Overview
- Headquarters
- Scottsdale, AZ
- Total Firm Assets
- $134 million
- Average High-Net-Worth Client Portfolio Size
- $1.5 million
- Minimum Account Size
- $1,000,000
Fee Structure
Primary Fee Schedule (ALMEGA WEALTH MANAGEMENT - FORM ADV PART 2A)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $5,000,000 | 1.00% |
| $5,000,001 | $10,000,000 | 0.50% |
| $10,000,001 | and above | 0.25% |
Minimum Annual Fee: $10,000
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $50,000 | 1.00% |
| $10 million | $75,000 | 0.75% |
| $50 million | $175,000 | 0.35% |
| $100 million | $300,000 | 0.30% |
Clients
- High-Net-Worth Share of Firm Assets
- 61.09%
- Number of High-Net-Worth Clients
- 54
- Total Client Accounts
- 767
- Discretionary Accounts
- 762
- Non-Discretionary Accounts
- 5
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Pension Consulting, Educational Seminars
Regulatory Filings
- SEC CRD Number
- 316840
Additional Brochure: ALMEGA WEALTH MANAGEMENT - FORM ADV PART 2A (2026-06-26)
View Document Text
Almega Wealth Management LLC
Part 2A of Form ADV: Firm Brochure
ARIZONA
8350 E. Raintree Dr., Ste. 215
Scottsdale, AZ 85260
480-770-4700
KENTUCKY
112 Mill Street
Greenville, KY 42345
270-820-2056
KENTUCKY
312 S. 4th St., 7th Floor
Louisville, KY 40202
502-754-0001
NORTH CAROLINA
129 Moore Avenue
Mount Airy, NC 27030
336-789-6241
NORTH CAROLINA
8601 Six Forks Rd, 4th Floor
Raleigh, NC 27615
919-689-8986
Almega-Wealth.com
Social Media
Facebook.com/almegawealthmanagement
Instagram.com/almega-wealth
LinkedIn.com/company/almega-wealth
X.com/almegawealth
June 26, 2026
This brochure provides information about the qualifications and business practices of Almega Wealth
Management LLC. If you have any questions about the contents of this brochure, please get in touch with us
at (480) 770-4700 or info@almega-wealth.com. The information in this brochure has not been approved or
verified by the United States Securities and Exchange Commission or any state securities authority.
Additional information about Almega Wealth Management LLC also is available on the SEC's website at
https://adviserinfo.sec.gov. Registration does not imply any level of skill or training.
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Part 2A of Form ADV: Almega Wealth Management LLC
ITEM 2 – MATERIAL CHANGES
This Firm Brochure is the disclosure document for Almega Wealth Management LLC ("Almega") "we" and/or
the "firm") prepared according to regulatory requirements and rules.
Almega Wealth Management is required to amend this Brochure when information becomes materially
inaccurate. In the future, this Item 2 will be used to provide you with a summary of new and/or updated
information since the previous Brochure. We will inform you of the revisions based on the nature of the
updated information.
We will ensure that you receive a summary of any material changes to this and subsequent Brochures within
120 days of the close of our fiscal year. We will also provide you with other interim disclosures about material
changes to the information provided in this Brochure as necessary or required.
Whenever you would like to receive a complete copy of the current Brochure, please contact (480) 770-4700
or email info@almega-wealth.com. We will be happy to provide you with a complete copy.
Summary of Material Changes
The following material changes have been made to this brochure since its initial release:
• Client relationships whose assets under management fall below certain threshold levels may be subject
to a 0.10% increase in their fee. For more information, please refer to Item 5 – Fees and
Compensation.
• We eliminated the Ramsey SmartVestor service offering. Clients utilizing this service have been
converted to our Private Wealth Management service offering.
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Part 2A of Form ADV: Almega Wealth Management LLC
ITEM 3 – TABLE OF CONTENTS
ITEM 2 – MATERIAL CHANGES ....................................................................................................................... 2
ITEM 3 – TABLE OF CONTENTS ....................................................................................................................... 3
ITEM 4 – ADVISORY BUSINESS ....................................................................................................................... 4
Description of Primary Services Offered .................................................................................................................... 5
Description of Ancillary Services Offered as Part of Our Other Services ..................................................................... 7
Additional Details About Our Advisory Business ..................................................................................................... 12
ITEM 5 – FEES AND COMPENSATION ............................................................................................................ 14
ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT .................................................... 18
ITEM 7 – TYPES OF CLIENTS .......................................................................................................................... 19
ITEM 8 – INVESTMENT STRATEGIES, METHODS OF ANALYSIS, AND RISK OF LOSS ......................................... 19
ITEM 9 – DISCIPLINARY INFORMATION ........................................................................................................ 24
ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ....................................................... 24
ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS, AND PERSONAL
TRADING ..................................................................................................................................................... 26
ITEM 12 – BROKERAGE PRACTICES ............................................................................................................... 28
ITEM 13 – REVIEW OF ACCOUNTS ................................................................................................................ 33
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION ......................................................................... 34
ITEM 15 – CUSTODY ..................................................................................................................................... 37
ITEM 16 – INVESTMENT DISCRETION ........................................................................................................... 38
ITEM 17 – VOTING CLIENT SECURITIES AND CLASS-ACTION LAWSUITS ......................................................... 38
ITEM 18 – FINANCIAL INFORMATION ........................................................................................................... 39
ITEM 19 - REQUIREMENTS FOR STATE-REGISTERED ADVISORS ..................................................................... 39
BROCHURE SUPPLEMENT (“SUPERVISED PERSONS”) ................................................................................... 41
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Part 2A of Form ADV: Almega Wealth Management LLC
As used in this Brochure, the words "our" and "us" also refer to Almega. The words "you," "your," or
"client" refer to our clients and prospective clients. Other terms may be defined later in this brochure as
well.
ITEM 4 – ADVISORY BUSINESS
Legal Description of the Firm
Almega Wealth Management LLC (“Almega”) is an Arizona Limited Liability Company founded in 2021, with its
principal place of business in Arizona. Almega Wealth Management LLC is a manager-managed limited liability
company (LLC) managed by Wisda Family Management Inc. Almega Wealth Management LLC is owned solely
by Bryan Craig Wisda. Wisda Family Management Inc. is owned by the Bryan & Sarah Wisda Family Trust.
Almega Wealth Management LLC is a Registered Investment Advisor, registered in Arizona, Florida, Indiana,
Kentucky, North Carolina, and Virginia. It operates in other states pursuant to those states’ De Minimis
regulations. Almega Wealth Management has $134,306,196 in regulated assets under management as of the
date of this brochure, of which approximately $129,816,916 is managed on a discretionary basis.
Almega Wealth Management has office locations in Scottsdale (AZ), Greenville (KY), Louisville (KY), Mount Airy
(NC), and Raleigh (NC). All books and records are maintained at our principal place of business in Scottsdale,
Arizona.
Wisda Family Management Inc. owns Almega Tax LLC. Almega Tax LLC is a manager-managed limited liability
company (LLC) managed by Wisda Family Management Inc. It provides professional tax services to clients and
non-clients of Almega Wealth Management.
Real Fiduciary™ Advisor Affirmation Program
Almega Wealth Management has voluntarily subscribed to the “Real Fiduciary™ Practices” published by the
Institute for the Fiduciary Standard. Real Fiduciary™ Practices offer a simple code of conduct and outline a
commitment to clients of subscribing financial advisors. They seek to clearly articulate what a client can
expect to receive from a subscribing financial advisor. These Real Fiduciary™ Practices do not replace our
regulatory compliance obligations or duties to clients under relevant laws, rules, or regulations. The Institute
for the Fiduciary Standard’s role is limited to publishing the practices as well as maintaining a corresponding
register of subscribing financial advisors. You can verify our affirmation of Real Fiduciary™ Practices on our
website or at the Institute for the Fiduciary Standard website at www.thefiduciaryinstitute.org. The practices
can be found at https://thefiduciaryinstitute.org/wpcontent/uploads/2019/03/Real-Fiduciary-Practices-2019-
02-22.pdf
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Part 2A of Form ADV: Almega Wealth Management LLC
Description of Primary Services Offered
The following paragraphs describe the primary services offered by Almega Wealth Management LLC. Please
refer to the following paragraphs for more detail about the specific service and how we tailor our services to
your individual needs.
