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Form ADV Part 2A Brochure
Cover Page - Item 1
AGH Wealth Advisors, LLC
301 N. Main, Suite 1700
Wichita, Kansas 67202-4868
Phone: (316) 267-3220
Fax: (316) 291-4115
www.aghwealth.com
July 15, 2025
AGH Wealth Advisors, LLC (“AGH Wealth”) is an investment advisor registered with the Securities and Exchange
Commission (“SEC”). An "investment adviser" means any person who, for compensation, engages in the business of
advising others, either directly or through publications or writings, as to the value of securities or as to the
advisability of investing in, purchasing, or selling securities, or who, for compensation and as part of a regular
business, issues or promulgates analyses or reports concerning securities. Registration with the SEC or any state
securities authority does not imply a certain level of skill or training.
This Disclosure Brochure provides information about the qualifications and business practices of AGH Wealth. If you
have any questions about the contents of this brochure, please contact us at (316) 267-3220. The information in this
Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority.
Additional information about AGH Wealth is also available on the SEC’s website at www.adviserinfo.sec.gov.
AGH Wealth Advisors, LLC
Form ADV Part 2A
Page 2
Material Changes - Item 2
The purpose of this page is to inform you of any material changes since the previous version of AGH Wealth
Advisors, LLC’s Form ADV Part 2 disclosure brochure. We have not made any material changes to this brochure.
Annually, we will review and update this brochure, as needed, to make sure that it remains current.
On March 7, 2025, we submitted our annual updating amendment for fiscal year 2024. We amended Item 4 of
our Form ADV Part 2A Brochure to reflect discretionary assets under management of $439,945,283 and non-
discretionary assets under management of $0. We also provide consulting services over an additional $44,515,280
in retirement plan assets on a non-discretionary basis.
If you would like to receive a complete copy of our current brochure free of charge at any time, please contact us
at (316) 267-3220 or at info@aghwealth.com.
AGH Wealth Advisors, LLC
Form ADV Part 2A
Page 3
Table of Contents - Item 3
Contents
Form ADV Part 2A Brochure ..................................................................................................................... 1
Cover Page - Item 1 ................................................................................................................................... 1
Material Changes - Item 2 ......................................................................................................................... 2
Table of Contents - Item 3 ........................................................................................................................ 3
Advisory Business - Item 4 ........................................................................................................................ 4
Fees and Compensation - Item 5 .............................................................................................................. 6
Performance-Based Fees and Side-By-Side Management - Item 6 ........................................................ 10
Types of Clients - Item 7.......................................................................................................................... 10
Methods of Analysis, Investment Strategies and Risk of Loss - Item 8................................................... 11
Disciplinary Information - Item 9 ............................................................................................................ 18
Other Financial Industry Activities or Affiliations - Item 10 .................................................................... 18
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Item 11 ........... 19
Brokerage Practices - Item 12 ................................................................................................................. 20
Review of Accounts - Item 13 ................................................................................................................. 21
Client Referrals and Other Compensation - Item 14 .............................................................................. 22
Custody - Item 15 .................................................................................................................................... 22
Investment Discretion - Item 16 ............................................................................................................. 23
Voting Client Securities - Item 17 ........................................................................................................... 23
Financial Information - Item 18 .............................................................................................................. 23
Requirements of State-Registered Advisers - Item 19 ............................................................................ 24
Form ADV Part 2A, Appendix 1: Wrap Fee Program Brochure ................................................................. 0
Cover Page - Item 1 ................................................................................................................................... 0
Material Changes - Item 2 ......................................................................................................................... 1
Table of Contents - Item 3 ........................................................................................................................ 2
Services Fees and Compensation - Item 4 ................................................................................................ 3
Account Requirements and Types of Clients - Item 5 ............................................................................... 6
Portfolio Manager Selection and Evaluation - Item 6 ............................................................................... 6
Client Information Provided to Portfolio Managers - Item 7 .................................................................... 7
Client Contact with Portfolio Managers - Item 8 ...................................................................................... 7
Additional Information - Item 9 ................................................................................................................ 8
Requirements for State-Registered Advisors - Item 10 .......................................................................... 10
AGH Wealth Advisors, LLC
Form ADV Part 2A
Page 4
Advisory Business - Item 4
AGH Wealth Advisors, LLC (“AGH Wealth”) is a limited liability company formed under the laws of the State of
Kansas and based in Wichita. We are licensed with the SEC as an investment adviser, and have been providing
investment advisory services since 2008.
Allen, Gibbs & Houlik, L.C. is the sole owner of AGH Wealth, and Paul S. Allen, Managing Member and Brad J.
Bechtel, President/Chief Compliance Officer are the principals and management persons of the firm.
You may see the term “Associated Person” throughout this Disclosure Brochure. As used in this Disclosure
Brochure, this term refers to anyone from our firm who is an officer, employee, and any individual providing
investment advice on behalf of our firm. Such persons are properly registered as Investment Adviser
Representatives (“IARs”) in all required jurisdictions.
Currently, we offer the following investment advisory services, personalized to each individual client:
Portfolio Management Services
•
• General Consulting Services
• Retirement Plan Consulting
• Referrals to Third Party Investment Advisers
Portfolio Management Services - Wrap Fee Program
AGH Wealth is the portfolio manager and sponsor of the AGH Wealth Wrap Fee Program. A wrap fee program
combines portfolio management, advisory services, and trade execution for a single fee. AGH Wealth, as portfolio
manager is responsible for the research, security selection, and implementation of transaction orders in the
Client's account. The transactions in the Client's account will be executed by and custodied at LPL Financial, LLC
(“LPL”), a FINRA-registered broker-dealer, member SIPC. The Client pays AGH Wealth an all inclusive Wrap fee.
AGH Wealth pays LPL a portion of this fee for trade execution expenses. Detailed information about the AGH
Wealth Wrap Fee Program and program fees is provided in the Form ADV Part 2A, Appendix 1 (Wrap Brochure)
that is attached to this Form ADV Part 2A Disclosure Brochure.
General Consulting Services
AGH Wealth provides general consulting services that focus on the specific needs and concerns of the client.
Advisory consulting services may include giving advice on investment and investment related matters. These
services include the identification of financial goals and objectives, collection and assessment of all relevant data,
identification of financial problems and formulation of solutions, and the preparation of a financial plan in the
form of specific written recommendations. The services we provide will typically focus on one or more of the
following areas:
Retirement Planning
Retirement Planning is a process of determining retirement income goals and the actions and decisions necessary
to achieve those goals. Retirement planning includes identifying sources of income, estimating expenses,
implementing a savings program and managing assets. Future cash flows are estimated to determine if the
retirement income goal will be achieved.
Tax Planning
The goal of tax planning is to arrange your financial affairs so as to minimize your taxes. There are three basic
ways to reduce your taxes, and each basic method might have several variations. You can reduce your income,
increase your deductions, and take advantage of tax credits.
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Form ADV Part 2A
Page 5
Investment Planning
The goal of investment planning is to determine the investment mix and policy, matching investments to
objectives, asset allocation for individuals and institutions, and balancing risk against performance. The process
realizes strengths, weaknesses, opportunities and risks in the choice of debt vs. equity, domestic vs. international,
growth vs. safety, and many other tradeoffs encountered in the attempt to maximize return at a given risk.
Financial plans are based on your financial situation and the financial information you provide to our firm. If your
financial situation, goals, objectives, or needs change, you must notify us promptly.
You may choose to accept or reject our recommendations. If you decide to proceed with our recommendations,
you may do so either through our firm or by using the advisory/brokerage firm of your choice.
Retirement Plan Consulting Services
AGH Wealth provides several advisory services separately or in combination. While the primary clients for these
services will be pension, profit sharing and 401(k) plans, AGH Wealth will also offer these services, where
appropriate, to individuals and trusts, estates and charitable organizations. Retirement Plan consulting services
are comprised of four distinct services. Clients may choose to use any or all of these services.
Investment Policy Statement Preparation
AGH Wealth will meet with the client to determine investment needs and goals. AGH Wealth will prepare a
written Investment Policy Statement (“IPS”) stating those needs and goals and creating a policy to help achieve
these goals. The IPS will also list the criteria for selection of investment vehicles and the procedures and timing
interval for monitoring of investment performance.
Selection of Investments
AGH Wealth will review various investments, consisting of one or all of the following: individual equities, bonds,
other investment products and mutual funds (both index and managed) to determine which of these investments
are appropriate to implement the client's IPS. The number of investments to be recommended will be determined
by the client, based on the IPS.
Investment Performance Monitoring
Client investments will be monitored continuously based on the procedures and timing intervals outlined in the
IPS. Although AGH Wealth will not be involved in any way in the purchase or sale of these investments, AGH
Wealth will supervise the client's portfolio and will make recommendations to the client as market factors and
the client's needs dictate.
Employee Communications
For pension, profit sharing and 401(k) plans where the individual account participant exercises control over assets
in his/her own account (''self-directed plans''), AGH Wealth also provides educational support and investment
workshops designed for the Plan participants. The nature of the topics to be covered will be determined by AGH
Wealth and the client under the guidelines established in ERISA Section 404(c).
The educational support and investment workshops will also provide Plan participants with individualized,
tailored investment advice or individualized, tailored asset allocation recommendations.
Other retirement plan consulting services are available on request. All of our retirement plan consulting services,
whether general or customized, will be outlined in an agreement that shows exactly which services will be
provided and at what fee for those services.
All client retirement plans are regulated under the Employee Retirement Income Securities Act (“ERISA”). AGH
Wealth will provide consulting services to the plan fiduciaries as described above. Typically, the named plan
fiduciary must make the ultimate decision as to retaining the services of such investment advisers as the firm
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Form ADV Part 2A
Page 6
recommends. The plan fiduciary is free to seek independent advice about the appropriateness of any
recommended services for the plan.
Selection of Third Party Investment Advisers
AGH Wealth has entered into agreements with various third party investment advisers for the provision of certain
investment advisory services. Factors considered in the selection of a third party advisor include but may not be
limited to: i) AGH Wealth’s preference for a particular third party advisor; ii) the client’s risk tolerance, goals and
objectives, as well as investment experience; and, iii) the amount of client assets available for investment. In order
to assist clients in the selection of a third party advisor, an Associated Person of AGH Wealth will typically gather
information from the client about the client’s financial situation, investment objectives, and reasonable
restrictions the client wants imposed on the management of the account.
Generally, securities transactions will be decided upon and executed by the third party advisor on a discretionary
basis. This means that the manager selected will have the ability to buy and sell securities in your account without
obtaining your approval. AGH Wealth and its Associated Persons will not manage, or obtain discretionary
authority over the assets in accounts participating in these programs; however, clients may grant AGH Wealth the
discretionary authority to hire and fire such third party managers. Generally, clients may not impose restrictions
on investing in certain securities or types of securities in accounts managed by a third party advisor.
