o r s. c o m The
information in this brochure has not been approved or verified by the United States
Securities and Exchange Commission or by any state securities authority. Additional
information about Adaptive Wealth Engineering also is available on the SEC’s website at
w w w . a d v i s e r i n f o . s e c . g o v . You can search this site by a unique
identifying number, known as a CRD number. Our firm's CRD number is 111243.
Item 2 Material Changes
The SEC adopted "Amendments to Form ADV" in July, 2010. This Firm Brochure, dated 3/23/2026, is
our new disclosure document prepared according to the SEC’s new requirements and rules. As you will
see, this document is a narrative that is substantially different in form and content, and includes some new
information that we were not previously required to disclose.
After our initial filing of this Brochure, this Item will be used to provide our clients with a summary of
new and/or updated information. We will inform you of the revision(s) based on the nature of the
updated information.
Consistent with the new rules, we will ensure that you receive a summary of any material changes to this
and subsequent Brochures within 90 days of the close of our business’ fiscal year. Furthermore, we will
provide you with other interim disclosures about material changes as necessary. There were no material
changes.
Item 3 Table of Contents
Page
Fees and Compensation
Performance-Based Fees and Side-By-Side Management
Types of Clients
Investment Discretion
Item 1 Cover Page
Item 2 Material Changes
Item 3
Table of Contents
Item 4 Advisory Business
Item 5
Item 6
Item 7
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Item 9 Disciplinary Information
Item 10 Other Financial Industry Activities and Affiliations
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Item 12 Brokerage Practices
Item 13 Review of Accounts
Item 14 Client Referrals and Other Compensation
Item 15 Custody
Item 16
Item 17 Voting Client Securities
Item 18 Financial Information
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Item 4 Advisory Business
Adaptive Wealth Engineering (AWE) is an SEC-registered investment adviser with its principal place
of business located in Las Vegas, Nevada. Adaptive Wealth Engineering began conducting business in
March 1999.
• Timothy Francis Bock is 100% owner of AWE: CRD#
111243
Adaptive Wealth Engineering offers the following advisory services to our clients:
Because some types of investments involve certain additional degrees of risk, they will only be
implemented/recommended when consistent with the client's stated investment objectives, tolerance for
risk, liquidity and suitability.
PORTFOLIO MANAGEMENT
Our firm provides asset management of client funds based on the individual needs of the client. Through
personal discussions in which goals and objectives based on the client's particular circumstances are
established, we create and manage a portfolio based on client’s individual objectives, time horizons,
risk tolerance, and liquidity needs. As appropriate, we may also review and discuss a client’s prior
investment history, as well as family composition and background.
We manage these advisory accounts on a d iscretionary basis. Account supervision is guided by the
client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as
well as tax considerations.
Once the client's portfolio has been established, we review the portfolio quarterly or more frequently and
if necessary, rebalance the portfolio as needed based on the client's individual needs.
Our investment recommendations are not limited to any specific product or service offered by a broker-
dealer or insurance company and will generally include advice regarding the following securities:
• Exchange-listed securities
• Corporate debt securities
• Municipal securities
•
Fixed annuities
• Variable annuities
• Mutual fund shares
• United States Government securities
•
Private debt securities
•
Private equity securities
Investment advice may be offered on any investments held by a client at the start of the advisory
relationship. The primary vehicles recommended for investing are exchange traded funds and open-end
mutual funds. A d a p t i v e W e a l t h E n g i n e e r i n g g enerally recommends investment grade bond funds.
Adaptive's security analysis is based on a number of factors, including those derived from academic
research and literature, commercially available software technology, securities rating services, general
market and financial information, due diligence reviews and specific investment analysis that clients
may request.
Adaptive Wealth Engineering practices an evidence-based approach to investing (EBI) which is the
understanding the investment best practices and body of knowledge defined by the last 50-plus years of
academic and practitioner research. This research is ongoing and will continue to inform the
recommendations Adaptive makes to its clients. Adaptive believes there are five key tenets
associated with evidence-based investing (EBI):
Outperforming the market is difficult.
While Adaptive does believe there are ways to build portfolios through strategic allocation decisions
informed by academic evidence, Adaptive never loses sight of the fact that outperforming the market is
not easy. Given this fact, Adaptive generally recommends low-cost, tax-efficient portfolios to its clients.
Size, value, profitability and momentum tilts utilized for the equity component of a portfolio.
There is abundant academic evidence showing that small-cap stocks have historically generated higher
long-term returns than large-cap stocks, that value stocks — which are stocks with low prices relative to
earnings — have historically outperformed growth stocks, and that positive momentum stocks — which
are stocks with high returns over the last year — have historically outperformed negative momentum
stocks. Profitable companies have outperformed less profitable companies. Adaptive tries to capture
these historical long-term return premiums through the stock funds Adaptive uses.
Global stock market diversification is the starting point.
The academic evidence shows that investors should own U.S., international and emerging markets
stocks, not concentrating solely on U.S. companies. This research shows that diversification across
countries makes sense in the same way that diversification across companies does. We have no way of
knowing which particular country will generate the highest long-term returns (and Adaptive does not
that diversification is the right strategy. Further,
believe anyone else does either), so we believe
approximately 40% of the world’s stock market value is located in non-U.S. companies, which is one
other argument for global diversification.