Private Wealth Management Service
Almega Wealth Management’s Private Wealth Management Service is suited for high-net-worth
individuals and successful families with liquid assets exceeding $1 million.
Our wealth management process involves defining financial and life goals and creating strategies
designed to achieve the desired results based on the client's particular circumstances. Within our
Private Wealth Management Service offering, we offer clients investment consulting, advanced
planning, and relationship management. We may offer other customized advisory services depending
on the client’s individual needs.
The investment consulting service included within our Private Wealth Management Service offering
focuses on managing financial assets using primarily a passive investment advisory portfolio coupled
with opportunistic rebalancing. The investment consulting process begins with selecting an investment
strategy. The client’s investment strategy will reflect the client’s investment objectives, risk tolerance,
and any desired investment restrictions. Almega usually is given the discretion and authority to
manage client investment accounts. This means Almega is authorized to perform various functions at
the client’s expense without further approval from the client. Such functions include the
determination of securities to be purchased or sold and the number of securities to be bought or sold.
Almega continually manages each investment account as changes in issuer, market conditions, and
client circumstances may require. For more detailed information specific to Investment Advisory see
Item 4.3 “Investment Consulting Services.” Almega may also provide non-discretionary investment
management services to our Private Wealth Management Service clients. In providing non-
discretionary services, Almega will obtain the approval of the client before executing a trade.
Our advanced planning services encompass retirement planning, educational planning, tax planning,
risk management, debt management, charitable giving, and estate planning. This is primarily an
analytical process designed to organize financial data, identify needs and opportunities, and evaluate
alternative courses of action. Advanced Planning may address current net worth, income tax issues,
cash flow and budgeting strategies, retirement planning, employee benefit plan analysis, estate and
gift tax planning, charitable giving, education pre-funding, and risk management. The goal is to
develop a planned strategy for the successful management of personal income, assets, and liabilities in
meeting the client’s financial goals and lifetime objectives. Depending on individual preferences, some
form of written plan may be produced as part of the wealth management process.
Relationship management focuses on assisting the client’s engagement with other professional
advisors, such as their Attorney, Accountant, Insurance Agents, Bankers, and other professionals
related to the management of the client’s financial and non-financial affairs.
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For Private Wealth Management clients who maintain a minimum of $1 million in investable assets
under management with Almega Wealth Management, tax return preparation services of a “standard
tax return” by Almega Tax LLC are complimentary. Non-standard tax returns are billed at an hourly
rate by Almega Tax LLC. Non-standard tax returns are those tax returns that include rental real estate,
small business ownership, partnership interests, charitable trusts, estate taxes, or multiple K-1 filings,
as examples. Depending on the nature of the client relationship, we may waive the hourly tax return
preparation costs for non-standard tax returns.
For its Private Wealth Management clients, Almega offers complimentary cash management.
Because each client is unique, this general description does not discuss the many individual issues and
factors that may be involved in our wealth management process for specific clients. For example,
some clients are engaged in funding charitable activities while others are not. Clients are advised to
promptly notify us of all material changes in their financial situation or investment objectives. The
level of services chosen is entirely at the client’s discretion and based on their financial needs and their
personal preferences concerning what services they desire and how they want the selected services to
be delivered.
This is a general description of our Private Wealth Management Service offering.
Family Wealth Management Service
Almega Wealth Management’s Family Wealth Management Service is offered to high-net-worth
individuals and successful families in addition to those services provided as part of our Private Wealth
Management Service. These services are designed to address the complex and often multi-
generational financial needs of highly affluent households.
These services are generally offered to successful families with combined family assets under
management by Almega Wealth Management of at least $5 million.
Our Family Wealth Management Service may include, but is not limited to:
Intergenerational wealth transfer planning, gifting strategies, and family governance consulting
• Coordination of tax, legal, and estate planning professionals
• Coordination of clients’ tax
•
• Oversight of trust and estate administration
• Consolidated family reporting and performance monitoring
• Philanthropic advisory, including charitable giving strategies and foundation management
• Assistance with business succession planning
• Private investment due diligence
• Cash flow and liquidity management
• Personal financial concierge services
For our Family Wealth Management clients, Almega Tax LLC will provide complimentary tax return
preparation services for standard tax returns for all family members. Based on the nature of the
relationship, Almega Tax LLC may bill an hourly rate or waive fees for the preparation of non-standard
tax returns.
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Part 2A of Form ADV: Almega Wealth Management LLC
All family members taking part in our Family Wealth Management Service are offered complimentary
cash management.
This is a general description of our Family Wealth Management Service.
Business Services
Business Services are offered to small businesses, associations, retirement plans, and non-profit
organizations.
Within our Business Services offering, we offer investment consulting services, cash management
services, financial planning, tax planning, tax return preparation services, and qualified retirement plan
services.
Because each client is unique, this general description does not discuss the many individual issues and
factors that may be involved in our wealth management process for specific clients. For example,
some clients are engaged in funding charitable activities while others are not. Clients are advised to
promptly notify us of all material changes in their financial situation or investment objectives. The
level of services chosen is entirely at the client’s discretion and based on their financial needs and their
personal preferences concerning what services they desire and how they want the selected services to
be delivered.
This is a general description of our Business Services offering.
Description of Ancillary Services Offered as Part of Our Other Services
The following paragraphs describe the ancillary services offered by Almega Wealth Management LLC to our
Private Wealth Management, Family Wealth Management, or Ramsey SmartVestor clients. Please refer to the
following paragraphs for more details about the specific service and how we tailor our services to your
individual needs.
Investment Consulting Services
Almega provides continuous and ongoing investment advisory and portfolio management services as a
part of our Private Wealth Management Service, Family Wealth Management Service, and Ramsey
SmartVestor Service offerings. We do not provide Investment Consulting Services as a standalone
offering.
We primarily offer passive investment advisory portfolios. Our passive investment portfolios primarily
involve managing investments in passive or index-based mutual funds, exchange-traded funds (ETFs),
and/or direct indexing through model portfolios. The model portfolios are tailored to each client’s
individual needs. Almega may provide management of US Treasury securities, Certificates of Deposit,
and Principal-Protected Structured Notes as part of its passive investment advisory portfolios.
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Customized active investment advisory services are utilized when clients’ needs are specific (i.e.,
concentrated stock positions, restricted stock, or company stock options). Active investment advisory
services primarily involve managing investments of individual equity or debt securities, options
contracts, fixed-income securities, mutual funds, and exchange-traded funds (ETFs).
We have discussions with the client to determine the client's investment objectives, risk tolerance,
time horizons, and liquidity needs; we may also use specialized software, such as Riskalyze, to
determine this. We use the information we gather to prepare an individualized Investment Policy
Statement ("IPS"), which guides Almega’s discretionary investment decisions for clients.
Clients may impose reasonable restrictions and guidelines on investing in certain securities, types of
securities, or industry sectors. We expect all such restrictions to be timely communicated to us. Client
restrictions and guidelines may negatively affect investment performance. Any restrictions imposed by
the client will be reflected in their Investment Policy Statement.
Clients must inform us of any changes to their financial circumstances, investment objectives or risk
tolerance ,or any modifications or restrictions to be imposed on the management of the client's
account. In this manner, we can better serve our clients' needs.
Account management and supervision is guided by the client's IPS and market conditions. We manage
clients' investment accounts on a discretionary basis; in certain limited circumstances, we may also
provide management on a non-discretionary basis. Once we construct an Investment Policy
Statement for a client, we will monitor the portfolio's performance on an ongoing and continuous
basis, unless otherwise agreed, and will make adjustments and reallocations as necessary due to
changes in market conditions and the client's circumstances, as communicated to us.