Associated Persons of AGH Wealth will periodically review reports provided to the client. An Associated Person
of AGH Wealth will contact the client at least annually, or more often as agreed upon with each client, to review
the client’s financial situation and objectives, communicate information to the third party advisor managing the
account as necessary, and to assist the client in understanding and evaluating the services provided by the third
party advisor. Clients will be expected to notify AGH Wealth of any changes in their financial situation, investment
objectives, or account restrictions.
interested
The third party advisor may offer wrapped or non-wrapped pricing options. Wrap pricing structures allow the
client to pay an all-inclusive fee for management, brokerage, clearance, custody and administrative services. In a
non-wrap pricing structure, the third party advisor’s fee may be separated from the advisory fee charged by AGH
Wealth. Transaction costs may also be charged for the execution and clearance of advisory transactions directed
by such Third Party Advisory Services. A complete description of the programs and services provided, the amount
of total fees, the payment structure, termination provisions and other aspects of each program are detailed and
disclosed in: i) the third party advisor’s Form ADV Part 2A; ii) the program wrap brochure (if applicable) or other
applicable disclosure documents; iii) the disclosure documents of the portfolio manager(s) selected; or, iv) the
third party advisor’s account opening documents. A copy of all relevant disclosure documents of the third party
in these
individual portfolio manager(s) will be provided to anyone
advisor and of the
programs/managers.
Assets Under Management
As of December 31, 2024, we manage $439,945,283 in client assets on a discretionary basis, and $0 in client assets
on a non-discretionary basis. We also provide consulting services over an additional $44,515,280 in retirement
plan assets on a non-discretionary basis.
Fees and Compensation - Item 5
AGH Wealth charges the following fees for its investment advisory services:
Portfolio Management Services - Wrap Fee Program Fees
Detailed information about the AGH Wealth Wrap Fee Program and program fees is provided in the Form ADV
Part 2A, Appendix 1 (Wrap Brochure) that is attached to this Form ADV Part 2A Disclosure Brochure.
AGH Wealth Advisors, LLC
Form ADV Part 2A
Page 7
Retirement Plan Consulting and General Consulting Services Fees
Advisory and retirement plan consulting services are offered for negotiable hourly rate of $350. Occasionally, we
may opt to charge a fixed fee or a fee based on a percentage of plan assets. This fee can range from 0.15% to
2.00%. In any case, the exact fee payable by the client will be clearly listed in the services agreement signed by
the firm and the client. All Fees are payable as invoiced. AGH Wealth will not have access to client funds for
payment of fees without the client’s written consent.
AGH Wealth or the client may terminate the Consulting Agreement in accordance with the terms of the
Agreement. Refunds are not applicable as fees are payable in arrears.
Third Party Adviser (TPAs) Fees
AGH Wealth will perform management searches of various independent registered investment advisers for
referral to AGH Wealth clients. AGH Wealth will share in the fee paid to the TPA. The management fee is disclosed
in the TPA's disclosure documents. These fees may or may not be negotiable. AGH Wealth's compensation may
differ depending upon the firm’s individual agreement with each TPA. AGH Wealth or its Associated Persons may
have an incentive to recommend one TPA over another TPA with whom it has less favorable compensation
arrangements or other advisory programs offered by TPAs with which it has no compensation arrangements.
Additional Fees and Expenses
The fees AGH Wealth charges are negotiable based on the amount of assets under management, complexity of
Client goals and objectives, and level of services rendered. Fees are charged as described above and are not based
on a share of capital gains of the funds of any advisory Client.
Negotiability of Fees: We allow Associated Persons servicing the account to negotiate the exact investment
management fees within the range disclosed in our Form ADV Part 2A Brochure. As a result, the Associated Person
servicing your account may charge more or less for the same service than another Associated Person of our firm.
Further, our annual investment management fee may be higher than that charged by other investment advisors
offering similar services/programs.
Billing on Cash Positions: The firm treats cash and cash equivalents as an asset class. Accordingly, unless otherwise
agreed in writing, all cash and cash equivalent positions (e.g., money market funds, etc.) are included as part of
assets under management for purposes of calculating the firm’s advisory fee. At any specific point in time,
depending upon perceived or anticipated market conditions/events (there being no guarantee that such
anticipated market conditions/events will occur), the firm may maintain cash and/or cash equivalent positions for
defensive, liquidity, or other purposes. While assets are maintained in cash or cash equivalents, such amounts
could miss market advances and, depending upon current yields, at any point in time, the firm’s advisory fee could
exceed the interest paid by the client’s cash or cash equivalent positions.
Periods of Portfolio Inactivity: The firm has a fiduciary duty to provide services consistent with the client’s best
interest. As part of its investment advisory services, the firm will review client portfolios on an ongoing basis to
determine if any changes are necessary based upon various factors, including but not limited to investment
performance, fund manager tenure, style drift, account additions/withdrawals, the client’s financial
circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may
be extended periods of time when the firm determines that changes to a client’s portfolio are neither necessary
nor prudent. Notwithstanding, unless otherwise agreed in writing, the firm’s annual investment advisory fee will
continue to apply during these periods, and there can be no assurance that investment decisions made by the
firm will be profitable or equal any specific performance level(s).
All fees paid to AGH Wealth for investment advisory services are separate and distinct from the fees and expenses
charged to shareholders by investment companies like unit investment trusts, mutual funds or exchange traded
funds. These fees and expenses are described in each fund's prospectus. These fees generally include a
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Form ADV Part 2A
Page 8
management fee, other fund expenses, and a possible distribution fee. If the fund also imposes sales charges, you
may pay an initial or deferred sales charge.
You could invest in a mutual fund directly, without the services of AGH Wealth. In which case, you would not
receive ongoing planning and portfolio management services provided by AGH Wealth, which are designed,
among other things, to assist you in determining which mutual fund or funds are most appropriate to your
financial condition and objectives. Accordingly, you should review both the fees charged by the funds and the
fees charged by AGH Wealth to fully understand the total amount of fees to be paid by you to evaluate the
advisory services being provided. Although AGH Wealth uses its best efforts to purchase lower cost mutual fund
shares when available, some mutual fund companies do not offer institutional classes to us or funds that do not
pay 12b-1 distribution fees.
ERISA Accounts: AGH Wealth 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. To avoid engaging in prohibited transactions, AGH Wealth
may only charge fees for investment advice about products for which our firm and/or our related persons do not
receive any commissions or 12b-1 fees, or conversely, investment advice about products for which our firm and/or
our related persons receive commissions or 12b-1 fees, however, only when such fees are used to offset AGH
Wealth's advisory fees.
IRA Rollover Considerations: As a normal extension of financial advice, we provide education or recommendations
related to the rollover of an employer-sponsored retirement plan. A plan participant leaving employment has
several options. Each choice offers advantages and disadvantages, depending on desired investment options and
services, fees and expenses, withdrawal options, required minimum distributions, tax treatment, and the
investor's unique financial needs and retirement plans. The complexity of these choices may lead an investor to
seek assistance from us. An Associated Person who recommends an investor roll over plan assets into an
Individual Retirement Account (“IRA”) may earn an asset-based fee as a result, but no compensation if assets are
retained in the plan. Thus, we have an economic incentive to encourage an investor to roll plan assets into an IRA.
In most cases, fees and expenses will increase to the investor as a result because the above-described fees will
apply to assets rolled over to an IRA and outlined ongoing services will be extended to these assets. We are
fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding
your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title
I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are
laws governing retirement accounts. We have to act in your best interests and not put our interest ahead of yours.
At the same time, the way we make money creates some conflicts with your interests.
Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of fees in excess of $1,200,
six or more months in advance of services rendered.
Important Disclosures about Mutual Fund Share Classes: Mutual funds generally offer multiple share classes
based upon certain eligibility and/or purchase requirements. For instance, in addition to retail share classes
(typically referred to as class A, class B and class C shares), mutual funds may also offer institutional share classes
or other share classes that are specifically designed for purchase by investors who meet certain specified eligibility
criteria, including, for example, whether an account meets certain minimum dollar amount thresholds or is
enrolled in an eligible fee-based investment advisory program. Institutional share classes usually have a lower
expense ratio than other share classes. AGH Wealth and its Associated Persons have a financial incentive to
recommend or select share classes that have higher expense ratios because such share classes generally result in
higher compensation. We have taken steps to address this conflict of interest, including providing Associated
Persons with training and guidance on this issue, as well as by conducting periodic reviews of client holdings in
mutual fund investments to ensure the appropriateness of mutual fund share class selections and whether
AGH Wealth Advisors, LLC
Form ADV Part 2A
Page 9
alternative mutual fund share class selections are available that might be more appropriate given the client’s
particular investment objectives and any other appropriate considerations relevant to mutual fund share class
selection.
Certain money market funds and other mutual funds in which clients invest make payments to AGH Wealth or
our Associated Persons, pursuant to a Rule 12b-1 distribution plan or other arrangement as compensation for
distribution, shareholder services, recordkeeping, or administrative services. These payments are generally paid
from the fund’s total assets and can be paid by a fund’s adviser or distributor. The Rule 12b-1 distribution plan
and other fee arrangements are disclosed in each fund’s registration statement.
For Clients investing in mutual funds, AGH Wealth requires that the Associated Person purchase the share class
most beneficial to the Client, generally the institutional or advisory share class. In some cases these share classes
are not made available by the sponsor fund. Here, AGH Wealth will direct the Associated Person to seek a
comparable, similar mutual fund that provides an advisory share class, and offer the fund and share class to the
Client. If no comparable fund with an advisory share class is available, the Client may pay higher fees that include
12b-1 fees. Although AGH Wealth automatically credits client accounts with any 12b-1 fees received during the
period an account is managed by AGH Wealth, clients should not assume that they will be invested in the share
class with the lowest available expense ratio.
Class A shares that transfer into Client accounts are periodically converted to the advisory or institutional share
class. The Firm requires advisory or institutional share classes in accounts, and does not permit purchases of Class
A, B or C shares in advisory accounts unless there is no advisory share class available, and no similar mutual fund
with an advisory share class. Although we anticipate that this would occur infrequently, the purchase would be
made at Net Asset Value (“NAV”) or the commission would be credited to the Client. Although AGH Wealth uses
its best efforts to purchase lower cost mutual fund shares when available, some mutual fund companies do not
offer institutional classes or funds that do not pay 12b-1 distribution fees.
Please contact us for more information about share class eligibility. Further information regarding fees and
charges assessed by a mutual fund is available in each mutual fund’s prospectus.
Compensation for the Sale of Securities or Other Investment Products
Compensation for the Sale of Securities
Certain Executive officers and other Associated Persons of AGH Wealth are registered representatives of LPL
Financial, LLC (“LPL”), a licensed full service securities broker-dealer and investment adviser under federal and
state securities laws. LPL is a member of the Financial Industry Regulatory Authority ("FINRA") and the Securities
Investors Protection Corporation (“SIPC”). In their capacity as registered representatives, these persons will
receive commission-based compensation in connection with the purchase and sale of securities, including 12b-1
fees for the sale of investment company products. Compensation earned by these persons in their capacities as
registered representatives, is separate and in addition to our advisory fees. This practice presents a conflict of
interest because persons providing investment advice on behalf of our firm who are registered representatives
have an incentive to effect securities transactions for the purpose of generating commissions rather than solely
based on your needs. As a matter of general policy, we aggressively discourage activities that put your interests
anywhere but first. Additionally, we have instituted compliance procedures and a code of ethics that requires our
Associated Persons to uphold their fiduciary duty by acting in the best interest of the Client. Clients of our firm
have the option to purchase investment products that we recommend through other brokers and agents that
are not affiliated with our firm.