The primary role of fixed income is to reduce portfolio volatility.
Adaptive believes that academic and practitioner evidence shows that the most efficient way to
build portfolios is by taking risk through the stock of the portfolio and using fixed income to reduce
portfolio risk. This means that Adaptive's fixed income recommendations primarily emphasize
government-backed securities, high-quality municipal and corporate bond funds because these securities
tend to provide the m ost effective diversification of stock market risks.
EBI slowly evolves over time.
Importantly, EBI is not static. Adaptive's investment strategy recommendations will evolve as
academic and practitioner evidence evolves.
Long-term investment success means different things to different people. Adaptive believes that the
best investment plan for a client depends on the client’s specific circumstances and objectives. That is
why Adaptive begins the investment planning process in a discovery meeting with a conversation
about the client’s values, goals, relationships, assets, types of accounts, advisors, preferred processes and
interests.
While every client’s situation is unique, certain factors should be considered in creating any investment
plan. These factors include the purpose of the portfolio, its size, specific funding sources, how and when
a client plans to use the funds, and the degree of uncertainty or risk a client is willing to accept in pursuit
of their objectives. As Adaptive establishes a clear vision of a client’s goals and circumstances,
Adaptive can build the foundation of an investment plan that best matches the client’s needs as well as the
realities of the financial markets.
As part of the assessment process with each client, Adaptive engages in a risk assessment process. For
many investors, their most important long-term goal is achieving financial independence. But most
clients also have intermediate-term goals, such as funding college education, travel or vacation homes.
Achieving these goals commonly requires some measure of risk since most investors need returns in
excess of inflation to meet their goals. Risk, however, is multifaceted, which is why Adaptive focuses on
three different aspects of risk in helping guide the asset allocation discussion.
Part One: Ability to Take Risk
A client’s ability to take risk is most commonly a function of (1) the time horizon(s) of the client’s
investment objective(s), (2) whether the client is working or retired, and (3) the stability of the client’s
job. Longer time horizons argue for more aggressive asset allocation strategies because a long time
horizon gives the portfolio more time to recover after periods of poor performance. If a client is still
working, he or she may be able to be more aggressive since the portfolio is likely not needed to support
spending needs. Investors in more stable jobs (e.g., a university professor) generally have greater ability
to take risk compared to investors with jobs that are more sensitive to the performance of the economy.
Part Two: Willingness to Take Risk
Willingness to take risk measures a client’s tolerance for risk. Specifically, we measure the amount of
portfolio loss a client is capable of experiencing without it significantly affecting the client’s quality of
life or causing the client to change portfolio strategy. This is a crucially important aspect of risk because
changing portfolio strategy after a client experiences risk is something the client’s portfolio may not
recover from.
Part Three: Need to Take Risk
Need to take risk is directly tied to the client’s rate-of-return objective. If a client needs relatively high
returns to achieve his or her goals, the need to take risk is high. But this will require a more aggressive
asset allocation, which could be in conflict with a client’s ability or willingness to take risk. Need to take
risk is typically relatively high for investors who expect to withdraw (or are withdrawing) a relatively
high proportion (e.g., a withdrawal rate in excess of 3 percent) of their investment portfolios to fund
living expenses.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear.
All investments present the risk of loss of principal – the risk that the value of securities (mutual funds,
exchange traded funds (ETFs)), 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.
real estate investment
income securities. Equity securities may
The mutual funds and ETFs utilized by Adaptive may include funds invested in domestic and
trusts (REITs), corporate, municipal and
international equities, including
government fixed
include large capitalization, medium
capitalization and small capitalization stocks. Mutual funds and ETF shares invested in fixed income
securities are subject to the same interest rate, inflation and credit risks associated with the underlying
bond holdings.
Among the more risky mutual funds used in Adaptive's investment strategies are the U.S. and
international small capitalization value funds and emerging markets funds. Conservative fixed income
securities have lower risk of loss of principal, but most bonds (with the exception of Treasury Inflation
Protected Securities (TIPS) present the risk of loss of purchasing power through lower expected return.
This risk is greatest for longer-term bonds.
Certain funds utilized by Adaptive may contain international securities. Investing outside the United
States involves additional risks, such as currency fluctuations, periods of illiquidity and price volatility.
These risks may be greater with investments in developing countries.
More information about the risks of any particular market sector can be reviewed in representative
mutual fund prospectuses within each applicable sector.
Equity Securities Risk. Equity securities (common, convertible preferred stocks and other securities
whose values are tied to the price of stocks, such as rights, warrants and convertible deb t securities)
could decline in value if the issuer's financial condition declines or in response to overall market and
economic co nditions. A fund's principal market segment(s) – such as large cap, mid cap or small cap
stocks, or growth or value stocks – may underperform other market segments or the equity markets as a
whole. 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 Risk. 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.
Asset Allocation Risk. A fund's selection and weighting of asset classes and/or underlying funds may
cause it to underperform other funds with a similar investment objective.
FINANCIAL PLANNING
We provide financial planning services. Financial planning is a comprehensive evaluation of a client’s
current and future financial state by using currently known variables to predict future cash flows, asset
values and withdrawal plans. Through the financial planning process, all questions, information and
analysis are considered as they impact and are impacted by the entire financial and life situation of the
client. Clients purchasing this service receive a written report which provides the client with a detailed
financial plan designed to assist the client achieve his or her financial goals and objectives.