For our discretionary asset management services, Almega will receive a limited power of attorney to
effect securities transactions on behalf of the client. The client may limit our discretionary authority by
providing us with written communication that details restrictions and other guidelines. Unless
otherwise agreed to by the client and Almega, if we manage a client's account on a non-discretionary
basis, we will have the ongoing responsibility to make investment recommendations based on the
client's individualized investment strategy or we will develop and implement an asset allocation
strategy, which we will continuously monitor and supervise.
We will obtain the client's approval before executing transactions in a non-discretionary account.
Requests for approval will be communicated via electronic mail to an authorized account or via a
telephone call to an authorized phone number. The client will be responsible for responding promptly.
We explore different investment options and strategies in designing a client's customized Investment
Policy Statement. Our investment recommendations are not limited by any specific product or service
offered by a broker-dealer or custodian. These recommendations will generally include, but not
necessarily be limited to, Mutual Funds and Exchange-Traded Funds, U.S. Treasury Securities (Bills,
Notes, and Bonds), FDIC Insured Certificates of Deposit, Principal Protected Structured Notes, and
Money Market Funds.
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Each type of security has its own unique set of risks associated with it. 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.
Because some types of investments involve certain additional degrees of risk, they will only be
recommended and implemented when consistent with the client's IPS.
Cash Management Services
Almega Wealth Management’s Cash Management Services aims to provide clients with returns that
are competitive with bank offerings on strategic cash holdings.
Almega Wealth Management offers its Cash Management Services on a complimentary basis to its
Private Wealth Management and Family Wealth Management clients. We may also offer our Cash
Management service to companies, charities, and non-profit associations owned by or associated with
our Private Wealth Management and Family Wealth Management clients for a fee or on a
complimentary basis, depending on the nature of the relationship.
Our Cash Management Service primarily manages short-term US Treasury Securities for clients on a
discretionary basis. In certain circumstances, we may also utilize FDIC-insured certificates of Deposit.
These services may be tailored to a client’s unique needs.
Account management and supervision is guided by the client's IPS and market conditions. We manage
clients' cash management accounts on a discretionary basis. Almega Wealth Management does not
provide Cash Management Services on a non-discretionary basis.
Once we construct an Investment Policy Statement for a client, we will monitor their cash
management account(s) on an ongoing and continuous basis and will make adjustments as necessary
due to changes in market conditions and the client's circumstances, as communicated to us.
Each type of security has its own unique set of risks associated with it. 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.
Because some types of investments involve certain additional degrees of risk, they will only be
recommended and implemented when consistent with the client's IPS.
Tax Return Preparation Services
Almega Wealth Management provides tax return preparation services, tax planning, and IRS
representation to clients through Almega Tax LLC.
Private Wealth Management clients with investable assets under management (excluding Cash
Management Services) exceeding $1 million are offered tax return preparation services for a “standard
tax return” on a complimentary basis. Additionally, all family members of Family Wealth Management
clients are offered tax return preparation services for a “standard tax return” on a complimentary
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basis. Non-standard tax returns are those tax returns that include rental real estate, small business
ownership, partnership interests, charitable trusts, estate taxes, or multiple K-1 filings, as examples.
Depending on the nature of the client relationship, we may waive the hourly tax return preparation
costs for non-standard tax returns.
Clients who are not offered complimentary tax return preparation services are offered a flat rate for
preparing a standard tax return. Non-standard tax returns are billed at an hourly rate by Almega Tax
LLC. Depending on the nature of the client relationship, we may negotiate lower fees for the standard
tax return preparation.
Clients are under no obligation to use Almega Tax LLC’s services and tax services are not tied to
advisory account openings.
Qualified Retirement Plan Services
Almega Wealth Management offers retirement plan services to small businesses and non-profit
associations owned by or associated with our Private Wealth Management, Family Wealth
Management, Ramsey SmartVestor, or Business Services clients.
Our retirement plan services can include, but are not limited to, the following services:
Fiduciary Consulting Services
Almega Wealth Management provides the following Fiduciary Retirement Plan Consulting Services:
•
Investment Policy Statement Preparation – Almega helps clients develop an investment policy
statement. The investment policy statement establishes the investment policies and objectives for
the Plan. Clients have the ultimate responsibility and authority to establish such policies and
objectives and to adopt and amend the investment policy statement.
•
•
•
• Non-Discretionary Investment Advice – Almega provides clients with general, non-discretionary
investment advice regarding asset classes and investment options, consistent with the client’s
investment policy statement.
Investment Selection Service – Almega provides clients with recommendations of investment
options consistent with ERISA section 404(c).
Investment Due Diligence Review – Almega provides clients periodic due diligence reviews of the
Plan's reports, investment options, and recommendations.
Investment Monitoring – Almega assists in monitoring investment options by preparing periodic
investment reports that document investment performance, consistency of fund management, and
conformation to the guidelines set forth in the investment policy statement. Almega makes
recommendations to maintain or remove and replace investment options.
• Default Investment Alternative Advice – Almega provides Plan Sponsors with non-discretionary
investment advice to assist with the development of qualified default investment alternative(s)
("QDIA"), as defined in DOL Reg. Section 2550.404c-5(e)(4)(I), for participants who are
automatically enrolled in the Plan or who otherwise fail to make an investment election. Plan
Sponsors retain the sole responsibility to provide all notices to participants required under ERISA
section 404(c)(5).
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•
Individualized Participant Advice – Upon request, Almega provides one-on-one advice to Plan
participants regarding their individual situations. We can also meet with individual participants to
discuss their specific investment risk tolerance, investment time frame, and investment selections.
For Fiduciary Consulting Services, all recommendations of investment options and portfolios are
submitted to clients for the clients' ultimate approval or rejection. The retirement plan sponsor client
or the plan participant who elects to implement any recommendations made by us is solely responsible
for implementing all transactions.
Fiduciary Consulting Services are not management services, and Almega does not serve as
administrator or trustee of the plan. Almega does not act as custodian for any client accounts or have
access to client funds or securities (except for having written authorization from the client to deduct
our fees).
Almega Wealth Management acknowledges that in performing the Fiduciary Consulting Services listed
above that it is acting as a "fiduciary" as such term is defined under Section 3(21)(A)(ii) of the Employee
Retirement Income Security Act of 1974 ("ERISA") for purposes of providing non-discretionary
investment advice only.
Fiduciary Management Services
Almega Wealth Management does not maintain or promote ERISA 3(38) plans but could provide that
service if requested.
• Discretionary Investment Selection Services – Almega will monitor the investment options of the
Plan and add or remove investment options for the Plan. Almega Wealth Management will have
discretionary authority to make all decisions regarding the investment options that will be made
available to Plan participants.
•
• Default Investment Alternative Management – Almega will develop and actively manage qualified
default investment alternative(s) ("QDIA"), as defined in DOL Reg. Section 2550.404c-5(e)(4)(I), for
participants who are automatically enrolled in the Plan or who otherwise fail to make an
investment election.
Investment Management via Model Portfolios – Almega will provide discretionary management via
model portfolios. Almega manages model portfolios which are investment options available to
Plan participants. If a Plan has elected to include Almega Wealth Management’s passive model
portfolios as available options for the qualified retirement plan, then each Plan participant will
have the opportunity to elect or not elect the model portfolios managed by Almega and will be
allowed to impose reasonable restrictions upon the management of each account by written
instructions to Almega.
If clients elect to utilize any of Almega Wealth Management’s Fiduciary Management Services, then
Almega Wealth Management will be acting as an Investment Manager to the Plan, as defined by ERISA
section 3(38), with respect to our Fiduciary Management Services, and Almega Wealth Management
hereby acknowledges that it is a fiduciary with respect to its Fiduciary Management Services.