Executive Officers and Associated Persons of AGH Wealth will never receive commissions for securities
transactions in advisory accounts managed by AGH Wealth.
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Form ADV Part 2A
Page 10
Compensation for the Sale of Insurance Products
Certain Executive officers and other Associated Persons of our firm are licensed as independent insurance agents.
These persons will earn commission-based compensation for selling insurance products, including insurance
products they sell to our clients. Insurance commissions earned by these persons are separate from and in
addition to our advisory fees. The sale of insurance instruments and other commissionable products offered by
Associated Persons are intended to complement our advisory services. However, this practice presents a conflict
of interest because persons providing investment advice on behalf of our firm who are insurance agents have an
incentive to recommend insurance products to you for the purpose of generating commissions rather than solely
based on your needs. We address this conflict of interest by recommending insurance products only where we,
in good faith, believe that it is appropriate for the client’s particular needs and circumstances and only after a full
presentation of the recommended insurance product to our client. In addition, we explain the insurance
underwriting process to our clients to illustrate how the insurer also reviews the client’s application and
disclosures prior to the issuance of a resulting insuring agreement. Clients to whom the firm offers advisory
services are informed that they are under no obligation to purchase insurance services. Clients who do choose to
purchase insurance services are under no obligation to use our licensed Associated Persons and may use the
insurance brokerage firm and agent of their choice.
Where fixed annuities are sold, clients should also note that the annuity sales result in substantial up-front
commissions and ongoing trails based on the annuity’s total value. In addition, many annuities contain surrender
charges and/or restrictions on access to your funds. Payments and withdrawals can have tax consequences.
Optional lifetime income benefit riders are used to calculate lifetime payments only and are not available for cash
surrender or in a death benefit unless specified in the annuity contract. In some annuity products, fees can apply
when using an income rider. Annuity guarantees are based on the financial strength and claims-paying ability of
the issuing insurance company. We urge our clients to read all insurance contract disclosures carefully before
making a purchase decision. Rates and returns mentioned on any program presented are subject to change
without notice. Insurance products are subject to fees and additional expenses.
Performance-Based Fees and Side-By-Side Management - Item 6
Performance-based fees are based on a share of capital gains on or capital appreciation of the Client’s assets.
Side-by-side management refers to the practice of managing accounts that are charged performance-based fees
while at the same time managing accounts that are not charged performance-based fees. We do not accept
performance-based fees or participate in side-by-side management. Our fees are calculated as described in the
Fees and Compensation section above, and are not charged on the basis of a share of capital gains upon, or capital
appreciation of, the funds in your advisory account(s).
Types of Clients - Item 7
We offer investment advisory services to individuals, banks and thrift institutions, retirement plans, trusts,
estates, charitable organizations, corporations, and other business or government entities.
AGH Wealth requires a minimum account size of $5,000 to establish an advisory relationship.
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Form ADV Part 2A
Page 11
Methods of Analysis, Investment Strategies and Risk of Loss - Item 8
AGH Wealth advisors may use various methods to determine an appropriate investment strategy for your
portfolio with the goal of reducing risk and increasing performance in each customized portfolio. We seek to
recommend investment strategies or products that will give you a diversified portfolio consistent with your
investment objective. We do this by analyzing the various products, investment strategies, and money
management firms to which we provide access. That analysis includes a review of the structure, cost, and
investment performance history of each program.
Methods of Analysis
AGH Wealth uses Fundamental and Technical analysis in formulating investment advice:
Fundamental analysis is a method of evaluating a company or security by attempting to measure its intrinsic value.
In other words, trying to determine a company’s or a security’s true value by looking at all aspects of the business,
including both tangible factors (e.g., machinery buildings, land, etc.) and intangible factors (e.g., patents,
trademarks, “brand” names, etc.). Fundamental analysis also involves examining related economic factors (e.g.,
overall economy and industry conditions, etc.), financial factors (e.g., company debt, interest rates, management
salaries and bonuses, etc.), qualitative factors (e.g., management expertise, industry cycles, labor relations, etc.),
and quantitative factors (e.g., debt-to-equity and price-to-equity ratios). The end goal of performing fundamental
analysis is to produce a value that an investor can compare with the security's current price in hopes of
determining what sort of position to take with that security (underpriced = buy, overpriced = sell or short). This
method of security analysis is considered to be the opposite of technical analysis. Fundamental analysis is about
using real data to evaluate a security's value. Although most analysts use fundamental analysis to value stocks,
this method of valuation can be used for just about any type of security.
Technical Analysis is a technique that relies on the assumption that current market data (such as charts of price,
volume, and open interest) can help predict future market trends, at least in the short term. It assumes that
market psychology influences trading and can predict when stocks will rise or fall. Technical trading models are
mathematically driven based upon historical data and trends of domestic and foreign market trading activity,
including various industry and sector trading statistics within such markets. Technical trading models, through
mathematical algorithms, attempt to identify when markets are likely to increase or decrease and identify
appropriate entry and exit points. The primary risk of technical trading models is that historical trends and past
performance cannot predict future trends, and there is no assurance that the mathematical algorithms employed
are designed properly, updated with new data, and can accurately predict future market, industry, and sector
performance.
In some cases, AGH Wealth utilizes investment research provided by unaffiliated third-party research providers.
Investment Strategies
We may use one or more of the following investment strategies when advising you on investments:
Long Term Purchases – securities purchased with the expectation that the value of those securities will grow over
a relatively long period of time, generally greater than one year. Using a long-term purchase strategy generally
assumes the financial markets will go up in the long-term which may not be the case. There is also the risk that
the segment of the market that you are invested in or perhaps just your particular investment will go down over
time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity
cost - "locking-up" assets that may be better utilized in the short-term in other investments.
Short Term Purchases – securities purchased with the expectation that they will be sold within a relatively short
period of time, generally less than one year, to take advantage of the securities' short-term price fluctuations.
Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform
AGH Wealth Advisors, LLC
Form ADV Part 2A
Page 12
in the short-term which may be very difficult and will incur a disproportionately higher amount of transaction
costs compared to long-term trading. There are many factors that can affect financial market performance in the
short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a
smaller impact over longer periods of times.
Trading – securities are sold within 30 days. The principal type of risk associated with trading is market risk. There
can be no assurance that a specific investment will achieve its investment objectives and past performance should
not be seen as a guide to future returns. The value of investments and the income derived may fall as well as rise
and investors may not recoup the original amount invested. Investments may also be affected by any changes in
exchange control regulation, tax laws, withholding taxes, international, political and economic developments, and
government, economic or monetary policies. Additionally, trading is speculative. Market movements are difficult
to predict and are influenced by, among other things, government trade, fiscal, monetary and exchange control
programs and policies; changing supply and demand relationships; national and international political and
economic events; changes in interest rates; and the inherent volatility of the marketplace. In addition,
governments from time to time intervene, directly and by regulation, in certain markets, often with the intent to
influence prices directly. The effects of governmental intervention may be particularly significant at certain times
in the financial instrument markets and such intervention (as well as other factors) may cause these markets to
move rapidly.
Margin Transactions – margin strategies allow an investor to purchase securities on credit and to borrow on
securities already in their custodial account. Interest is charged on any borrowed funds for the period of time that
the loan is outstanding. When you purchase securities, you may pay for the securities in full or you may borrow
part of the purchase price from your broker-dealer. If you intend to borrow funds in connection with your account,
you will be required to open a margin account, which will be carried by the broker-dealer of your account. The
securities purchased in such an account are the broker-dealer’s collateral for its loan to you. If the securities in a
margin account decline in value, the value of the collateral supporting this loan also declines, and, as a result, a
brokerage firm is required to take action, such as issue a margin call and/or sell securities or other assets in your
accounts, in order to maintain necessary level of equity in the account. It is important that you fully understand
the risks involved in trading securities on margin, which are applicable to any margin account that you may
maintain, including any margin Account that may be established as a part of our advisory services and held by
your broker-dealer. These risks include the following:
•
•
•
•
•
You can lose more funds than you deposit in your margin account.
The broker-dealer can force the sale of securities or other assets in your account.
The broker-dealer can sell your securities or other assets without contacting you.
You may not be able to choose which securities or other assets in your margin account are liquidated or
sold to meet a margin call.
The broker-dealer may move securities held in your cash account to your margin account and pledge the
transferred securities.
You may not be entitled to an extension of time on a margin call.
•
Short Sales – Short sales are securities transactions in which an investor sells securities that were borrowed in
anticipation of a price decline. The investor is then required to return an equal number of shares at some point
in the future. The principal risk associates with short sales is that while a short seller will profit if the stock goes
down in price, if the price of the shares increase, the potential losses are unlimited.
Option Writing – an option is the right either to buy or sell a specified amount or value of a particular underlying
investment instrument at a fixed price (i.e. the “exercise price”) by exercising the option before its specified
expiration date. Options giving you the right to buy are called “call” options. Options giving you the right to sell
are called “put” options. When trading options on behalf of a Client, we generally use covered options. Covered
options involve options trading when you own the underlying instrument on which the option is based.
Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts
AGH Wealth Advisors, LLC
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Page 13
are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock.
This leverage can compound gains or losses.
Risk of Loss
Clients should be aware that investing in securities involves a risk of loss that they should be prepared to bear.
Past performance is not indicative of future results. Therefore, you should never assume that future performance
of any specific investment or investment strategy will be profitable. Investing in securities (including stocks,
mutual funds, and bonds, etc.) involves risk of loss. Further, depending on the different types of investments there
may be varying degrees of risk. You should be prepared to bear investment loss including loss of original principal.
Because of the inherent risk of loss associated with investing, our firm is unable to represent, guarantee, or even
imply that our services and methods of analysis can or will predict future results, successfully identify market tops
or bottoms, or insulate you from losses due to market corrections or declines.
There are certain additional risks associated with investing in securities, as described below:
Recommendation of Particular Types of Securities
As disclosed under the “Advisory Business” section in this Brochure, we provide advice on various types of
securities and we do not necessarily recommend one particular type of security over another since each Client
has different needs and different tolerance for risk. Each type of security has its own unique set of risks associated
with it and it would not be possible to list here all of the specific risks of every type of investment. Even within
the same type of investment, risks can vary widely. However, in very general terms, the higher the anticipated
return of an investment, the higher the risk of loss associated with it.
General Investment Risk: All investments come with the risk of losing money. Investing involves substantial risks,
including complete possible loss of principal plus other losses and may not be suitable for many members of the
public. Investments, unlike savings and checking accounts at a bank, are not insured by the government to protect
against market losses. Different market instruments carry different types and degrees of risk and you should
familiarize yourself with the risks involved in the particular market instruments in which you intend to invest.