In general, the financial plan can address any or all of the following areas:
• Personal: We review family records, budgeting, personal liability, estate information and financial
goals.
• Tax & Cash Flow: We analyze the client’s income tax and spending and planning for past, current
and future years.
•
Investments: We analyze investment alternatives and their effect on the client's portfolio.
•
Insurance: We review existing policies to ensure proper coverage for life, health, disability,
long-term care, liability, home and automobile.
• Retirement: We analyze current strategies and investment plans to help the client achieve his or her
retirement goals.
• Death & Disability: We review the client’s cash needs at death, income needs of surviving
dependents, estate planning and disability income.
• Estate: We assist the client in assessing and developing long-term strategies, including as
appropriate, living trusts, wills, estate tax, asset protection plans.
We gather required information through in-depth personal interviews. Information gathered includes the
client's current financial status, tax status, future goals, returns objectives and attitudes towards risk. We
carefully review documents supplied by the client, including a questionnaire completed by the client,
and prepare a written report. Should the client choose to implement the recommendations contained in
the plan, we suggest the client work closely with his/her attorney and accountant. Implementation of
financial plan recommendations is entirely at the client's discretion.
Typically, the financial plan is presented to the client within six months of the contract date, provided
that all information needed to prepare the financial plan has been promptly provided.
Financial Planning recommendations are not limited to any specific product or service offered by a
broker-dealer or insurance company. All recommendations are of a generic nature.
AMOUNT OF MANAGED ASSETS
Discounts, not generally available to our advisory clients, may be offered to family members and friends
of associated persons of our firm.
As of 3/23/2026, AWE is actively managing $204,413,827 of clients' assets on a discretionary basis.
Assets managed on a non-discretionary basis: $9,562,785. Total assets under management:
$213,413,827.
Item 5 Fees and Compensation
PORTFOLIO MANAGEMENT SERVICES FEES
Clients are charged advisory fees at the beginning of each calendar quarter based on the combined
balances of their managed accounts. Account cash flows are prorated for fees. Our annual fees for
Portfolio Management Services are based upon a percentage of assets under management and generally
range from .50% to 2.0%. Grandfathering of Minimum Account Requirements: Pre-existing advisory
clients are subject to Adaptive's minimum account requirements and advisory fees in effect at the time
the client entered into the advisory relationship. Our firm's minimum account requirements and fee
schedules differ among clients.
The annualized fee for Portfolio Management Services is charged as a percentage of assets under
management, according to the following schedule:
Assets Under Management
Annual Fee
First $250,000
Next $250,000
Next $500,000
Next $4,000,000
Next $5,000,000
Next $15,000,000
Next $25,000,000
Next amounts over $50,000,000
PER QUARTER
.400%
.300%
.225%
.213%
.188%
.138%
.088%
.063%
PER ANNUM
1.60%
1.20%
0.90%
0.85%
0.75%
0.55%
0.35%
0.25%
A minimum of $500,000 of assets under management is required for this service and the minimum
quarterly fee is $1,875.00. This account size may be negotiable under certain circumstances. Adaptive
Wealth Engineering may group certain related client accounts for the purposes of achieving the
minimum account size and determining the annualized fee.
Limited Negotiability of Advisory Fees: Although Adaptive Wealth Engineering has established the
aforementioned fee schedule(s), we retain the discretion to negotiate alternative fees on a client-by-client
basis. C lient facts, circumstances and needs are considered in determining the
fee schedule. These
include the complexity of the client, assets to be placed under management, anticipated future additional
assets; related accounts; portfolio style, account composition, reports, among other factors. The specific
annual fee schedule is identified in the contract between the adviser and each client.
We may group certain related client accounts for the purposes of achieving the minimum account size
requirements and determining the annualized fee.
Discounts, not generally available to our advisory clients, may be offered to family members and friends
of associated persons of our firm.
FINANCIAL PLANNING FEES
Adaptive Wealth Engineering's Financial Planning fee is determined based on the nature of the services
being provided and the complexity of each client’s circumstances. All fees are agreed upon prior to
entering into a contract with any client.
Typically, a comprehensive plan will cost between $2,500 and $5,000 and will include all or part of a
tax plan, portfolio analysis, insurance needs analysis retirement needs analysis, and estate plan. The fee
for a financial plan is payable in advance. Financial consulting services are also available on an hourly
basis as follows: Principals $500/hour, non- principal advisors $200/hour and administrative staff at
$75/hour. The clients are given up to five (5) business days after signing the Advisory Contract and
receiving a copy of Form ADV Part IIA to unconditionally rescind the contract. Clients may terminate
the agreement at any time, and a refund of the unearned fees will be made, based on the time and effort
expended by Adaptive Wealth Engineering, Inc. before termination. Otherwise, the agreement
terminates upon delivery of any specified reports, or upon performance of specified services.
Financial Planning Fee Offset: Adaptive Wealth Engineering reserves the discretion to reduce or
waive the hourly fee and/or the minimum fixed fee if a financial planning client chooses to engage us for
our Portfolio Management Services.
The client is billed in advance based on our total estimated Financial Planning fees.
GENERAL INFORMATION
Termination of the Advisory Relationship: A client agreement may be canceled at any time, by either
party, for any reason upon receipt of 30 days written notice. Upon termination of any account, any
prepaid, unearned fees will be promptly refunded.