Retirement Plan Services - General Information and Disclosures
Securities and other types of investments all bear different types and levels of risk. Those risks are
typically discussed with clients in defining the investment policies and objectives, which guides our
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investment decisions for clients' qualified plan accounts. Upon request, as part of our retirement plan
services, we can discuss those investments and investment strategies that we believe may tend to
reduce the risks for a particular client and plan participant’s circumstances.
Additional Details About Our Advisory Business
Wrap Fee Programs
Almega does not participate in or sponsor any wrap-fee programs.
Held Away Assets
We may use a third-party platform such as, but not limited to, Pontera, to facilitate management of held away
assets such as, but not limited to, defined contribution plan participant accounts with discretion. The third-
party platform allows Almega to review the current account allocations without having custody of these held-
away client accounts or access to client log-in credentials. Almega is not affiliated with Pontera in any way and
receives no compensation for using its platform.
If a client requests we manage their held-away assets, a link will be provided to connect an account(s) to the
third-party platform. Once said account(s) are connected to the platform, we will review the current account
allocations from within the third-party platform. When deemed necessary, based on our review from time to
time (but at least annually), we will rebalance the account considering the client’s investment goals and risk
tolerance, and any change in allocations will consider current economic and market trends.
If a client requests us to manage their held-away assets as part of our Investment Advisory Service these
assets will be subject to a fee. For more information about our fees, please refer to Item 5 – Fees and
Compensation.
Direct Indexing & Outsourced Trading Services
In providing our discretionary asset management services, we may elect to engage the services of Advyzon
Investment Management LLC (“AIM”), Charles Schwab (“Schwab”), Altruist LLC (“Altruist”), Dimensional Fund
Advisors (“DFA”), Absolute Capital, and/or Pontera Solutions Inc. (“Pontera”) as an outsourced agent(s) to
provide certain operational, administrative, investment management, and/or trading functions. We do not
necessarily use the services of these outsourced agents for all clients; we may elect to use these outsourced
agents for clients based on the needs of the individual client, without prior consultation or consent of the
client.
When we engage these outsourced agents for a client, we provide an asset allocation model portfolio and
designate the appropriate model for each client account. We will also define the parameters for supervising
your account, including the rebalancing frequency and the allowable drift from asset allocation targets. We
also choose the securities to be utilized. Once we choose the model portfolio for a client account(s) and
define the parameters, the outsourced agent(s) will provide ongoing supervision of the account(s) in
accordance with the model portfolio and our defined parameters.
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Please note that if we engage an outsourced agent, they may obtain access to your confidential information
from us and/or from the custodian of your brokerage account(s). As stated in our Privacy Policy, we are
authorized to share your personal information with third parties as necessary to service your account. Our
agreement with these providers includes provisions requiring your personal information be held in strict
confidence and to maintain reasonable technological protections, precautions, and safeguards your
information.
The fees associated with direct indexing are billed directly to the client by the outsourced agent. Fees for the
utilization of other outsourced agent services are not passed onto the client.
Outsourced agents who are providing direct indexing services to clients are authorized to vote proxies for
those securities purchased as part of the direct indexing service.
Standard of Care Regarding Qualified Plans and/or IRA Accounts
When we provide investment advice to you regarding your retirement plan account (i.e., 401k) or individual
retirement account (IRA), we are fiduciaries within the meaning of Title I of the Employee Retirement Income
Security Act (ERISA) and/or the Internal Revenue Code (IRC), as applicable, which are laws governing
retirement accounts. The way we make money creates some conflicts with your interests, so we operate
under a special rule that requires us to act in your best interest and not put our interests ahead of yours.
Under this special rule’s provisions, we are required to:
a) Meet a professional standard of care when making investment recommendations (give prudent advice)
b) Never put our financial interests ahead of yours when making recommendations (give loyal advice)
c) Avoid misleading statements about conflicts of interest, fees, and investments
d) Follow policies and procedures designed to ensure that we provide advice that is in your best interest
e) Charge no more than is reasonable for our services
f) Give you basic information about conflicts of interest
Information Regarding Conflicts of Interest
Almega has conflicts of interest arising from our advisory services. These include, but are not limited to:
• Conflicts related to how Almega’s investment advisor representatives (IARs) get paid (Please refer to
Item 5 below).
• Conflicts related to Almega Tax LLC. Almega Tax LLC and Almega Wealth Management LLC are under
common ownership; thus, there may be a financial incentive for Almega Wealth Management to
recommend that clients utilize the services of Almega Tax LLC.
• Conflicts related to allocating time and resources between client accounts, allocation of advisory fees,
and investment opportunities generally. For further information on our brokerage and allocation
policies and related conflicts of interest, please refer to Item 12 below.
• Conflicts related to investing in securities recommended to clients and contemporaneous trading of
securities (i.e., personal trading) by Almega or its related persons. Please refer to Item 11 for further
information.
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Almega’s policies and procedures attempt to mitigate conflicts of interest. However, the conflicts of interest
discussed here and in other sections of this brochure still exist and cannot be removed or eliminated.
Publication of Periodicals/Newsletters
Almega may publish newsletters, videos, podcasts, and/or social media posts providing general information on
various financial topics, including, but not limited to, estate and retirement planning, market trends, etc. No
specific investment recommendations are being provided in any newsletter or social media post, and the
information provided is not intended and does not purport to meet the objectives, needs, or targets of any
client or individual. Absent specific advice or services provided by Almega, clients should rely on something
other than the information contained in any newsletter or social media post. This newsletter will be
distributed to our advisory clients, prospects, and other professionals.
Educational Seminars
Almega may periodically offer educational seminars, webinars, and/or workshops for clients, prospective
clients, accountants, and others. Although these seminars may address financial planning, Social Security
strategies, investment management, and investment and retirement planning, their content will vary
depending on the needs of the attendees. These seminars are purely educational in nature and do not involve
the sale of any investment products or investment advisory offering. The information presented will not be
based on any individual's personal needs, and we do not provide individualized investment advice to
attendees during these seminars.
Almega may charge a nominal fee, typically less than $25 per attendee, to cover basic costs associated with
the seminars, webinars, and/or workshops. Almega does not charge for educational seminars in the State of
Kentucky.
Almega does not conduct educational seminars in the State of Virginia.
ITEM 5 – FEES AND COMPENSATION
Fees will be charged quarterly in advance based on the value of the client’s account(s), as determined by the
custodian, as of the last day of the previous quarter. For partial quarters, fees are prorated based on the
number of days remaining in the quarter.
Cash and assets that are invested in mutual funds, money market funds and other cash instruments, individual
securities, ETFs, annuities we manage, options, and any other security held by the custodian shall be included
in the calculation of the value of the client’s assets under management with us for the purposes of computing
our fee. Held-away assets that the client has requested we manage as part of our service offerings will also be
included in this calculation.
Unless other arrangements are made, fees are directly debited from a client's account(s); each client is
required to provide the qualified custodian of each account with written authorization to deduct the fees
described. Clients may terminate the relationship at any time with written notice. All unearned fees will be
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refunded to the date the termination notice is made. Almega will generally provide 30 days’ notice to the
client if we terminate the relationship; we reserve the right to do so for any reason.
The various custodians charge fees and/or commissions for their services; these fees are paid by the client in
addition to the fees charged by Almega. These fees and/or commissions may include mutual fund trade ticket
charges, equity trading commissions, option trading commissions, account fees, margin interest, and other
account-level fees and charges.
The custodian sends the client a statement, at least quarterly, indicating the amount of our fees and all
amounts disbursed from the account to Almega for our fees. The client is encouraged to verify the accuracy of
the fee calculation, as the custodian will not verify the calculation. Payment of fees may result in the
liquidation of the client's securities if there is insufficient cash in the client's account(s).
Clients will not receive a monthly account statement from Almega; custodians are responsible for providing
clients with monthly account statements. Almega provides clients with a quarterly performance report which
includes a fee invoice. The client is encouraged to verify that the assets under management reported in the
quarterly performance report and fee invoice match the values of the accounts reported by their custodians.
Asset-based fees are always subject to the management agreement between the client and Almega, and we
generally retain the right to amend our fee schedule with written agreement by the client.