Loss of Value: There can be no assurance that a specific investment will achieve its investment objectives and
past performance should not be seen as a guide to future returns. The value of investments and the income
derived may fall as well as rise and investors may not recoup the original amount invested. Investments may also
be affected by any changes in exchange control regulation, tax laws, withholding taxes, international, political and
economic developments, and governmental economic or monetary policies.
Interest Rate Risk: Fixed income securities and funds that invest in bonds and other fixed income securities may
fall in value if interest rates change. Generally, the prices of debt securities rise when interest rates fall, and their
prices fall when interest rates rise. Longer-term debt securities are usually more sensitive to interest rate changes.
Credit Risk: Investments in bonds and other fixed income securities are subject to the risk that the issuer(s) may
not make required interest payments. An issuer suffering an adverse change in its financial condition could lower
the credit quality of a security, leading to greater price volatility of the security. A lowering of the credit rating of
a security may also offset the security's liquidity, making it more difficult to sell. Funds investing in lower quality
debt securities are more susceptible to these problems and their value may be more volatile.
Foreign Exchange Risk: Foreign investments may be affected favorably or unfavorably by exchange control
regulations or changes in the exchange rates. Changes in currency exchange rates may influence the share value,
the dividends or interest earned and the gains and losses realized. Exchange rates between currencies are
determined by supply and demand in the currency exchange markets, the international balance of payments,
governmental intervention, speculation, and other economic and political conditions. If the currency in which a
security is denominated appreciates against the US Dollar, the value of the security will increase. Conversely, a
decline in the exchange rate of the currency would adversely affect the value of the security.
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Form ADV Part 2A
Page 14
Equity (stock) Market Risk: Common stocks are susceptible to general stock market fluctuations and to volatile
increases and decreases in value as market confidence in and perceptions of their issuers change. If you held
common stock, or common stock equivalents, of any given issuer, you would generally be exposed to greater risk
than if you held preferred stocks and debt obligations of the issuer.
Company Risk: When investing in stock positions, there is always a certain level of company or industry specific
risk that is inherent in each investment. This is also referred to as unsystematic risk and can be reduced through
appropriate diversification. There is the risk that the company will perform poorly or have its value reduced based
on factors specific to the company or its industry. For example, if a company’s employees go on strike or the
company receives unfavorable media attention for its actions, the value of the company may be reduced.
Fixed Income Risk: When investing in bonds, there is the risk that the issuer will default on the bond and be
unable to make payments. Further, individuals who depend on set amounts of periodically paid income face the
risk that inflation will erode their spending power. Fixed-income investors receive set, regular payments that face
the same inflation risk. In addition pricing risk if not held to maturity and interest rate move.
Risks Associated with Investing in Mutual Funds: Mutual funds are professionally managed collective investment
systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments,
other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the
fund's investments in accordance with the fund's investment objective. While mutual funds generally provide
diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market,
primarily invests in small cap or speculative companies, uses leverage (i.e., borrows money) to a significant
degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different
types of securities. The returns on mutual funds can be reduced by the costs to manage the funds. In addition,
while some mutual funds are “no load” and charge no fee to buy into, or sell out of, other types of mutual funds
do charge such fees which can also reduce returns.
Risks Associated with Investing in Exchange Traded Funds (ETF): Investing in ETFs carries the risk of capital loss
(sometimes up to a 100% loss in the case of a stock holding bankruptcy). Investments in these securities are not
guaranteed or insured by the FDIC or any other government agency.
Management Risk: Your investment with our firm varies with the success and failure of our investment
strategies, research, analysis and determination of portfolio securities. If our investment strategies do not
produce the expected returns, the value of the investment will decrease.
Municipal Securities Risk: The value of municipal obligations can fluctuate over time, and may be affected by
adverse political, legislative and tax changes, as well as by financial developments that affect the municipal
issuers. Because many municipal obligations are issued to finance similar projects by municipalities (e.g., housing,
healthcare, water and sewer projects, etc.), conditions in the sector related to the project can affect the overall
municipal market. Payment of municipal obligations may depend on an issuer’s general unrestricted revenues,
revenue generated by a specific project, the operator of the project, or government appropriation or aid. There
is a greater risk if investors can look only to the revenue generated by the project. In addition, municipal bonds
generally are traded in the “over-the-counter” market among dealers and other large institutional investors. From
time to time, liquidity in the municipal bond market (the ability to buy and sell bonds readily) may be reduced in
response to overall economic conditions and credit tightening.
Alternatives Risk: Non-traded REITs, business development companies, limited partnerships, and direct
alternatives are subject to various ricks such as liquidity and property devaluation based on adverse economic
and real estate market conditions and may not be suitable for all investors. A prospectus that discloses all risks,
fees, and expenses may be obtained from your advisor. Read the prospectus carefully before investing. This is not
a solicitation or offering which can only be made in conjunction with a copy of the prospectus. Investors
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Form ADV Part 2A
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considering an investment strategy utilizing alternative investments should understand that alternative
investments are generally considered speculative in nature and may involve a high degree of risk, particularly if
concentrating investments in one or few alternative investments.
Foreign Securities Risk: Foreign securities are subject to additional risks not typically associated with investments
in domestic securities. These risks may include, among others, currency risk, country risks (political, diplomatic,
regional conflicts, terrorism, war, social and economic instability, currency devaluations and policies that have
the effect of limiting or restricting foreign investment or the movement of assets), different trading practices, less
government supervision, less publicly available information, limited trading markets and greater volatility. To the
extent that underlying funds invest in issuers located in emerging markets, the risk may be heightened by political
changes, changes in taxation, or currency controls that could adversely affect the values of these investments.
Emerging markets have been more volatile than the markets of developed countries with more mature
economies.
Sector Risk: Funds which concentrate their portfolio in a specific sector may carry a higher degree of risk due to
lower diversification and sector-specific risks. Because these investments are limited to a relatively narrow
segment of the economy, the funds' investments are not as diversified as most funds. This means that these funds
tend to be more volatile than other funds and their portfolio values can increase or decrease more rapidly. The
performance of each Fund may differ in direction and degree from that of the overall stock market.
Environmental, Social, and Governance Investment Criteria Risk: If a portfolio is subject to certain
environmental, social and governance (ESG) investment criteria it may avoid purchasing certain securities for ESG
reasons when it is otherwise economically advantageous to purchase those securities, or may sell certain
securities for ESG reasons when it is otherwise economically advantageous to hold those securities. In general,
the application of the portfolio’s ESG investment criteria may affect the portfolio’s exposure to certain issuers,
industries, sectors and geographic areas, which may affect the financial performance of the portfolio, positively
or negatively, depending on whether these issuers, industries, sectors or geographic areas are in or out of favor.
An adviser can vary materially from other advisers with respect to its methodology for constructing ESG portfolios
or screens, including with respect to the factors and data that it collects and evaluates as part of its process. As a
result, an adviser’s ESG portfolio or screen may materially differ from or contradict the conclusions reached by
other ESG advisers concerning the same issuers. Further, ESG criteria are dependent on data and are subject to
the risk that such data reported by issuers or received from third-party sources may be subjective, or it may be
objective in principle but not verified or reliable.
Small Capitalization: Funds which include smaller capitalization companies, may involve greater risk than funds
investing in larger, more established companies. For example, small capitalization companies may have limited
product lines, markets and financial or managerial resources. As a result, price movements in securities of smaller
capitalization companies may be more volatile. Transaction costs in securities of smaller capitalization companies
can be higher than those of larger capitalization companies and there may be less liquidity.
Risks Associated with Investing in Options: Transactions in options carry a high degree of risk. A relatively small
market movement will have a proportionately larger impact, which may work for or against the investor. The
placing of certain orders, which are intended to limit losses to certain amounts, may not be effective because
market conditions may make it impossible to execute such orders. Selling ("writing" or "granting") an option
generally entails considerably greater risk than purchasing options. Although the premium received by the seller
is fixed, the seller may sustain a loss well in excess of that amount. The seller will also be exposed to the risk of
the purchaser exercising the option and the seller will be obliged either to settle the option in cash or to acquire
or deliver the underlying investment. If the option is "covered" by the seller holding a corresponding position in
the underlying investment or a future on another option, the risk may be reduced.
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Concentrated Position Risk: Certain Associated Persons may recommend that clients concentrate account assets
in an industry or economic sector. In addition to the potential concentration of accounts in one or more sectors,
certain accounts may, or may be advised to, hold concentrated positions in specific securities. Therefore, at times,
an account may, or may be advised to, hold a relatively small number of securities positions, each representing a
relatively large portion of assets in the account. As a result, the account will be subject to greater volatility than a
more sector diversified portfolio. Investments in issuers within an industry or economic sector that experiences
adverse economic, business, political conditions or other concerns will impact the value of such a portfolio more
than if the portfolio’s investments were not so concentrated. A change in the value of a single investment within
the portfolio will affect the overall value of the portfolio and will cause greater losses than it would in a portfolio
that holds more diversified investments.
Inverse Funds: Inverse mutual funds and ETFs, which are sometimes referred to as "short" funds, seek to provide
the opposite of the single-day performance of the index or benchmark they track. Inverse funds are often
marketed as a way to profit from, or hedge exposure to, downward moving markets. Some inverse funds also use
leverage, such that they seek to achieve a return that is a multiple of the opposite performance of the underlying
index or benchmark (i.e., -200%, -300%). In addition to leverage, these funds may also use derivative instruments
to accomplish their objectives. As such, inverse funds are highly volatile and provide the potential for significant
losses.
Cybersecurity Risks: Our firm and our service providers are subject to risks associated with a breach in
cybersecurity. Cybersecurity is a generic term used to describe the technology, processes, and practices designed
to protect networks, systems, computers, programs, and data from cyber-attacks and hacking by other computer
users, and to avoid the resulting damage and disruption of hardware and software systems, loss or corruption of
data, and/or misappropriation of confidential information. In general, cyber-attacks are deliberate; however,
unintentional events may have similar effects. Cyber-attacks may cause losses to clients by interfering with the
processing of transactions, affecting the ability to calculate net asset value or impeding or sabotaging trading.
Clients may also incur substantial costs as the result of a cybersecurity breach, including those associated with
forensic analysis of the origin and scope of the breach, increased and upgraded cybersecurity, identity theft,
unauthorized use of proprietary information, litigation, and the dissemination of confidential and proprietary
information. Any such breach could expose our firm to civil liability as well as regulatory inquiry and/or action. In
addition, clients could be exposed to additional losses as a result of unauthorized use of their personal
information. While our firm has established a business continuity plan and systems designed to prevent cyber-
attacks, there are inherent limitations in such plans and systems, including the possibility that certain risks have
not been identified. Similar types of cyber security risks are also present for issuers of securities, investment
companies and other investment advisers in which we invest, which could result in material adverse
consequences for such entities and may cause a client's investment in such entities to lose value.
Pandemic Risk: Large-scale outbreaks of infectious disease can greatly increase morbidity and mortality over a
wide geographic area, crossing international boundaries, and causing significant economic, social, and political
disruption. It is difficult to predict the long-term impact of such events because they are dependent on a variety
of factors including the global response of regulators and governments to address and mitigate the worldwide
effects of such events. Workforce reductions, travel restrictions, governmental responses and policies and
macroeconomic factors will negatively impact investment returns.