Mutual Fund Fees: All fees paid to Adaptive Wealth Engineering for investment advisory services are
separate and distinct from the fees and expenses charged by mutual funds and/or ETFs to their
shareholders. These fees and expenses are described in each fund's prospectus. These fees will generally
include a management fee, other fund expenses, and a possible distribution fee. A client could invest in a
mutual fund directly, without our services. In that case, the client would not receive the services
provided by our firm which are designed, among other things, to assist the client in determining which
mutual fund or funds are most appropriate to each client's financial condition and ob jectives. Accordingly ,
the client should review both the fees charged by the funds and our fees to fully understand the total amount
of fees to be paid by the client and to thereby evaluate the advisory services being provided.
Additional Fees and Expenses: In addition to our advisory fees, clients are also responsible for the fees
and expenses charged by custodians and imposed by broker dealers, in cluding, but not limited to, any
transaction charges imposed by a broker dealer with which an independent investment manager effects
transactions for the client's account(s). Please refer to the "Brokerage Practices" section (Item 12) of this
Form ADV for additional information.
ERISA Accounts: Adaptive Wealth Engineering is deemed to be a fiduciary to advisory clients that are
employee benefit plans or individual retirement accounts (IRAs) pursuant to the Employee Retirement
Income and Securities Act ("ERISA"), and regulations under the Internal Revenue Code of 1986 (the
"Code"), respectively. As such, our firm is subject to specific duties and obligations under ERISA and
the Internal Revenue Code that include among other things, restrictions concerning certain forms of
compensation. Adaptive Wealth Engineering may only charge fees for investment advice. Adaptive
Wealth Engineering does not receive commissions or 12b-1 fees.
Advisory Fees in General: Clients should note that similar advisory services may (or may not) be
available from other registered (or unregistered) investment advisers for similar or lower fees.
Item 6 AWE does not charge performance-based fees.
Item 7 Types of Clients
Adaptive Wealth Engineering provides advisory services to the following types of clients:
Individual clients, pension and profit-sharing plans, corporations and other business entities.
As previously disclosed in
Item 5, our firm has established certain initial minimum account
requirements, based on the nature of the service(s) being provided. For a more detailed understanding of
those requirements, please review the disclosures provided in each applicable service.
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
METHODS OF ANALYSIS
We use the following methods of analysis in formulating our investment advice and/or managing client
assets:
In conducting the analysis of securities, the firm uses a number of tools and resources including
commercially available software technology, securities rating services, general market an d financial
information, due diligence reviews and specific investment analysis requested by the client. The principal
sources of in formation include major financial publications and resource tools, security analysis and
benchmarking software, prospectuses, and various financial and business resources
including filings
in
with the Securities and Exchange Commission. AWE may also use outside consultants
certain circumstances to provide expertise as to particular areas of information or analysis.
Margin Transactions: Clients may use margin when appropriate to seek higher returns with higher
risks.
Risk of Loss: Securities investments are not guaranteed and you may lose money on your investments.
We ask that you work with us to help us understand your tolerance for risk.
Item 9 Disciplinary Information
We are required to disclose any legal or disciplinary events that are material to a client's or prospective
client's evaluation of our advisory business or the integrity of our management.
Our firm and our management personnel have no reportable disciplinary events to disclose.
Item 10 Other Financial Industry Activities and Affiliations
Clients should be aware that the receipt of additional compensation by Adaptive Wealth Engineering
and its management persons or employees creates a conflict of interest that may impair the objectivity of
our firm and these individuals when making advisory recommendations. Adaptive Wealth Engineering
endeavors at all times to put the interest of its clients first as part of our fiduciary duty as a registered
investment adviser; we take the following steps to address this conflict:
• We disclose to clients the existence of all material conflicts of interest, including the potential for
our firm and our employees to earn compensation from advisory clients in addition to our firm's
advisory fees;
• We collect, maintain and document accurate, complete and relevant client background information,
including the client’s financial goals, objectives and risk tolerance;
• Our firm's management conducts regular reviews of each client account to verify that all
recommendations made to a client are suitable to the client’s needs and circumstances;
• We require that our employees seek prior approval of any outside employment activity so that we may
ensure that any conflicts of interests in such activities are properly addressed;
• We periodically monitor these outside employment activities to verify that any conflicts of interest
continue to be properly addressed by our firm; and
• We educate our employees regarding the responsibilities of a fiduciary, including the need for
having a reasonable and independent basis for the investment advice provided to clients.
We are aware of the special considerations required under Rule 206(4)-3 of the Investment Advisers Act
of 1940. As such, all appropriate disclosure shall be made and all applicable Federal and State laws will
be observed.
• We disclose to clients the existence of all material conflicts of interest.
Item 11 Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Our firm has adopted a Code of Ethics which sets forth high ethical standards of business conduct that
we require of our employees, including compliance with applicable federal securities laws.
Adaptive Wealth Engineering and our personnel owe a duty of loyalty, fairness and good faith
towards our clients, and have an obligation to adhere not only to the specific provisions of the Code of
Ethics but to the general principles that guide the Code.