Clients should be aware that similar advisory services may or may not be available from other investment
advisors for equal or lower fees.
Almega Wealth Management generally requires a minimum portfolio size of $1,000,000 and a minimum
investment advisory annual fee of $10,000. In certain circumstances, we may waive this minimum based on
the individual client’s circumstances, for family members of clients, and for clients referred to us.
Although, Almega has established the fee schedules below, we may negotiate lower fee schedules depending
on the size of the account, type of account, the type of investment management style, the level of client
service required, and other factors we consider relevant.
Fees for Private Wealth Management and Family Wealth Management
Almega’s fee for our Private Wealth Management and Family Wealth Management will be charged as a
percentage of a client’s and their family’s aggregate assets under management with us according to the
following schedule:
Private Wealth Management – AUM
First $5,000,000
Next $5,000,000
$10,000,001 and above
Annual Fee Rate
1.00%
0.50%
0.25%
The specific annual fee charged to the client will be set forth and identified in an agreement between Almega
and that client.
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If the client requests or requires a customized active investment advisory service, instead of the passive
investment advisory service included in our Private Wealth Management Service offering, for any account(s),
Almega may charge an AUM fee up to +1.0% higher than quoted in the above table for the specific account(s)
utilizing an active investment advisory service. Customized active investment advisory services are not
available to clients who select our Ramsey SmartVestor Service offering.
Private Wealth Management and Family Wealth Management clients whose assets under management
(excluding cash management and 529 plans) fall below $500,000 may be charged an additional 0.10%.
Fees for Cash Management Services
Cash Management Services will be charged as a percentage of the value of the cash management account(s)
us according to the following schedule:
Cash Management – AUM
$0.01 and above
Annual Fee Rate
0.10%
Almega Wealth Management provides its Cash Management Service to clients utilizing our Private Wealth
Management service and Family Wealth Management service on a complimentary basis. However, clients
whose total assets under management (excluding Cash Management and 529 plans) fall below $1 million may
be charged a fee for our Cash Management Services. Cash Management Services are generally not offered to
clients who utilize our Ramsey SmartVestor Service offering.
Fees for Tax Return Preparation Services
Fees for tax return preparation services are billed directly to the client by Almega Tax LLC.
Private Wealth Management clients with investable assets under management (excluding Cash Management
Services) exceeding $1 million are offered tax return preparation services for a “standard tax return” on a
complimentary basis. Family members of Family Wealth Management clients are offered complimentary
“standard tax return” preparation. Non-standard returns are those tax returns that include rental real estate,
small businesses, partnership interests, certain trusts, estate taxes, foreign accounts, multiple state income tax
filings, or multiple K-1 filings, as examples. Depending on the nature of the client relationship, we may waive
the hourly tax return preparation costs for non-standard tax returns. Clients who are not offered
complimentary tax return preparation services are offered a flat rate of $600 (2025 Tax Year) for the
preparation of a “standard tax return.”
Almega Tax LLC bills $300 per hour for the preparation of non-standard tax returns, business tax returns, prior
year tax amendments, bookkeeping services, and IRS representation. Depending on the nature of the client
relationship, Almega Tax LLC may negotiate lower fees.
Clients are not obligated to use Almega Tax LLC’s services. Similarly, tax-only clients of Almega Tax LLC are not
required to establish or maintain a relationship with Almega Wealth Management.
Fees for Qualified Retirement Plan Services
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Almega’s fee for our Qualified Retirement Plan Services will be charged as a percentage of each plan’s assets
under management with us according to the following schedule:
Defined Benefit Plan – AUM
First $10,000,000
$10,000,001 and above
Annual Fee Rate
0.50%
0.25%
Defined Compensation Plan – AUM
First $2,000,000
$2,000,001 and above
Annual Fee Rate
0.20%
0.10%
Please note: Solo-401k plans are billed as part of our Private Wealth Management, Family Wealth
Management, or Ramsey SmartVestor service.
Fees for Business Services
Almega’s fee for our Business Services is charged at an hourly rate. Hourly rates are billed commensurate with
the skill level and experience of the team member providing the services, ranging from $300 to $1,200 per
hour. Clients are provided with firm invoices prior to any Business Services engagement.
Fees for Periodicals, Newsletters, Podcasts, & Social Media
We do not charge subscribers for our newsletter, periodicals, podcasts, or social media posts. Almega may
receive compensation from platforms such as Spotify, Facebook, Instagram, and YouTube for publishing
podcasts, videos, and social media posts when our audience listens to or views our content on those
platforms. Any revenue generated by Almega under such circumstances will be donated to charity.
Fees for Educational Seminars
Almega may charge a fixed fee per attendee, typically less than $25, for educational seminars. Seminar fees
are non-negotiable. Almega does not charge a fee to attend its educational seminars in the State of Kentucky
or in any state where such fees are prohibited by law. Almega does not conduct seminars in the State of
Virginia.
Payment for Services, Margin Billing, and General Information
The client may select to be directly billed for our services or to have the custodian for the investment account
deduct our fees from the investment account. The client must provide written authorization permitting
Almega to bill the custodian for Almega’s fees if our fees are going to be directly debited from a client’s
custody account. In addition, the account must be held by a qualified independent custodian, and the
qualified custodian must agree to send the client an account statement each calendar quarter. Each quarterly
account statement must indicate all amounts disbursed from the account, including fees paid directly to
Almega. Clients are encouraged to verify the accuracy of the custodian statement and fee calculation. The
investment account custodian will not determine whether the fee is calculated correctly.
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It is our standard business practice to bill on the value of assets reported to us by the client’s custodian on the
close of business the day prior to generating an invoice. We do not recalculate the value reported to us by the
custodian of the client’s assets to account for margin balances or investments.
An investment management agreement may be terminated at any time by the client, or with 30 days written
notice by Almega, for any reason. The timing is specified in the client management agreement between
Almega and the client. Additionally, if a client receives this Brochure at the time the client enters into the
investment management agreement, the client has the right to terminate the agreement within 10 business
days for a full refund by notice of termination to Almega.
All fees paid to Almega are separate and distinct from fees and expenses charged by any mutual fund,
exchange-traded funds, or other investment product. Fund fees are described in the respective fund's
prospectus. These fees will generally include management fees, various expenses, and a possible distribution
fee. The client should review all fees being charged on its investments and those charged by Almega to fully
understand the total amount of fees to be paid by the client and to evaluate the advisory services being
provided.
Additionally, the client is also responsible for paying the fees and expenses charged by their independent,
qualified custodian(s). Clients may incur certain charges imposed by custodians, brokers, and other third
parties, such as custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, electronic fund
fees, transaction fees,and other fees and taxes on brokerage accounts and securities transactions. For
additional information, please refer to Item 12 (Brokerage Practices) in this Brochure.
Almega has a fiduciary duty to all its clients. To avoid engaging in prohibited transactions,
Almega, its management personnel, its related persons, and its supervised persons may NOT receive any
compensation from current clients other than those fees described herein. For more information, see Items
10 & 11.
Almega reserves the right to charge past clients an hourly rate of $300 for research or other inquiries made
more than 180 days after termination of the client relationship.
Under no circumstances do we require or solicit payment of fees in excess of $500 more than six months in
advance of services rendered.
ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
Almega does not charge performance-based fees or participate in side-by-side management. Performance-
based fees are fees based on the share of capital gain or capital appreciation of a client's account.
Side-by-side management refers to the practice of managing accounts that are charged performance-based
fees while at the same time managing accounts that are not charged a performance-based fee. We do not
charge performance-based fees, nor do we provide side-by-side management.
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ITEM 7 – TYPES OF CLIENTS
Almega primarily offers its services to individuals, high-net-worth individuals, small businesses, charitable
organizations, retirement plans, guardianships, conservatorships, estates, and trusts.
Almega does not have any established or stated minimum account requirements. Almega evaluates all client
relationships on a case-by-case basis to determine whether Almega can provide value to the client. If, in our
analysis of the client’s situation, Almega does not feel it can provide value to the client, we will advise the
client as to why and recommend an alternative advisory firm.