Recommendation of Other Advisers: In the event we recommend a third-party investment adviser to manage all
or a portion of your assets, we will advise you on how to allocate your assets among various classes of securities
or third-party investment managers, programs, or managed model portfolios. As such, we will primarily rely on
investment model portfolios and strategies developed by the third-party investment advisers and their portfolio
managers. If there is a significant deviation in characteristics or performance from the stated strategy and/or
benchmark, we may recommend changing models or replacing a third-party investment adviser. The primary risks
associated with investing with a third party is that while a particular third party may have demonstrated a certain
level of success in the past; it may not be able to replicate that success in future markets. In addition, as we do
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Form ADV Part 2A
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not control the underlying investments in third party model portfolios, there is also a risk that a third party may
deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for
our clients. To mitigate this risk, we seek third parties with proven track records that have demonstrated a
consistent level of performance and success over time. A third party’s past performance is not a guarantee of
future results and certain market and economic risks exist that may adversely affect an account’s performance
that could result in capital losses in your account. Please refer to the third-party investment adviser’s advisory
agreements, Form ADV Brochure, and associated disclosure documents for details on their specific investment
strategies, methods of analysis, and associated risks.
Structured Notes: Below are some specific risks related to the structured notes recommended by our firm:
•
Complexity: Structured notes are complex financial instruments. Clients should understand the reference
asset(s) or index(es) and determine how the note’s payoff structure incorporates such reference asset(s)
or index(es) in calculating the note’s performance. This payoff calculation may include leverage
multiplied by the performance of the reference asset or index, protection from losses should the
reference asset or index produce negative returns, and/or fees. Structured notes may have complicated
payoff structures that can make it difficult for clients to accurately assess their value, risk and potential
for growth through the term of the structured note. Determining the performance of each note can be
complex and this calculation can vary significantly from note to note depending on the structure. Notes
can be structured in a wide variety of ways. Payoff structures can be leveraged, inverse, or inverse-
leveraged, which may result in larger returns or losses. Clients should carefully read the prospectus for a
structured note to fully understand how the payoff on a note will be calculated and discuss these issues
with our firm.
•
•
•
• Market risk. Some structured notes provide for the repayment of principal at maturity, which is often
referred to as “principal protection.” This principal protection is subject to the credit risk of the issuing
financial institution. Many structured notes do not offer this feature. For structured notes that do not
offer principal protection, the performance of the linked asset or index may cause clients to lose some,
or all, of their principal. Depending on the nature of the linked asset or index, the market risk of the
structured note may include changes in equity or commodity prices, changes in interest rates or foreign
exchange rates, and/or market volatility.
Issuance price and note value: The price of a structured note at issuance will likely be higher than the fair
value of the structured note on the date of issuance. Issuers now generally disclose an estimated value
of the structured note on the cover page of the offering prospectus, allowing investors to gauge the
difference between the issuer’s estimated value of the note and the issuance price. The estimated value
of the notes is likely lower than the issuance price of the note to investors because issuers include the
costs for selling, structuring, and/or hedging the exposure on the note in the initial price of their notes.
After issuance, structured notes may not be re-sold on a daily basis and thus may be difficult to value
given their complexity.
Liquidity: The ability to trade or sell structured notes in a secondary market is often very limited, as
structured notes (other than exchange-traded notes known as ETNs) are not listed for trading on
securities exchanges. As a result, the only potential buyer for a structured note may be the issuing
financial institution’s broker-dealer affiliate or the broker-dealer distributor of the structured note. In
addition, issuers often specifically disclaim their intention to repurchase or make markets in the notes
they issue. Clients should, therefore, be prepared to hold a structured note to its maturity date or risk
selling the note at a discount to its value at the time of sale.
Credit risk: Structured notes are unsecured debt obligations of the issuer, meaning that the issuer is
obligated to make payments on the notes as promised. These promises, including any principal
protection, are only as good as the financial health of the structured note issuer. If the structured note
issuer defaults on these obligations, investors may lose some, or all, of the principal amount they
invested in the structured notes as well as any other payments that may be due on the structured notes.
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Form ADV Part 2A
Page 18
Disciplinary Information - Item 9
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events
that would be material to your evaluation of us or of the integrity of our management. Neither we nor our
management persons have a history of material legal or disciplinary events.
Other Financial Industry Activities or Affiliations - Item 10
Allen, Gibbs & Houlik, L.C., the parent company of AGH Wealth, is a full service certified public accounting firm
providing a wide range of accounting services to individuals and business clients. Certain Associated Persons of
AGH Wealth are separately employed as accountants by Allen, Gibbs & Houlik, L.C.
These individuals, and other employees of Allen, Gibbs & Houlik, L.C, may recommend AGH Wealth to their clients,
and conversely Allen, Gibbs & Houlik, L.C may be recommended to advisory clients of AGH Wealth. As such, clients
should be aware that a conflict of interest is inherent in such an arrangement. However, clients of one firm are
not required to use the services of any affiliated firm.
Insight Wealth Strategies, LLC, is a licensed independent insurance agency affiliated with AGH Wealth through
common control and ownership. Agents of Insight Wealth Strategies, LLC can offer life insurance and fixed
annuities from a variety of product sponsors. Associated Persons of AGH Wealth who are licensed insurance
agents can effect transactions in insurance products for their clients and earn commissions for these activities.
The firm expects that clients to whom it offers advisory services may also be clients for whom Insight Wealth
Strategies, LLC acts as an insurance agency. Clients are instructed that the fees paid to the firm for advisory
services are separate and distinct from the commissions earned by Insight Wealth Strategies, LLC, for placing the
client in insurance products. Clients to whom the firm offers advisory services are informed that they are under
no obligation to use Insight Wealth Strategies, LLC or its associated persons for insurance services.
Associated Persons of AGH Wealth are registered representatives, licensed to sell securities through LPL Financial,
(“LPL”), an investment adviser and securities broker/dealer registered with the Securities and Exchange
Commission and Financial Industry Regulatory Authority. In this capacity, Associated Persons of the firm are
involved in the sale of securities of various types, including, but not limited to, stocks, bonds, and mutual funds.
Associated Persons of AGH Wealth may receive compensation on the sale of securities, including 12b-1
distribution fees from investment companies (mutual funds) in connection with the placement of clients’ funds
into investment companies, through their capacities as registered representatives of LPL. A conflict of interest is
present when an Associated Person of AGH Wealth recommends that a client invests in a security which results
in a commission being paid to the Associated Person.
Clients of our firm are under no obligation, contractually or otherwise, to purchase securities or insurance
products through any person affiliated with our firm.
Allen, Gibbs & Houlik, L.C., the parent company of AGH Wealth has a material ownership interest in the following
financial industry affiliates:
• AGH Advisors, LLC, a business management and operations consulting firm;
• AGH Benefit Resources, LLC, a human resources consulting firm;
• AGH Benefits Recordkeeping Services, LLC, an accounting and consulting services firm that specializes
in servicing qualified plans;
• AGH Consulting, Inc., a business consulting firm;
• AGH Employer Solutions, LLC, a payroll, human resources, and benefits consulting firm;
• AGH Financial Services, LLC, a mergers and acquisitions consulting firm;
AGH Wealth Advisors, LLC
Form ADV Part 2A
Page 19
• AGH Specialized Tax Solutions, LLC an accounting and consulting services firm that specializes in
complex taxation matters; and
• AGH University, LLC, a continuing education firm for accounting, human resources, and other corporate
professionals.
AGH Wealth will recommend the services of the above listed firms to clients who have a need for their respective
services. The above referenced firms can also refer their clients to AGH Wealth for investment advisory services.
Clients should note that these referral arrangements create a conflict of interest because they result in Allen,
Gibbs & Houlik, L.C.’s receipt of additional compensation in the form of a share of profits from these entities. To
address this conflict of interest, AGH Wealth has adopted a code of ethics that obliges all Associated Persons to;
(i) deal fairly with all clients when making investment decisions; (ii) to uphold their fiduciary duty at all times; and
(iii) to put the client's interest first. Clients are not required to use the services of any affiliated firms
recommended by AGH Wealth.
Recommendation of Other Advisors
We may recommend that you use a third-party investment adviser or program as part of our asset allocation and
investment strategy. In some cases, AGH Wealth will share in the compensation received by the third-party
investment adviser. As a result of such arrangements, we are incentivized to recommend only the investment
advisers from whom we receive solicitor/referral fees as opposed to another investment adviser from whom we
do not receive such fees. We continually monitor other investment advisers that we might recommend under a
solicitor arrangement. In the event that such investment advisers are not meeting the standards that we believe
meet your needs, we will seek other investment advisers that may be a better fit for your specific management
needs.
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Item 11
Description of Our Code of Ethics
AGH Wealth has adopted a Code of Ethics (the “Code”) to address investment advisory conduct. The Code focuses
primarily on fiduciary duty, personal securities transactions, insider trading, gifts, and conflicts of interest. The
Code includes AGH Wealth’s policies and procedures developed to protect Client’s interests in relation to the
following topics:
The duty at all times to place the interests of Clients first;
The requirement that all personal securities transactions be conducted in such a manner as to be
consistent with the Code;
The responsibility to avoid any actual or potential conflict of interest or misuse of an employee’s
position of trust and responsibility;
The fiduciary principle that information concerning the identity of security holdings and financial
circumstances of Clients is confidential; and
The principle that independence in the investment decision-making process is paramount.
A copy of AGH Wealth’s Code of Ethics is available upon request to our firm at (316) 267-3220 or at
info@aghwealth.com.
Interest in Client Transactions
Please refer to Compensation for the Sale of Securities in Item 10 above for information about the
recommendation of securities in which related persons has a material financial interest and the conflicts of
interest associated with such practices.
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Form ADV Part 2A
Page 20
Personal Trading Practices
At times AGH Wealth and/or its Associated Persons may take positions in the same securities as clients, which
may pose a conflict of interest with clients. AGH Wealth and its Associated Persons will generally be “last in” and
“last out” for the trading day when trading occurs in close proximity to client trades. We will not violate our
fiduciary responsibilities to our clients. Front running (trading shortly ahead of clients) is prohibited. Should a
conflict occur because of materiality (i.e. a thinly traded stock), disclosure will be made to the client(s) at the time
of trading. Incidental trading not deemed to be a conflict (i.e. a purchase or sale which is minimal in relation to
the total outstanding value, and as such would have negligible effect on the market price), would not be disclosed
at the time of trading.
Brokerage Practices - Item 12
Brokerage and Custodial Services Offered by LPL Financial LLC
AGH Wealth recommends that you establish brokerage accounts with LPL Financial LLC (“LPL”), a registered
broker-dealer and member SIPC, to maintain custody of assets and to effect trades. Factors which AGH Wealth
considers in recommending LPL to Clients include their respective financial strength, reputation, execution,
pricing, research and service. LPL enables AGH Wealth to obtain many mutual funds without transaction charges
and other securities at nominal transaction charges. The commissions and/or transaction fees charged by LPL
may be higher or lower than those charged by other Financial Institutions.