Our Code of Ethics includes policies and procedures for the review of quarterly securities transactions
reports as well as initial and annual securities holdings reports that must be submitted by the firm’s
access persons. Among other things, our Code of Ethics also requires the prior approval of any acquisition
of securities in a limited offering (e.g., private placement) or an initial public offering. Our code also
provides for oversight, enforcement and recordkeeping provisions.
Adaptive Wealth Engineering's Code of Ethics further includes the firm's policy prohibiting the use of
material non-public information. While we do not believe that we have any particular access to non-
public information, all employees are reminded that such information may not be used in a personal or
professional capacity.
A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may
request a copy by email sent to info@aweadvisors.com or by calling us at 800-683-5800.
Adaptive Wealth Engineering and individuals associated with our firm are prohibited from engaging in
principal transactions.
Adaptive Wealth Engineering and individuals associated with our firm are prohibited from engaging in
agency cross transactions.
Our Code of Ethics is designed to assure that the personal securities transactions, activities and interests
of our employees will not interfere with (i) making decisions in the best interest of advisory clients and
(ii) implementing such decisions while, at the same time, allowing employees to invest for their own
accounts.
Our firm and/or individuals associated with our firm may buy or sell for their personal accounts securities
identical to or different from those recommended to our clients. In addition, any related person(s)
may have an interest or position in a certain security(ies) which may also be recommended to a client.
As these situations represent actual or potential conflicts of interest to our clients, we have established
the following policies and procedures for implementing our firm’s Code of Ethics, to ensure our firm
complies with its regulatory obligations and provides our clients and potential clients with full and fair
disclosure of such conflicts of interest:
1. No principal or employee of our firm may put his or her own interest above the interest of an
advisory client.
2. No principal or employee of our firm may buy or sell securities for their personal portfolio(s) where
their decision is a result of information received as a result of his or her employment unless the
information is also available to the investing public.
3.
It is the expressed policy of our firm that no person employed by us may purchase or sell any
security prior to a transaction(s) being implemented for an advisory account. This prevents such
employees from benefiting from transactions placed on behalf of advisory accounts. This policy
would not apply to mutual funds or ETFs.
4. Our firm requires prior approval for any IPO or private placement investments by related persons of
the firm.
5. We maintain a list of all reportable securities holdings for our firm and anyone associated with this
advisory practice that has access to advisory recommendations ("access person"). These holdings are
reviewed on a regular basis by our firm's Chief Compliance Officer or his/her designee.
6. We have established procedures for the maintenance of all required books and records.
7. All of our principals and employees must act in accordance with all applicable Federal and State
regulations governing registered investment advisory practices.
8. We require delivery and acknowledgment of the Code of Ethics by each supervised person of our
firm.
9. We have established policies requiring the reporting of Code of Ethics violations to our senior
management.
10. Any individual who violates any of the above restrictions may be subject to termination.
Trade Errors
In all circumstances involving trade errors caused by Adaptive, clients are “made whole." If the
correction of the trade error by the firm results in a loss, Adaptive is responsible for that loss. Adaptive
does not retain any client trade error gains.
In instances where multiple trades are corrected at the same time for the same event, the firm will net the
results of each correction against each other. Gains received during these corrections may be used to
offset losses resulting from other corrections within the total trade error correction.
Adaptive may also correct trade errors by reallocating a purchased security to another client(s) account(s)
in situations in which Adaptive determines such allocation will be in the clients’ best interest. Such
reallocations might prevent Adaptive from incurring trade error losses.
Item 12 Brokerage Practices
Adaptive Wealth Engineering does not maintain custody of your assets that we manage, although we
may be deemed to have custody of your assets if you give us authority to withdraw assets from your
account. Your assets must be maintained in an account at a “qualified custodian,” generally a broker-
dealer or bank. We recommend that our clients use Charles Schwab & Co., Inc. (Schwab), a registered
broker- dealer, member SIPC, as the qualified custodian.
We are independently owned and operated and are not affiliated with Schwab. Schwab will hold your assets
in a brokerage account and buy and sell securities when we instruct them to. While we recommend that you
use Schwab as custodian/broker, you will decide whether to do so and will open y our account with Schwab
by entering into an account agreement directly with them. Conflicts of interest associated with this
arrangement are described below as well as in Item 14. You should consider these c onflicts of interest when
selecting your custodian.
We do not open the account for you, although we may assist you in doing so. Even though your
account is maintained at Schwab, we can still use other brokers to execute trades for your account as
described below (see “Your brokerage and custody costs”).
How we select brokers/custodians
We seek to use a custodian/broker that will hold your assets and execute transactions. When considering
whether the terms that Schwab provides are, overall, most advantageous to you when compared with
other available providers and their services, we consider a wide range of factors, including:
• Combination of transaction execution services and asset custody services (generally without a separate fee
for custody)
• Capability to execute, clear, and settle trades (buy and sell securities for your account)
• Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill
payment, etc.)
• Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs],
etc.)
• Availability of investment research and tools that assist us in making investment decisions
• Quality of services
• Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.)
and willingness to negotiate the prices
• Reputation, financial strength, security, and stability
• Prior service to us and our clients
• Availability of other products and services that benefit us, as discussed below (see “Products and
services available to us from Schwab”)
Your brokerage and trading costs
For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for
custody services but is compensated by charging you commissions or other fees on trades that it executes
or that settle into your Schwab account. Certain trades (for example, many mutual funds, and U.S.
exchange-listed equities and ETFs) may not incur Schwab commissions or transaction fees. Schwab is
also compensated by earning interest on the uninvested cash in your account in Schwab’s Cash Features
Program. To minimize your trading costs, we have Schwab execute trades for your account.