ITEM 8 – INVESTMENT STRATEGIES, METHODS OF ANALYSIS, AND RISK OF LOSS
Almega offers several distinctive investment strategies that are categorized as passive investment
management styles.
Passive Asset Allocation Investment Strategies Offered
Almega Wealth Management’s passive asset allocation investment strategies target reliable drivers of higher
returns across equity and fixed income markets; primarily utilize mutual funds and ETFs which use flexible
implementation to focus on higher expected returns, manage risks, and minimize costs; all funds and ETFs
utilized are priced within the lowest quartile among their category peers.
The passive asset allocation investment strategies we offer include:
• Core - Pursues higher expected returns across global equity and fixed-income markets. Deviates from
traditional market capitalization weights to target securities with higher expected returns,
overweighting small-cap and value companies relative to market-wide capitalization.
• Core Plus - Seeks returns above those of the Core Models by increasing the target weight allocation to
small-cap companies and adds profitability as an additional factor.
• Sustainability – Seeks to align certain sustainability values with investment goals, focusing on scientific
drivers of climate change.
• Tax-Sensitive – Includes a focus on municipal bonds within the fixed income allocation and actively
seeks to minimize trading and rebalancing to reduce capital gains.
• Socially Responsible – Seeks to align certain social values with investment goals, seeking to exclude
companies involved in areas of social concern.
• Dave Ramsey – Seeks to mirror the asset allocation philosophies of Dave Ramsey.
Methods of Analysis
Asset Class Investing: Almega’s Passive Asset Allocation Strategies are best described as “asset class
investing.” They are based on the premise that global financial markets are highly efficient (prices adjust very
quickly to new information) and the primary factor affecting the variability of returns is the asset allocation
decision.
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The mix of assets in a portfolio (the “asset allocation”) is the primary determinant of portfolio returns over
time. Our selection of asset classes (groups of securities with similar risk and return characteristics) is
influenced primarily by the research of Nobel Laurette Professor Eugene Fama, Sr. (University of Chicago) and
Professor Kenneth French (Dartmouth College). We also follow the research on securities and financial
markets from many other academics around the world (Robert Novy-Marx, Merton Miller, Abbie J. Smith,
Roger Ibbotson, Robert Merton, and Myron Scholes)
Modern Portfolio Theory: Almega’s Passive Asset Allocation Strategies adhere to the principles of Modern
Portfolio Theory (MPT). MPT is based on the observation that diversifying among different investments that
are not highly correlated can result in a weighted average of the asset class returns, but less than a weighted
average of their risk. In other words, mixing low correlating investments or asset classes in a portfolio can
reduce the volatility of the portfolio without lowering the overall portfolio's expected return.
Diversification: Almega’s Passive Asset Allocation Strategies will generally diversify client’s assets among the
following passively managed or index strategies: money market funds; fixed income mutual funds and/or ETFs;
large and small U.S. company equity mutual funds and/or ETFs; large and small international company equity
mutual funds and/or ETFs; large and small equity mutual funds and/or ETFs in select emerging markets; U.S. or
international real estate investment trust (REITs) mutual funds and/or ETFs. We may also make
determinations as to overweight growth equities (lower book-to-market price) or value equities (higher book-
to-market price) in our U.S. equity, international equity, or emerging market equity mutual funds and/or ETFs.
From time to time, based on our research and the research of others, we may use individually issued cash
equivalents, certificates of deposit, individual US Treasury securities, and/or high-quality, short-term,
individual fixed-income securities.
Asset Allocation: Almega’s Passive Asset Allocation Strategies utilize a mix of asset classes for client portfolios
based on an assessment of their long-term financial objectives. Where appropriate, we will recommend an
allocation to high-quality, shorter-term bonds (either in a broadly diversified index or asset class mutual fund
or using individual securities) to reduce overall portfolio risk, generate a more predictable cash flow (interest
income), facilitate portfolio rebalancing, and provide a hedge against inflation. If the client’s objective is a
higher annual expected return and the client is willing to accept a higher degree of risk, we will recommend a
portfolio with greater allocations to stocks in general. Recommended stock allocations will generally be
globally diversified among the U.S., foreign developed markets, emerging markets, and REITs.
Current market conditions do not influence our recommended target asset allocation. This asset allocation
(which becomes a client’s written Investment Policy Statement) is altered only when the client’s long-term
investment objectives have changed.
Rebalancing: Almega’s Passive Asset Allocation Strategies asset allocations for client portfolios will change as
financial markets rise and fall. This creates the need to rebalance the portfolio to bring asset class
percentages back to your policy targets. Asset classes that have grown beyond predetermined limits are sold
by an amount that brings the allocation back in line with policy targets, and those that have fallen in value are
similarly purchased. This method of “selling high and buying low” is notably contrarian and is not based on
predicting the direction of markets or asset class returns.
Rebalancing typically has the effect of enhancing portfolio returns while maintaining the agreed-upon risk
level for the portfolio. To limit rebalancing transactions and the costs associated with buying and selling
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mutual funds through the chosen custodian, Almega has set ranges in which allocations may vary and at which
rebalancing is triggered.
Almega may also rebalance when it deems it appropriate. Within the constraints of each client’s investment
policy statement (IPS), Almega Wealth Management will generally allow asset allocations to drift over-weight
and under-weight and subsequently rebalance based on our research.
Investment Selection: Almega’s Passive Asset Allocation Strategies invests client assets in passively managed
index mutual funds and/or ETFs and structured asset class mutual funds and/or ETFs representing selected
asset classes. “Passively managed” refers to the fact that the managers of these kinds of funds do not engage
in active stock picking, market timing, sector rotation, and other speculative strategies that introduce risks to
portfolios that are not compensated with higher returns over time.
Passively managed index and structured asset class mutual funds and/or ETFs generally have much lower
portfolio turnover (the amount of buying and selling of securities), less taxable distributions to shareholders,
much lower internal costs, and much greater diversification, all while outperforming the majority of actively
managed funds over time.
When selecting specific mutual funds or ETFs for client portfolios, Almega examines each fund or ETF’s
management structure, financial condition, and operating procedures. We also analyze each mutual fund or
ETF for adherence to its stated investment objectives (as noted in the fund’s prospectus). The investment
performance of each mutual fund or ETF is observed over past market cycles to determine its correlation to
public indexes (i.e., S&P 500, MSCI EAFE, and Russell 2000 indexes) and proprietary indexes, such as those of
Dimensional Fund Advisors (DFA) and the Center for Research in Securities Prices (CRSP). Almega also
monitors the portfolio turnover, growth in total assets, management and administrative expenses, taxable
distributions, and other relevant information.
Due to account size, inception date, cash flows, tax considerations, and certain other factors, the mutual funds
or ETFs selected for a particular asset class may not be the same for all client accounts, and the actual
percentage mix of asset classes may differ from the targets and other accounts with similar investment
objectives.
Specifically for fixed income allocations, Almega may also invest client assets in US Treasury Securities, FDIC
Insured Certificates of Deposit, Principal Protected Structured Notes, and Money Market Funds. For clients
who request a Tax Sensitive Portfolio, Almega may also invest in municipal bonds.
Within Almega’s Passive Asset Allocation Strategies, risks may include:
Risk of Loss: Investing involves a risk of loss. Clients should be prepared to bear investment losses, including
the loss of the original principal. Clients should never presume the future performance of any specific
investment or investment strategy will be profitable. Further, there may be varying degrees of risk depending
on different types of investments. Clients should know that all investments carry a certain degree of risk
ranging from the variability of market values to the possibility of permanent loss of capital. Although
portfolios seek principal protection, asset allocation and investment decisions may not achieve this goal in all
cases. There is no guarantee that a portfolio will meet a target return or an investment objective.