LPL provides AGH Wealth with access to its institutional trading and custody services, which are typically not
available to retail investors. LPL services include brokerage, 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.
LPL provides AGH Wealth assistance in managing and administering Clients’ accounts. These include access to
Client account data, facilitate trade execution, provide research, and facilitate payment of AGH Wealth
management fees from its Clients’ accounts, recordkeeping, and Client reporting.
LPL also makes available to AGH Wealth other services intended to help AGH Wealth manage and further develop
its business enterprise. These services may include consulting, publications and conferences on practice
management, information technology, business succession, regulatory compliance, and marketing.
In choosing a broker-dealer or negotiating commission rates, we are not obligated to seek competitive bids or the
lowest commission cost to you; but we determine that the commission rate charged is reasonable based on the
quality of custodial services available to our Clients. As a fiduciary, AGH Wealth endeavors to act in your best
interest.
The commissions paid by AGH Wealth’s Clients comply with AGH Wealth’s duty to obtain “best execution.” Clients
may pay commissions that are higher than another qualified Financial Institution might charge to effect the same
transaction where AGH Wealth determines that the commissions are 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 Financial Institution’s services, including among others, the value of research provided,
execution capability, commission rates, and responsiveness. AGH Wealth seeks competitive rates but may not
necessarily obtain the lowest possible commission rates for Client transactions.
We do not receive Client referrals from broker-dealers and custodians with which we have an institutional
advisory arrangement. In addition, we do not receive other benefits from a broker-dealer in exchange for Client
referrals.
AGH Wealth Advisors, LLC
Form ADV Part 2A
Page 21
Associated persons of our firm, who are registered representatives of LPL are subject to FINRA Conduct Rule 3040,
which restricts such registered individuals from conducting securities transactions away from LPL, unless LPL
provides the representative with written authorization. Therefore, clients are advised that such persons may be
limited to conducting securities transactions through LPL or through custodians approved by LPL.
Trade Aggregation
While individual Client advice is provided to each account, Client trades can be executed as a block trade. The
executing broker will be informed that the trades are for the account of AGH Wealth’s Clients and not for AGH
Wealth itself. No advisory account within the block trade will be favored over any other advisory account, and
thus, each account will participate in an aggregated order at the average share price and receive the same
commission rate. The aggregation should, on average, reduce slightly the costs of execution. We will not
aggregate a Client’s order if in a particular instance we believe that aggregation would cause the Client’s cost of
execution to be increased. The broker dealer will be notified of the amount of each trade for each account. AGH
Wealth and/or its Associated Persons may participate in block trades with Clients, and may also participate on a
pro rata basis for partial fills, but only after the determination has been made that Clients will receive fair and
equitable treatment.
Trade Errors
In the event a trading error occurs in your account, our policy is to restore your account to the position it should
have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include
canceling the trade, adjusting an allocation, and/or reimbursing the account.
Brokerage for Client Referrals
We do not receive client referrals from broker-dealers and custodians in which we have an institutional advisory
arrangement. Also, we do not receive other benefits from a broker-dealer in exchange for client referrals.
Directed Brokerage
Associated Persons who are registered representatives of LPL are subject to FINRA Conduct Rule 3040 that
restricts these registered individuals from conducting securities transactions away from LPL unless LPL provides
the representative with written authorization. Therefore, AGH Wealth reserves the right to not accept a client
account if the client wishes to select a broker or dealer/custodian other than LPL. Due to the nature of its advisory
services, AGH Wealth does not have the authority to negotiate commissions or obtain volume discounts, although
AGH Wealth will attempt, to achieve best execution of transactions.
Review of Accounts - Item 13
Portfolio Management Account Reviews
AGH Wealth monitors account holdings and portfolio performance on a continuous basis. AGH Wealth offers
portfolio management clients an in-person portfolio review meeting on an annual basis. This meeting maybe
conducted virtually. Additional reviews may be offered in certain circumstances. Triggering factors that may
stimulate additional reviews include, but are not limited to, changes in economic conditions, changes in the
Client’s financial situation or investment objectives, or upon Client request.
The Associated Person assigned to the client relationship monitors portfolios and financial plans for investment
objectives and conducts other supervisory reviews.
Clients will receive statements directly from their account custodian(s) on at least a quarterly basis. The financial
plan is a snapshot in time and no ongoing reviews are conducted. We recommend clients engage us on an annual
basis to update the financial plan.
AGH Wealth Advisors, LLC
Form ADV Part 2A
Page 22
Clients will receive statements directly from their account custodian(s) on at least a quarterly basis. Clients may
also request access to a personal online portal that provides access to net worth statements, account overviews,
asset allocations, cash flow reports, and income and expense statements. AGH Wealth may also provide
performance reports on an as needed basis.
Client Referrals and Other Compensation - Item 14
Custodial Benefits
As described in Item 12 above, we receive economic benefits from our custodial broker dealer in the form of
support products and services they make available to us and other independent investment advisors whose
clients maintain their accounts at these custodial broker dealers. The availability of custodial products and
services is not dependent upon or based on the specific investment advice we provide our clients, such as buying
or selling specific securities or specific types of securities for our clients. The products and services provided by
the custodial broker dealer, how they benefit us, and the related conflicts of interest are described above (see
Item 12 – Brokerage Practices).
Economic Benefits Received from Vendors and Product Sponsors
Occasionally, our firm and our Associated Persons will receive additional compensation from vendors.
Compensation could include such items as gifts; an occasional dinner or ticket to a sporting event; reimbursement
in connection with educational meetings with an Associated Person, reimbursement for consulting services, client
workshops, or events; or marketing events or advertising initiatives, including services for identifying prospective
clients. Receipt of additional economic benefits presents a conflict of interest because our firm and Associated
Persons have an incentive to recommend and use vendors based on the additional economic benefits obtained
rather than solely on the client’s needs. We address this conflict of interest by recommending vendors that we,
in good faith, believe are appropriate for the client’s particular needs. Clients are under no obligation
contractually or otherwise, to use any of the vendors recommended by us.
Recommendation of Other Advisors
We may recommend that you use a third party investment adviser or program as part of our asset allocation and
investment strategy. In these cases, AGH Wealth will share in the compensation received by the third party
investment adviser. The compensation arrangement presents a conflict of interest due to a financial incentive to
recommend the services of a third party investment adviser. Since our compensation may differ depending upon
our individual agreement with each third party adviser, we have an incentive to recommend one third party
adviser over another third party adviser with whom we have less favorable compensation arrangements or other
advisory programs offered by third party advisers with which we have no compensation arrangements. At all
times AGH Wealth and its Associated Persons uphold their fiduciary duty of fair dealing with Clients. You are not
required to use the services of any recommended third party investment adviser.
Our firm and our Associated Persons do not compensate, either directly or indirectly, any person or entity who is
not our supervised person for Client referrals.
Custody - Item 15
AGH Wealth is deemed to have custody of Client funds because of the fee deduction authority granted by the
Client in the Advisory Agreement. You will receive account statements at least quarterly from the broker-dealer
or other qualified custodian. The custodian will not verify the calculation of the advisory fees. You are urged to
review custodial account statements for accuracy.
AGH Wealth Advisors, LLC
Form ADV Part 2A
Page 23
With respect to third party standing letters of authorization (“SLOA”) where a Client grants us authority to direct
custodians to disburse funds to one or more third party accounts, we are deemed to have custody pursuant to
Rule 206(4)-2 (the “Custody Rule”). We have taken steps to have controls and oversight in place to comply with
the no-action letter issued by the SEC on February 21, 2017 (the “SEC no-action letter”). We are not required to
comply with the surprise examination requirements of the Custody Rule if we are in compliance with the
representations noted in the SEC no-action letter. Where our firm acts pursuant to a SLOA, we believe we are
making a good faith effort to comply with the representations noted in the SEC no-action letter. Additionally,
since many of the representations noted in the SEC no-action letter involve the qualified custodian’s operations,
we will collaborate closely with our custodian(s) to ensure that the representations are met.
Investment Discretion - Item 16
AGH Wealth offers Portfolio Management Services on a discretionary basis. Clients must grant discretionary
authority in the management agreement. Discretionary authority extends to the types and amounts of securities
to be bought and sold in Client accounts. However, our firm does not retain discretionary authority to select the
broker/dealer used for transactions, or commission rates paid. In cases where we are not given discretion, we
must receive permission from the client to make any trades on a non- discretionary basis. In non-discretionary
accounts, you have the right to decide whether to act upon our recommendations.
Apart from the ability to withdraw management fees, AGH Wealth does not have the ability to withdraw funds or
securities from the Client’s account. The Client provides AGH Wealth discretionary authority via a limited power
of attorney in the management agreement and in the contract between the Client and the custodian.
If you wish, you may limit our discretionary authority, for example, by setting a limit on the type of securities that
can be purchased for your account. Simply provide us with your restrictions or guidelines in writing. Please refer
to the “Advisory Business” section in this Brochure for more information on our discretionary management
services.
Voting Client Securities - Item 17
AGH Wealth does not vote proxies. It is the Client's responsibility to vote proxies. Although, at the client’s request,
AGH Wealth may offer clients advice regarding corporate actions and the exercise of proxy voting rights and/or
materials.
Clients will receive proxy materials directly from the custodian. Questions about proxies may be made via the
contact information on the cover page.
Financial Information - Item 18
We are required in this Item to provide you with certain financial information or disclosures about AGH Wealth’s,
financial condition. AGH Wealth does not require the prepayment of over $1,200, six or more months in advance.
Additionally, AGH Wealth has no financial condition that impairs its ability to meet contractual and fiduciary
commitments to Clients, and it has not been the subject of a bankruptcy proceeding.
AGH Wealth Advisors, LLC
Form ADV Part 2A
Page 24
Requirements of State-Registered Advisers - Item 19
This section is not applicable because our firm is SEC registered.
Form ADV Part 2A, Appendix 1: Wrap Fee Program Brochure
Cover Page - Item 1
AGH Wealth Advisors, LLC
301 N. Main, Suite 1700
Wichita, Kansas 67202-4868
Phone: (316) 267-3220
Fax: (316) 291-4115
www.aghwealth.com
March 7, 2025
AGH Wealth Advisors, LLC is a registered investment adviser. An "investment adviser" means any person who, for
compensation, engages in the business of advising others, either directly or through publications or writings, as to
the value of securities or as to the advisability of investing in, purchasing, or selling securities, or who, for
compensation and as part of a regular business, issues or promulgates analyses or reports concerning securities.
Registration with the SEC or any state securities authority does not imply a certain level of skill or training.
This wrap fee program brochure provides information about the qualifications and business practices of AGH Wealth
Advisors, LLC. If you have any questions about the contents of this brochure, please contact us at (316) 267-3220.
The information in this brochure has not been approved or verified by the United States Securities and Exchange
Commission or by any state securities authority.
information about AGH Wealth Advisors, LLC
is available on
the SEC’s website at
Additional
www.adviserinfo.sec.gov.