We are not required to select the broker or dealer that charges the lowest transaction cost, even if that
broker provides execution quality comparable to other brokers or dealers. Although we are not required
to execute all trades through Schwab, we have determined that having Schwab execute most trades is
consistent with our duty to seek “best execution” of your trades. Best execution means the most
favorable terms for a transaction based on all relevant factors, including those listed above (see “How
we select brokers/ custodians”). By using another broker or dealer you may pay lower transaction costs.
Products and services available to us from Schwab
Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like ours.
They provide us and our clients with access to their institutional brokerage services (trading, custody,
reporting, and related services), many of which are not typically available to Schwab retail customers.
However, certain retail investors may be able to get institutional brokerage services from Schwab without
going through our firm. Schwab also makes available various support services. Some of those services help
us manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s
support services are generally available at no charge to us. Following is a more detailed description of
Schwab’s support services:
Services that benefit you. Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of client assets. The investment
products available through Schwab include some to which we might not otherwise have access or that
would require a significantly higher minimum initial investment by our clients. Schwab’s services
described in this paragraph generally benefit you and your account.
Services that do not directly benefit you. Schwab also makes available to us other products and services that
benefit us but do not directly benefit you or your account. These products and services assist us in managing
and administering our clients’ accounts and operating our firm. They include investment research, both
Schwab’s own and that of third parties. We use this research to service all or a substantial number of our
clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab
also makes available software and other technology that:
• Provide access to client account data (such as duplicate trade confirmations and account statements)
• Facilitate trade execution and allocate aggregated trade orders for multiple client accounts
• Provide pricing and other market data
• Facilitate payment of our fees from our clients’ accounts
• Assist with back-office functions, record keeping, and client reporting
Services that generally benefit only us. Schwab also offers other services intended to help us manage and
further develop our business enterprise. These services include:
• Educational conferences and events
• Consulting on technology and business needs
• Publications and conferences on practice management and business succession
• Access to employee benefits providers, human capital consultants, and insurance providers
• Marketing consulting and support
Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to
provide the services to us. Schwab also discounts or waives its fees for some of these services or pays all
or a part of a third party’s fees. Schwab also provides us with other benefits, such as occasional business
entertainment of our personnel. If you did not maintain your account with Schwab, we would be required
to pay for these services from our own resources.
Our interest in Schwab’s services
The availability of these services from Schwab benefits us because we do not have to produce or
purchase them. We don’t have to pay for Schwab’s services. The fact that we receive these benefits
from Schwab is an incentive for us to recommend the use of Schwab rather than making such decision
based exclusively on your interest in receiving the best value in custody services and the most
favorable execution of your transactions. This is a conflict of interest. We believe, however, that taken
in the aggregate, our recommendation of Schwab as custodian and broker is in the best interests of our
clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services
(see “How we select brokers/custodians”) and not Schwab’s services that benefit only us.
Item 13 Review of Accounts
PORTFOLIO MANAGEMENT SERVICES
REVIEWS: While the underlying securities within Individual Portfolio Management Services accounts
are continually monitored, these accounts are reviewed quarterly. Accounts are reviewed in the context
of each client's stated investment objectives and guidelines. More frequent reviews may be triggered by
material changes in variables such as the client's individual circumstances, or the market, political or
economic environment.
These accounts are reviewed by: Timothy F. Bock
REPORTS: In addition to the monthly statements and confirmations of transactions that Portfolio
Management Services clients receive from their broker-dealer, Adaptive Wealth Engineering will provide
quarterly reports summarizing account performance, balances and holdings. Year-end tax information is
provided to include taxable gain or loss and applicable expenses. Statements are generally available the
third week following the close of the prior quarter.
FINANCIAL PLANNING SERVICES
REVIEWS: While reviews may occur at different stages depending on the nature an d terms of the
specific engagement, typically no formal reviews will be conducted for Financial Planning clients
unless otherwise contracted for.
REPORTS: Financial Planning clients will receive a completed financial plan. Additional reports will
not typically be provided unless otherwise contracted for.
Item 14 Client Referrals and Other Compensation
As a result of past participation in TD Ameritrade’s AdvisorDirect program (the “referral program”) ;
Advisor received client referrals from TD Ameritrade established the referral program as a means of
referring its brokerage customers and other investors seeking fee based personal investment management
services or financial planning services to independent investment advisors. Upon the completion of the
acquisition of TD Ameritrade by Charles Schwab, the client advisory fee split arrangement has been
assigned to Charles Schwab. Charles Schwab does not su pervise Advisor and has no responsibility for
Advisor’s management of client portfolios or Advisor’s other advi ce or services. Advisor is no longer
participating in the referral program for purposes of receiving client referrals but it is obligated to
pay Charles Schwab an on-going fee for each successful client relationship established as a result of
past referrals. This fee is usually a percentage (not to exceed 15%) of ad visory fee that the client pays
to Advisor (“Solicitation Fee”). Advisor will also pay Charles Schwab the Solicitation Fee on any
advisory fees received by Advisor from any of a referred client’s family member who hired Advisor on
the recommendation of such referred client. Advisor will not
charge clients referred to it through
Charles Schwab any fees or costs higher than its standard fee schedule offered to its other clients or
otherwise pass Solicitation Fees paid to Charles Schwab to its clients.