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Risks to capital include, but may not be limited to, changes in the economy, market volatility, company results,
industry sectors, accounting standards, and changes in interest rates. Investments are generally subject to
risks inherent in governmental actions, exchange rates, inflation, deflation, and fiscal and monetary policies.
Market risks include changes in market sentiment in general and styles of investing. Diversification will not
protect an investor from these risks and fluctuations.
Because of the inherent risk of loss associated with investing, we cannot represent, guarantee, or even imply
that our services and analysis methods can or will predict future results, successfully identify market tops or
bottoms, or insulate clients from losses due to market corrections or declines.
Market Risk: Either the stock market as a whole or the value of an individual company goes down, resulting in
a decrease in the value of client investments. Stocks are susceptible to general stock market fluctuations and
volatile increases and decreases in value as market confidence in and perceptions of their issuers change.
Common stock (or its equivalent) is generally exposed to greater risk than preferred stocks and debt
obligations of an issuer.
Exchange Traded Fund (ETF) and Mutual Fund Risk: The risk of owning an ETF or mutual fund generally reflects
the risks of owning the underlying securities the ETF or mutual fund holds. Clients will incur additional costs
associated with ETFs and mutual funds (see Item 5).
Consumer Discretionary ETF Shares are listed for trading on NYSE Arca and can be bought and sold on the
secondary market at market prices. Although it is expected that the market price of these ETFs typically will
approximate its net asset value (NAV), there may be times when the market price and the NAV vary
significantly. Thus, the client may pay more or less than NAV when these ETFs are purchased on the
secondary market, and the client may receive more or less than NAV when you sell those shares. Although
Consumer Discretionary ETF Shares are listed for trading on the NYSE Arca, it is possible that an active trading
market may not be maintained and trading on the NYSE Arca may be halted by the activation of individual or
market-wide "circuit breakers" (which halt trading for a specific period of time when the price of a particular
security or overall market prices decline by a specified percentage). Trading of Consumer Discretionary ETF
Shares may also be halted if the shares are delisted from the NYSE Arca without first being listed on another
exchange or if exchange officials determine that such action is appropriate in the interest of a fair and orderly
market or to protect investors.
Margin Risk: Margin trading is the act of borrowing funds to invest in additional securities.
The purchased securities serve as collateral for the loan. The primary reason behind margin trading is to
utilize more capital to invest and, by extension, the potential for more profits. Margin trading may result in (a)
amplified losses which could result in losing more money than invested, (b) a margin call whereby you would
be required to deposit more money to cover losses, and/or (c) forced liquidation if there is not enough money
to cover capital requirements and additional monies are not deposited.
Management Risk: Investments managed by Almega vary with the success and failure of our investment
strategies, research, analysis, and determination of portfolio securities. Almega does not engage in high-
frequency trading activities or algorithmic trading strategies.
Foreign Investments Risks: Non-U.S. investments, currency, and commodity investments may contain
additional risks associated with government, economic, political, or currency volatility.
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Emerging Markets Risks: Emerging markets can experience high volatility and risk in the short term.
Additional risks are inherent in emerging markets, which may not be present in other markets. Non-U.S.
investments, currency, and commodity investments may contain additional risks associated with government,
economic, political, or currency volatility.
Liquidity Risks: Generally, assets are more liquid if many investors are interested in a standardized product,
making the product relatively easy to convert into cash. Assets with less interest, known as liquidity risk, are
not easily converted to cash. Examples of investments with liquidity risks utilized in client accounts include
certain bonds, structured products, and certificates of deposits.
Bond Risks: Investments in bonds involve interest rate and credit risks. Bond values change according to
changes in interest rates, inflation, credit climate, and issuer credit quality. Interest rate increases will reduce
the value of a bond. Longer-term bonds are more susceptible to interest rate variations than shorter-term,
lower-yield bonds.
Sector Risks: Investing in a particular sector is subject to cyclical market conditions and charges.
General Risks: Our strategies and investments may have unique and significant tax implications. Almega will
manage portfolios with an awareness of tax implications, but long-term wealth compounding is our primary
consideration. Specific goals regarding account tax efficiency should be set forth in writing. Regardless of
account size or other factors, Almega strongly recommends that its clients continuously consult with a tax
professional prior to and throughout the investing of clients' assets. Each client is responsible which cost-basis
accounting method is the right choice for them. Clients should provide Almega with written notice of a client's
selected accounting method, and Almega will alert the client's custodian of the individually selected
accounting method. Clients should be aware that decisions about cost-basis accounting methods will need to
be made before trades settle, as the cost-basis method cannot be changed after settlement.
Cash Risks: Cash balances are typically invested daily in interest-bearing FDIC-insured money market funds.
Inflationary Risk: Inherent to investing is the risk that your investment returns may not exceed the rate of
inflation over time.
Within our Cash Management portfolios, additional risks may include:
Liquidity Risks: US Treasury Bills are generally extremely liquid investments. However, within 3-5 days of a T-
Bill’s maturity, it becomes very difficult to sell them in the open market. This may pose an issue for investors
who need to sell the T-Bill within a 3-5 day proximity to the maturity date.
Interest Rate Risks: US Treasury Bills behave like bonds. Interest rate increases will reduce the value of the T-
Bill ahead of maturity.
Tax Risks: US Treasury Bills are tax-advantaged in that the interest rate earned, when held to maturity and
with some exception, is exempt from state income tax. However, when T-Bills are sold prior to maturity the
delta between the purchase price and sale price is treated as a capital gain/loss which is taxed differently.
Within a Customized Strategies, additional risks may include:
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Options Risk: Almega may use options in customized client portfolios. Options can lose value in relatively
short periods. Option contracts are leveraged instruments that allow the holder to control shares of the
underlying stock. This embedded leverage may compound gains and losses.
ITEM 9 – DISCIPLINARY INFORMATION
Almega Wealth Management must disclose any legal or disciplinary events that are material to a client’s or
prospective client’s evaluation of our firm, our business, or the integrity of our management or associated
persons.
Most states do not require a Registered Investment Advisor (RIA) or Investment Advisor Representative (IAR)
to register with the state securities division if the RIA or IAR serves five (5) or fewer clients who reside in the
state. This is referred to as the De Minimis Rule. In 2024, Almega Wealth Management and Bryan Wisda
accepted a 6th client before registering with the State of Indiana. When discovered, Mr. Wisda self-reported
the error to the state’s regulators. Subsequently, Almega Wealth Management and Mr. Wisda were required
to sign a Consent Decree and pay a $4,000 fine by the State of Indiana in May 2025.
Daniel Scott Braddock, a supervised person, paid a fine of $8,500 and signed a Consent Decree with the State
of North Carolina regarding unregistered investment-related business activity from 2018 – 2021, prior to his
association with Almega Wealth Management.
For further information regarding the above disciplinary disclosures, you are encouraged to contact Bryan
Wisda, our Chief Compliance Officer, by calling 480-770-4700. You may also visit https://adviserinfo.sec.gov
for further information.
ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Almega, nor its management personnel, is not a registered broker-dealer, registered representative of a
broker-dealer, commodity firm, commodity pool operator, commodity trading advisor, or futures commission
merchant, and does not have an application to register for any of the same pending.
Almega does NOT recommend investment, or any other financial products, for which it receives any form of
compensation.
As a part of Almega’s fiduciary duties, our Supervised Persons may provide advice on insurance products that
include, but are not limited to, annuities, life insurance, long-term care, disability, property and casualty,
health insurance, Medicare, structured settlements, and viatical settlements. These products are separate
and distinct from the investment advisory services offered through Almega; Almega will refer clients to non-
affiliated independent licensed insurance agents for these products. Almega, and its supervised persons, are
prohibited from receiving a commission or other benefit if a current client purchases an insurance product.
If a client is referred to an independent insurance agent, Almega will review the recommendations of the
independent insurance agent before the insurance product is presented to the client; we recommend that all
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insurance contracts be reviewed by the client’s attorney and tax advisor before purchase. In no event is any
client obligated, contractually or otherwise, to use the services of any referred licensed insurance agent acting
in such a capacity or to purchase products through said agent. In no event is any client obligated,
contractually or otherwise, to use the services of any licensed insurance agent acting in such a capacity or to
purchase products through said agent.