AGH Wealth Advisors, LLC
Form ADV Part 2A, Appendix 1 (Wrap brochure)
Page 1
Material Changes - Item 2
The purpose of this page is to inform you of any material changes since the previous version of this wrap fee
brochure. We have not made any material changes to this brochure since the last version.
If you would like to receive a complete copy of our current brochure free of charge at any time, please contact us
at (316) 267-3220 or at info@aghwealth.com.
AGH Wealth Advisors, LLC
Form ADV Part 2A, Appendix 1 (Wrap brochure)
Page 2
Table of Contents - Item 3
A table of contents is provided in Item 3 of the firm’s Form ADV Part 2A Disclosure Brochure above.
AGH Wealth Advisors, LLC
Form ADV Part 2A, Appendix 1 (Wrap brochure)
Page 3
Services Fees and Compensation - Item 4
Services
AGH Wealth Advisors, LLC (hereinafter “AGH Wealth ”) offers a wrap fee program, the AGH Wealth Wrap Fee
Program, whereby AGH Wealth manages Client accounts for a single, bundled fee that includes portfolio
management services, custodial services, and transaction/commission costs. Under the AGH Wealth Wrap Fee
Program, AGH Wealth offers discretionary investment advice designed to assist Clients in obtaining professional
portfolio management for an inclusive “wrap fee.”
You may see the term Associated Person throughout this Brochure. As used in this Brochure, this term refers to
anyone from our firm who is an officer, employee, and all individuals providing investment advice on behalf of
our firm. Where required, such persons are properly registered as investment adviser representatives.
As primary portfolio manager, AGH Wealth and its Associated Persons are responsible for the research, security
selection, and implementation of transaction orders in the Client's account. The transactions in the Client's
account will be executed by LPL Financial LLC (“LPL”), a registered broker dealer and a member of the Financial
Industry Regulatory Authority ("FINRA") and the Securities Investor Protection Corporation ("SIPC").
AGH Wealth receives a portion of the Wrap Fee for portfolio management services and LPL will receive a portion
of the fee for trade execution and custodial services. The terms and conditions under which a Client participates
in the AGH Wealth Wrap Fee Program are set forth in the written agreement between the Client and AGH Wealth.
The overall cost incurred from participation in the AGH Wealth Wrap Fee Program may be higher or lower than if
the services were purchased separately.
The portfolio management services for the AGH Wealth Wrap Fee Program are generally offered on a
discretionary basis. Our investment advice is tailored to meet our Clients' needs and investment objectives.
Subject to any written guidelines that you may provide, we will be granted discretionary authority to manage
your account. Once the portfolio allocation has been agreed upon, the ongoing supervision and management of
the portfolio will be our responsibility. Discretionary authorization is granted to us by you in a written agreement.
This allows our firm to decide on specific securities, the quantity of the securities and placing buy or sell orders
for your account without obtaining your approval for each transaction. This type of authorization is granted using
either the investment advisory agreement the Client signs with our firm, a limited power of attorney agreement,
or trading authorization forms. You may limit our discretionary authority (for example, limiting the types of
securities that can be purchased for your account) by providing our firm with restrictions and guidelines in writing.
In cases where we are not given discretion, we must receive permission from the client to make any trades on a
non- discretionary basis. In non-discretionary accounts, you have the right to decide whether to act upon
our recommendations.
Wrap accounts are managed to diversify Clients’ investments and may include various types of securities such as
exchange listed equities, over the counter equities, foreign issues, American depository receipts, corporate debt
securities, commercial paper, certificates of deposit, municipal securities, investment company securities
(including mutual funds and exchange traded funds), US Government securities, options contracts on securities
and/or commodities, private equity instruments, and interests in partnership investing in real estate. Additionally,
we will provide advice on existing investments you may hold at the inception of the advisory relationship or on
other types of investments for which you ask advice. 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.
Asset allocation models diversified among investment styles and/or asset classes are developed and managed by
us based on research conducted by AGH Wealth. We may also rely on portfolio models developed by third party
investment advisers. Once the Client portfolio is constructed, AGH Wealth provides continuous supervision of the
AGH Wealth Advisors, LLC
Form ADV Part 2A, Appendix 1 (Wrap brochure)
Page 4
portfolio as changes in the market conditions and Client circumstances may require. Investments and allocations
are determined based upon the Clients’ predefined objectives, risk tolerance, time horizons, financial horizons,
financial information, and other various suitability factors. Further restrictions and guidelines imposed by Clients
may affect the composition and performance of a Client’s portfolio. For these reasons, performance of the
portfolio might not be identical with other Clients of AGH Wealth. We review the Clients’ financial circumstances
and investment objectives on an ongoing basis and make adjustments to Clients’ portfolios or allocation models
as may be necessary to achieve the desired results.
In providing the contracted services, we are not required to verify any information we receive from you or from
your other professionals (e.g., attorney, accountant, etc.) and we are expressly authorized to rely on the
information you provide. You must promptly notify our firm of any changes in your financial circumstances or
investment objectives that might affect the manner in which your accounts should be managed.
Fees
AGH Wealth charges a single negotiable asset-based fee for its management services, which includes the cost of
portfolio management services, custodial services and the execution of securities transactions. This fee is
deducted from the Client's account held at the custodian. The Client authorizes AGH Wealth to debit the fee from
the Client’s account. If insufficient cash is available to pay such fees, securities in an amount equal to the balance
of unpaid fees will be liquidated to pay for the unpaid balance.
Since the fee is negotiable, the exact fee paid by you will be stated in the advisory agreement signed by you and
us. The maximum fee will not exceed 2.00% and will be outlined on the Advisory Services Agreement. Since AGH
Wealth does not use the services of unaffiliated portfolio managers to manage our wrap program accounts, the
Portfolio Manager servicing the account will be employed directly by our firm.
The annual fee for the AGH Wealth Wrap Fee Program is billed quarterly, in advance, and is based on the value
of your portfolio at the end of the preceding quarter. Fees will be assessed pro rata in the event the Agreement
is executed at any time other than the first day of a billing period. We may deduct the fee from a single, Client-
designated account to facilitate billing.
We encourage you to carefully review the statements you receive from the qualified custodian. If you have
questions about your statements, or if you did not receive a statement from the qualified custodian, please call
our office number located on the cover page of this brochure.
Termination
At the inception of investment management services, the first pay period’s fees will be calculated on a pro-rata
basis. The management agreement between you and AGH Wealth will continue in effect until either party
terminates the management agreement in accordance with the terms of the management agreement. AGH
Wealth’s annual fee will be pro-rated through the date of termination. Any pre-paid, unearned fees will be
promptly refunded to the Client.
Additional Fees and Expenses
The fees are charged as described above and are not based on a share of capital gains of the funds of an advisory
Client.
The AGH Wealth Wrap Fee Program fees do not include mark-ups and mark-downs, dealer spreads or other costs
associated with the purchase or sale of securities, interest, taxes, or other costs, such as national securities
exchange fees, charges for transactions not executed through LPL, costs associated with exchanging currencies,
wire transfer fees, or other fees required by law or imposed by third parties. The Account will be responsible for
these additional fees and expenses.
AGH Wealth Advisors, LLC
Form ADV Part 2A, Appendix 1 (Wrap brochure)
Page 5
Negotiability of Fees: We allow Associated Persons servicing the account to negotiate the exact investment
management fees within the range disclosed in our Form ADV Part 2A Brochure. As a result, the Associated Person
servicing your account may charge more or less for the same service than another Associated Person of our firm.
Further, our annual investment management fee may be higher than that charged by other investment advisors
offering similar services/programs.
Billing on Cash Positions: The firm treats cash and cash equivalents as an asset class. Accordingly, unless
otherwise agreed in writing, all cash and cash equivalent positions (e.g., money market funds, etc.) are included
as part of assets under management for purposes of calculating the firm’s advisory fee. At any specific point in
time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such
anticipated market conditions/events will occur), the firm may maintain cash and/or cash equivalent positions for
defensive, liquidity, or other purposes. While assets are maintained in cash or cash equivalents, such amounts
could miss market advances and, depending upon current yields, at any point in time, the firm’s advisory fee could
exceed the interest paid by the client’s cash or cash equivalent positions.
Periods of Portfolio Inactivity: The firm has a fiduciary duty to provide services consistent with the client’s best
interest. As part of its investment advisory services, the firm will review client portfolios on an ongoing basis to
determine if any changes are necessary based upon various factors, including but not limited to investment
performance, fund manager tenure, style drift, account additions/withdrawals, the client’s financial
circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may
be extended periods of time when the firm determines that changes to a client’s portfolio are neither necessary
nor prudent. Notwithstanding, unless otherwise agreed in writing, the firm’s annual investment advisory fee will
continue to apply during these periods, and there can be no assurance that investment decisions made by the
firm will be profitable or equal any specific performance level(s).
All fees paid to AGH Wealth for investment advisory services are separate and distinct from the fees and expenses
charged by mutual funds or exchange traded funds to their shareholders. These fees and expenses are described
in each fund's prospectus. These fees generally include a management fee, other fund expenses, and a possible
distribution fee. If the fund also imposes sales charges, a Client may pay an initial or deferred sales charge.
Each mutual fund, ETF, or variable annuity in which the Account may be invested will also charge a management
fee, other internal expenses, and a possible distribution fee. Certain mutual funds offered through the AGH
Wealth Wrap Fee Program may impose short-term trading charges (typically 1% - 2% of the amount originally
invested) for redemptions made within short periods of time. In the rare event an early redemption charge is
assessed, the charge would be offset by the advisory fee or paid by AGH Wealth.
All of the fees and expenses discussed above will be indirect expenses borne by the Account, and will be in
addition to the AGH Wealth Wrap Fee Program fee. You should consider all of these fees and expenses (including
the AGH Wealth Wrap Fee Program fee) to fully understand the total amount of fees and expenses to be paid by
the Account and to evaluate the advisory services being provided. The fees and expense related to mutual funds,
ETFs, or variable annuities are disclosed in their respective prospectus or summary disclosure document.
Other Important Considerations
• Wrap fee programs are not suitable for all investment needs, and any decision to participate in a wrap fee
program should be based on your financial situation, investment objectives, tolerance for risk, and
investment time horizon, among other considerations. The wrap fee program fee may cost the Client more
than if assets were held in a traditional brokerage account. In a brokerage account, a Client is charged a
commission for each transaction, and the representative has no duty to provide ongoing advice with
respect to the account. If the Client plans to follow a buy and hold strategy for the account or does not
wish to use AGH Wealth for ongoing investment advice or management services, the Client should consider
opening a brokerage account rather than a wrap fee program account.
AGH Wealth Advisors, LLC
Form ADV Part 2A, Appendix 1 (Wrap brochure)
Page 6
•
The investment products available to be purchased in the wrap fee program can be purchased by Clients
outside of a wrap fee program account, through broker-dealers or other investment firms not affiliated
with AGH Wealth. In such cases, our firm would not provide ongoing supervisory and management services
for the account.