Item 15 Custody
We previously disclosed in the "Fees and Compensation" section (Item 5) of this Brochure that
AWE directly debits advisory fees from client accounts.
As part of this billing process, the client's custodian is advised of the amount of the fee to be deducted
from that client's account. On at least a quarterly basis, the custodian is required to send to the client a
statement showing all transactions within the account during the reporting period.
Because the custodian does not calculate the amount of the fee to be deducted, it is important for clients
to carefully review their custodial statements to verify the accuracy of the calculation, among other
things. Clients should contact us directly if they believe that there may be an error in their statement.
In addition to the periodic statements that clients receive directly from their custodians, we also send
portfolio reports directly to our clients on a quarterly basis. We urge our clients to carefully compare the
information provided on these statements to ensure that all account transactions, holdings and values are
correct and current.
AWE does not have actual or constructive custody of client accounts.
Item 16 Investment Discretion
Clients may hire us to provide discretionary asset management services, in which case we place trades
in a client's account without contacting the client prior to each trade to obtain the client's permission.
Our discretionary authority includes the ability to do the following without contacting the client:
•
determine the security to buy or sell; and/or
•
determine the amount of the security to buy or sell
Clients give us discretionary authority when they sign a discretionary agreement with our firm, and may
limit this authority by giving us written instructions. Clients may also change/amend such limitations
by once again providing us with written instructions.
Item 17 Voting Client Securities
As a matter of firm policy, we do not vote proxies on behalf of clients. Therefore, although our firm may
provide investment advisory services relative to client investment assets, clients maintain exclusive
responsibility for: (1) directing the manner in which proxies solicited by issuers of securities beneficially
owned by the client shall be voted, and (2) making all elections relative to any mergers, acquisitions,
tender offers, bankruptcy proceedings or other type events pertaining to the client’s investment assets.
Clients are responsible for instructing each custodian of the assets, to forward to the client copies of all
proxies and shareholder communications relating to the client’s investment assets.
We may provide clients with consulting assistance regarding proxy issues if they contact us with
questions.
Item 18 Financial Information
As an advisory firm that maintains discretionary authority and we are required to disclose any financial
condition that may impair our ability to meet our contractual obligations. Adaptive Wealth Engineering
has no financial circumstances to report.
Under no circumstances do we require payment of fees in excess of $1,200 per client more than six
months in advance of services rendered.
Part 2B of Form ADV: Brochure Supplement
Timothy F. Bock
10091 W Park Run Dr, Suite
110 Las Vegas, NV 89145
800 683 5800
3/23/2026
This brochure supplement provides information about Timothy F. Bock that
supplements the Adaptive Wealth Engineering brochure. You should have
received a copy of that brochure. Please contact Timothy F. Bock 702 838 9999 if
you did not receive Adaptive Wealth Engineering's brochure or if you have any
questions about the contents of this supplement.
Additional information about Timothy F. Bock is available on the SEC’s website
at www.adviserinfo.sec.gov
Item 2 Educational Background and Business Experience
Full Legal Name: Timothy F. Bock
Born (Year): 1957
Education: Arizona State University; Engineering 1981
Business Experience: Adaptive Wealth Engineering; President; from 04/01/1999 to
Present
Item 3 Disciplinary Information
Timothy F. Bock has no reportable disciplinary history.
Item 4 Other Business Activities
A. Investment-Related Activities
1. Timothy F. Bock is not engaged in any other investment-
related activities.
2. Timothy F. Bock does not receive commissions, bonuses
or other compensation on the sale of securities or other investment
products.
B. Non Investment-Related Activities
Timothy F. Bock is not engaged in any other business or occupation that provides
substantial compensation or involves a substantial amount of his time.
Item 5 Additional Compensation
Timothy F. Bock does not receive any economic benefit from a non-advisory client
for advisory services.
Item 6 Supervision
Supervisor:
Title:
Phone Number:
Part 2B of Form ADV: Brochure Supplement
Matthew Wayne Ravenscroft
Business Address:
10091 W Park Run Dr, Suite
110 Las Vegas, NV 89145
3/23/2026
This brochure supplement provides information about Matthew Wayne Ravenscroft
that supplements the Adaptive Wealth Engineering brochure. You should have
received a copy of that brochure. Please contact Timothy F. Bock 702 838 9999 if
you did not receive Adaptive Wealth Engineering's brochure or if you have any
questions about the contents of this supplement.
Additional information about Matthew Wayne Ravenscroft is available on the
SEC’s website at www.adviserinfo.sec.gov
Item 2 Educational Background and Business Experience
Full Legal Name: Matthew Wayne Ravenscroft
Born (Year): 1985
Education: California State University San Bernardino, Bachelor of Arts (BA) Criminal Justice 2007
Business Experience: Contract Engineer/Project Manager with over 15 years of experience in
electrical design for commercial/industrial projects. Project Engineer in charge of management/leading
design team, client coordination and all subsequent meetings. Liaison for project coordination between
all Engineering disciplines, subcontractors, designers and owner.
Item 3 Disciplinary Information
Matthew Wayne Ravenscroft has no reportable disciplinary history.