•
• Our firm and our advisory representatives will receive compensation as a result of your participation in the
AGH Wealth Wrap Fee Program. Accordingly, a conflict of interest exists because our firm and our
representatives have a financial incentive to recommend the AGH Wealth Wrap Fee Program over the
establishment of a brokerage account or the use of a third party adviser for which the commission or
referral compensation arrangements are not as beneficial.
The advisory fee may cost the Client more than if assets were held in a traditional brokerage account. In a
brokerage account, a Client is charged a commission for each transaction, and the representative has no
duty to provide ongoing advice with respect to the account. If the Client plans to follow a buy and hold
strategy for the account or does not wish to purchase ongoing investment advice or management services,
the Client should consider opening a brokerage account rather than a wrap fee program account.
• Due to the single fee charged to an AGH Wealth Wrap Fee Program account, we are regarded as having a
conflict of interest in that we can realize a greater profit on a AGH Wealth Wrap Fee Program account with
a relatively low rate of portfolio turnover compared to other types of accounts, assuming the same level
of fees.
Account Requirements and Types of Clients - Item 5
We offer investment advisory services to individuals, banks and thrift institutions, retirement plans, trusts,
estates, charitable organizations, corporations, and other business or government entities.
AGH Wealth requires a minimum account size of $5,000 to establish an advisory relationship.
Portfolio Manager Selection and Evaluation - Item 6
Portfolio Managers
AGH Wealth is the sole sponsor and portfolio manager of the AGH Wealth Wrap Fee Program. Each account is
managed by the Associated Person assigned to the Client relationship. We have chosen not to utilize outside
portfolio managers. Therefore, there is no selection and review of outside portfolio managers. Neither us, nor
any third party reviews performance information to determine or verify its accuracy.
Where required, Associated Persons responsible for the management of the account are registered as investment
adviser representatives. Clients should refer to each Associated Person’s Form ADV Part 2B Supplement, provided
to you along with the copy of our disclosure brochure, for more information about their disciplinary, business and
educational backgrounds. Please contact us at (316) 267-3220 or at info@aghwealth.com with any questions you
may have.
Clients will receive statements directly from their account custodian(s) at least quarterly. AGH Wealth may also
provide performance reports on an as needed basis.
Other Advisory Services
Please refer to Item 4 of the firm’s Form ADV Part 2A Disclosure Brochure above for information about other
advisory services offered by AGH Wealth.
AGH Wealth Advisors, LLC
Form ADV Part 2A, Appendix 1 (Wrap brochure)
Page 7
Performance-Based Fees and Side-By-Side Management
Performance-based fees are based on a share of capital gains on or capital appreciation of the Client’s assets.
Side-by-side management refers to the practice of managing accounts that are charged performance-based fees
while at the same time managing accounts that are not charged performance-based fees. We do not accept
performance-based fees or participate in side-by-side management. Our fees are calculated as described in the
Advisory Business section above, and are not charged on the basis of a share of capital gains upon, or capital
appreciation of, the funds in your advisory account(s).
Investment Strategies
Please refer to Item 8 of the firm’s Form ADV Part 2A Disclosure Brochure above for information about AGH
Wealth’s investment strategies.
Methods of Analysis
Please refer to Item 8 of the firm’s Form ADV Part 2A Disclosure Brochure above for information about the
methods of analysis used by AGH Wealth.
Risk of Loss
Clients should be aware that investing in securities involves a risk of loss that they should be prepared to bear.
Past performance is not indicative of future results. Therefore, you should never assume that future performance
of any specific investment or investment strategy will be profitable. Investing in securities (including stocks,
mutual funds, and bonds, etc.) involves risk of loss. Further, depending on the different types of investments there
may be varying degrees of risk. You should be prepared to bear investment loss including loss of original principal.
Because of the inherent risk of loss associated with investing, our firm is unable to represent, guarantee, or even
imply that our services and methods of analysis can or will predict future results, successfully identify market tops
or bottoms, or insulate you from losses due to market corrections or declines. Please refer to Item 8 of our Form
ADV Part 2A Brochure above for a detailed discussion of the various risks associated with investing in securities.
Proxy Voting
AGH Wealth does not vote proxies. It is the Client's responsibility to vote proxies. Clients will receive proxy
materials directly from the custodian. Questions about proxies may be made via the contact information on the
cover page.
Client Information Provided to Portfolio Managers - Item 7
AGH Wealth is the sole sponsor of the AGH Wealth Wrap Fee Program and together with its portfolio managers
has access to and is responsible for maintaining all information provided by Clients. Client information will be
updated in our firm’s records upon notification of changes provided by Clients and during Client meetings.
Client Contact with Portfolio Managers - Item 8
AGH Wealth is the sole sponsor and portfolio manager to the AGH Wealth Wrap Fee Program. Clients are free to
contact AGH Wealth or their designated investment adviser representative at any time with questions regarding
the AGH Wealth Wrap Fee Program. We can be reached at (316) 267-3220 or at info@aghwealth.com.
AGH Wealth Advisors, LLC
Form ADV Part 2A, Appendix 1 (Wrap brochure)
Page 8
Additional Information - Item 9
Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events
that would be material to your evaluation of us or of the integrity of our management. Neither we nor our
management persons have a history of material legal or disciplinary events.
Other Financial Industry Activities or Affiliations
Please refer to Item 10 of our Form ADV Part 2A Brochure above for more information about our other financial
industry activities and/or affiliations.
Description of Our Code of Ethics
AGH Wealth has adopted a Code of Ethics (the “Code”) to address investment advisory conduct. The Code focuses
primarily on fiduciary duty, personal securities transactions, insider trading, gifts, and conflicts of interest. The
Code includes AGH Wealth’s policies and procedures developed to protect Client’s interests in relation to the
following topics:
The duty at all times to place the interests of Clients first;
The requirement that all personal securities transactions be conducted in such a manner as to be
consistent with the Code;
The responsibility to avoid any actual or potential conflict of interest or misuse of an employee’s
position of trust and responsibility;
The fiduciary principle that information concerning the identity of security holdings and financial
circumstances of Clients is confidential; and
The principle that independence in the investment decision-making process is paramount.
A copy of AGH Wealth’s Code of Ethics is available upon request to our firm at (316) 267-3220 or at
info@aghwealth.com.
Interest in Client Transactions
Please refer to Compensation for the Sale of Securities in Item 10 above for information about the
recommendation of securities in which related persons has a material financial interest and the conflicts of
interest associated with such practices.
Personal Trading Practices
At times, AGH Wealth and/or its related persons may take positions in the same securities as Clients, which may
pose a conflict of interest with Clients. In an effort to uphold our fiduciary duties to Clients, AGH Wealth and its
related persons will generally be “last in” and “last out” for the trading day when trading occurs in close proximity
to Client trades. Front running (trading shortly ahead of Clients) is prohibited. Should a conflict occur because of
materiality (e.g., a thinly traded stock), disclosure will be made to the Client(s) at the time of trading. Incidental
trading not deemed to be a conflict (e.g., a purchase or sale which is minimal in relation to the total outstanding
value, and as such would have negligible effect on the market price) would not be deemed a material conflict
requiring disclosure at the time of trading.
Account Reviews, Statements and Reports
AGH Wealth monitors account holdings and portfolio performance on a continuous basis. AGH Wealth offers
portfolio management clients an in-person portfolio review meeting on an annual basis. This meeting maybe
conducted virtually. Additional reviews may be offered in certain circumstances. Triggering factors that may
stimulate additional reviews include, but are not limited to, changes in economic conditions, changes in the
Client’s financial situation or investment objectives, or upon Client request.
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The Associated Person assigned to the client relationship monitors portfolios and financial plans for investment
objectives and conducts other supervisory reviews.
Clients will receive statements directly from their account custodian(s) on at least a quarterly basis. The financial
plan is a snapshot in time and no ongoing reviews are conducted. We recommend clients engage us on an annual
basis to update the financial plan.
Clients will receive statements directly from their account custodian(s) on at least a quarterly basis. Clients may
also request access to a personal online portal that provides access to net worth statements, account overviews,
asset allocations, cash flow reports, and income and expense statements. AGH Wealth may also provide
performance reports on an as needed basis.
Brokerage Practices
AGH Wealth executes all transactions for AGH Wealth Wrap Fee Program accounts through LPL. LPL is an
unaffiliated broker-dealer, and a member of FINRA and the SIPC. AGH Wealth has chosen LPL on the basis of a
number of factors, including quality of service, fees, reputation, accountability, and security of assets. The fees
and commissions charged by LPL may be higher or lower than other broker dealers or custodians, depending on
the type of transaction. AGH Wealth considers the services provided by LPL to be high-quality and the fees
charged to be comparable or favorable to those charged by other broker-dealers or custodians.
Client Referrals and Other Compensation
AGH Wealth receives additional benefits from LPL such as electronic delivery of Client information, electronic
trading platforms, institutional trading support, proprietary and/or third party research, continuing education,
practice management advice, and other services provided by custodians for the benefit of investment advisory
Clients.
The receipt of additional benefits gives us an incentive to require that you maintain your account with LPL based
on our interest in receiving additional services from these broker dealers rather than your interest in receiving
the best value and the most favorable execution of your transactions. This is a conflict of interest. We believe,
however, that our selection of LPL as broker dealer/custodian is in the best interests of our Clients. Our belief is
primarily supported by the scope and quality of services LPL provides to our Clients and not services that benefit
only us. Please refer to Item 12 of our Form ADV Part 2A Brochure above for more information about the receipt
of additional benefits from broker dealers.
To address the existence of this conflict, on a periodic basis, we conduct a best execution review considering the
full range and quality of LPL’s services, including execution quality, commission rate, the value of research
provided, financial strength, and responsiveness to our requests for trade data and other information. Our
obligation is not necessarily to get the lowest price but to obtain the best qualitative execution.
AGH Wealth has brokerage and clearing arrangements with LPL and the firm may receive additional benefits from
LPL in the form of electronic delivery of Client information, electronic trading platforms, institutional trading
support, proprietary and/or third party research, continuing education, practice management advice, and other
services provided by custodians for the benefit of investment advisory Clients. Please refer to item 12 above for
more information about the receipt of additional benefits from broker dealers.
Our firm and our Associated Persons do not compensate, either directly or indirectly, any person or entity who is
not our supervised person for Client referrals.
Recommendation of Other Advisors
We may recommend that you use a third party investment adviser or program as part of our asset allocation and
investment strategy. In these cases, AGH Wealth will share in the compensation received by the third party
investment adviser. The compensation arrangement presents a conflict of interest due to a financial incentive to
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recommend the services of a third party investment adviser. You are not required to use the services of any
recommended third party investment adviser.
Financial Information
We are required in this Item to provide you with certain financial information or disclosures about AGH Wealth’s,
financial condition. AGH Wealth does not require the prepayment of over $1,200, six or more months in advance.
Additionally, AGH Wealth has no financial commitment that impairs its ability to meet contractual and fiduciary
commitments to Clients, and it has not been the subject of a bankruptcy proceeding.
Requirements for State-Registered Advisors - Item 10
This section is not applicable because our firm is SEC registered