Item 4 Other Business Activities
A. Investment-Related Activities
1. Matthew Wayne Ravenscroft is not engaged in any other investment-
related activities.
2. Matthew Wayne Ravenscroft does not receive commissions, bonuses or
other compensation on the sale of securities or other investment products.
B. Non Investment-Related Activities
Matthew Wayne Ravenscroft is engaged in another business or occupation that provides
substantial compensation or involves a substantial amount of his time. He is presently working at
DMI Engineers.
Item 5 Additional Compensation
Matthew Wayne Ravenscroft does not receive any economic benefit from a non-advisory client for
advisory services.
Item 6 Supervision
Supervisor: Timothy F Bock
Title: President
Phone Number: 702-838-9999
Part 2B of Form ADV: Brochure Supplement
Brandon Cruz
Business Address:
10091 W Park Run Dr, Suite 110
Las Vegas, NV 89145
3/23/2026
This brochure supplement provides information about Brandon Cruz that supplements the
Adaptive Wealth Engineering brochure. You should have received a copy of that brochure.
Please contact info@aweadvisors.com if you did not receive Adaptive Wealth Engineering's
brochure or have questions about the contents of this supplement.
Additional information about Brandon Cruz is available on the SEC’s website at
www.adviserinfo.sec.gov
Item 2 Educational Background and Business Experience
Full Legal name: Brandon Andres Cruz Born (Year): 1997
Education: University of Nevada, Reno, Bachelor of Science, Finance & Economics,
2020
Business experience: Ameriprise Financial Services; Client Relationship Manager
07/2020 – 8/2021
Adaptive Wealth Engineering; Financial Advisor and Paraplanner 09/2021 – Present
Item 3 Disciplinary Information
Brandon A. Cruz has no reportable disciplinary history.
Item 4 Other Business Activities
A. Investment-Related Activities
1. Brandon A. Cruz is not engaged in any other investment-related activities.
2. Brandon A. Cruz does not receive commissions, bonuses or other compensation
on the sale of securities or other investment products.
B. Non Investment-Related Activities
Brandon A. Cruz is not engaged in an other business or occupation that provides
substantial compensation or involves a substantial amount of his time.
Item 5 Additional Compensation
Brandon A. Cruz does not receive any economic benefit from a non-advisory client for
advisory services.
Item 6 Supervision
Supervisor: Timothy F. Bock
Title: President
Phone Number: 702-838-9999
Part 2B of Form ADV: Brochure Supplement
Remington Conte
Business Address:
10091 W Park Run Dr, Suite
110 Las Vegas, NV 89145
3/23/2026
This brochure supplement provides information about Remington Conte that
supplements the Adaptive Wealth Engineering brochure. You should have
received a copy of that brochure. Please contact Timothy F. Bock 702 838 9999 if
you did not receive Adaptive Wealth Engineering's brochure or if you have any
questions about the contents of this supplement.
Additional information about Remington Conte is available on the
SEC's website at www.adviserinfo.sec.gov
Item 2 Educational Background and Business Experience
Full Legal Name: Remington Conte
Born (Year): 1989
Education: University of South Florida, Bachelor of Science (BSc) Finance,
Investment Analysis 2021
Business Experience: Financial Advisor with a background in finance and over 15
years of experience in customer service.
Item 3 Disciplinary Information
Remington Conte has no reportable disciplinary history.
Item 4 Other Business Activities
A. Investment-Related Activities
1. Remington Conte is not engaged in any other
investment-related activities.
2. Remington Conte does not receive commissions,
bonuses, or other compensation on the sale of securities or
other investment products.
B. Non Investment-Related Activities
Item 5 Additional Compensation
Remington Conte does not receive any economic benefit from a non-advisory client
for advisory services.
Item 6 Supervision
Supervisor: Timothy F Bock
Title: President
Phone Number: 702-838-9999
Part 2B of Form ADV: Brochure Supplement
Fionn Allen
Business Address:
10091 W Park Run Dr, Suite
110 Las Vegas, NV 89145
3/23/2026
This brochure supplement provides information about Fionn Allen that supplements
the Adaptive Wealth Engineering brochure. You should have received a copy of
that brochure. Please contact Timothy F. Bock 702 838 9999 if you did not receive
Adaptive Wealth Engineering's brochure or if you have any questions about the
contents of this supplement.
Additional information about Fionn Allen is available on the
SEC's website at www.adviserinfo.sec.gov
Item 2 Educational Background and Business Experience
Full Legal Name: Fionn Allen
Born (Year): 2002
Education: University of Nevada, Reno, Bachelor of Science (BSc) Business
Administration, Business Management 2025
Business Experience: Adaptive Wealth Engineering: Intern (2022 – 2025), Financial
Advisor (2025 – Present)
Item 3 Disciplinary Information
Fionn Allen has no reportable disciplinary history.
Item 4 Other Business Activities
A. Investment-Related Activities
1. Fionn Allen is not engaged in any other investment-
related activities.
2. Fionn Allen does not receive commissions, bonuses, or
other compensation on the sale of securities or other investment
products.
B. Non Investment-Related Activities
Item 5 Additional Compensation
Fionn Allen does not receive any economic benefit from a non-advisory client for
advisory services.
Item 6 Supervision
Supervisor: Timothy F Bock
Title: President
Phone Number: 702-838-9999