Almega, including its management personnel and control persons, is not an insurance agency, brokerage, or
agent of an insurance company. It does not hold an active insurance license, does not receive compensation
from any insurance company, agency, or brokerage, and does not have an application pending for licensure or
registration to solicit any line of insurance business.
Solicitors (Promoters) may hold an insurance license and/or other professional licenses; Solicitors who hold an
active insurance license, or other professional license, may have a material conflict of interest because they
could have a financial incentive to recommend products or services outside the scope of Almega’s advisory
relationship.
Solicitors (Promoters), who are Investment Advisor Representatives and supervised employees of Almega
Wealth Management, are prohibited from selling any new product or service to individuals/entities once they
become clients of Almega Wealth Management. Any compensation a Solicitor receives after a person(s)
becomes a client of Almega Wealth Management is based on activity completed/contracted before the client’s
advisory engagement with Almega Wealth Management. Furthermore, no solicitor is permitted to offer or sell
any products or services to advisory clients of Almega Wealth Management.
Investment Advisor Representatives (IARs) are not permitted to solicit insurance products, or any product for
which they will receive a commission or financial incentive, to any, then current, client of Almega; any IAR who
solicits the purchase or sale of an insurance product for which they will receive a commission to a current
client of Almega’s is doing so outside of the supervision of Almega Wealth Management, on their own behalf,
and in violation of Almega’s compliance and ethics policies.
Additional details about our investment advisor representatives' material conflicts may be found in our
Brochure Supplement (“Supervised Persons”) and in Part 2B of Form ADV.
Almega does not, nor do its management personnel and control persons, have any material conflicts of
interest with any of the following: broker-dealers, investment companies, other investment advisors or
financial planners, futures commission merchants, commodity pool operators, commodity trading advisors,
banks, thrift institutions, lawyers or law firms, an insurance company or agency, pension consultant, real
estate broker or dealer, or any sponsor or syndicator of limited partnerships.
Almega Tax LLC was specifically formed to provide Almega Wealth Management’s clients with tax return
preparation services, tax planning, and IRS audit representation. Almega Tax LLC may charge hourly, fixed, or
retainer-based fees for its services, depending on the client's needs. Certain Private Wealth Management and
Family Wealth Management clients may have some/all of these fees waived based on the nature of their
relationship with Almega Wealth Management. Our Supervised Persons may have financial incentives to
recommend Almega Tax LLC to clients; additionally, a conflict of interest exists inasmuch as Almega Wealth
Management and Almega Tax LLC are under common ownership and management.
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Almega, as well as its management personnel and supervised persons, must always act in the best interest of
the client (strict Fiduciary Standard), and any person providing investment advice on behalf of Almega must
act in the best interests of the client and put the client’s interests ahead of their own interests.
If you have any questions regarding our financial industry activities, affiliations, or the actions or
recommendations of our investment advisor representatives, you are encouraged to contact Bryan Wisda, our
Chief Compliance Officer, by calling 480-770-4700 or emailing info@almega-wealth.com.
ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT
TRANSACTIONS, AND PERSONAL TRADING
Code of Ethics
Almega has adopted a Code of Ethics that sets forth high ethical standards of business and professional
conduct which we require our employees to follow. The Code of Ethics outlines proper conduct related to all
services provided to clients by Almega and our associated persons. It includes guidelines for compliance with
applicable laws and regulations governing our practice. We always aim to protect our client’s interests and
demonstrate our commitment to our fiduciary duties of honesty, good faith, and fair dealing.
Almega’s Code of Ethics states it, and its investment advisor representatives and employees, shall always:
• Act with integrity, competence, dignity, and ethically.
• Exercise its authority and responsibility for the benefit of its clients, to place the interests of its clients
first, and to refrain from having outside interests that conflict with the interests of its clients. Almega
must avoid any circumstances that might adversely affect or appear to affect its duty of complete
loyalty to its clients.
• Refrain from disclosing any non-public personal information about a client to any non-affiliated third
party unless the client expressly permits Almega to do so. All client information will otherwise be
treated as confidential.
• Maintain the physical security of non-public information, including information stored on computers.
This code of ethics is in place to guide the personal conduct of our team members. The Code of Ethics
describes our fiduciary duties and responsibilities to you. It sets forth our practice of supervising the personal
securities transactions of employees with prior or concurrent access to client trade information. A copy of
Almega’s Code of Ethics is available upon request.
Personal Securities Transactions and Interests
Almega and its supervised persons are exposed to conflicts of interest through its professional activities. The
Code of Ethics contains provisions designed to mitigate specific conflicts by governing the personal securities
transactions of its employees, officers, and directors. The Code of Ethics can only attempt to mitigate conflicts
of interest, the conflict still exists, and the Code of Ethics cannot remove a conflict of interest. In particular,
the Code of Ethics governs the conduct of certain "access persons" in circumstances where Almega or access
persons may desire to purchase or sell securities for their personal accounts that are identical to those
recommended by Almega to its clients. For these purposes, the Code of Ethics defines an "access" person as a
supervised person of Almega that (1) has access to nonpublic information regarding any clients' purchase or
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sale of securities, (2) has access to nonpublic information regarding the portfolio holdings of any fund the
adviser or its control affiliates manage or sponsor, or (3) is involved in making securities recommendations (or
has access to such recommendations) to clients that are nonpublic.
Access persons' trades must be executed in a manner consistent with the following principles:
• The interests of client accounts will always be placed first.
• Access persons must not take inappropriate advantage of their positions.
• All personal securities transactions will be conducted in such a manner as to avoid any conflict of
interest or any abuse of an individual's position of trust and responsibility.
• Other than 401k-type accounts, all investment accounts belonging to an access person, and/or their
immediate family, must be managed by Almega according to one of our model portfolios. An
exception may be granted if the spouse of an access person is employed by a broker-dealer or other
registered investment advisor that has similar rules for its employees.
• Participation of access persons in transactions in securities in a limited offering or private placement is
prohibited.
Access persons must submit quarterly reports regarding their securities transactions and newly opened
accounts, as well as annual reports regarding holdings and existing accounts. Almega monitors access
persons' personal trading activity at least quarterly to ensure compliance with internal control policies and
procedures and our Code of Ethics.
The Code of Ethics does not prevent or prohibit access persons from trading in securities that we may
recommend or invest client assets in but rather prescribes the governing principles relative to the same (see
above). As such, it is possible that (1) Almega or its access persons could recommend to clients, or buy or sell
for client accounts, securities in which one or more access persons (including Almega) have a material financial
interest, (2) access persons (including Almega) could invest in the same securities (or related securities) that
we recommend to clients, or (3) Almega and its access persons could recommend securities to clients, or buy
or sell securities for client accounts, at or about the same time that one or more access persons (including
Almega) buys or sells the same securities for its own account. This presents a conflict in that the access
person might seek to benefit themselves from this type of trading activity in the same securities, either by
trading for personal accounts in advance of client trading activity or otherwise. All such activity must be in
strict adherence with our Code of Ethics and must fundamentally place the client's interests first. Moreover,
our policy is that neither Almega nor its associated persons will have priority over a client's account(s) in the
purchase or sale of securities.
Neither Almega nor its associated persons have any material financial interest in client transactions beyond
the provision of investment advisory services or other services as disclosed in this Brochure. Additionally,
neither Almega nor its management personnel has any material conflicts of interest with any broker-dealer,
municipal securities dealer, government securities dealer or broker, investment company, or other pooled
investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private
investment company or “hedge fund,” and offshore fund), other investment adviser or financial planner,
futures commission merchant, commodity pool operator, or commodity trading advisor, banking or thrift
institution, accountant or accounting firm, lawyer or law firm, insurance company or agency, pension
consultant, real estate broker or dealer, or sponsor or syndicator of limited partnerships.
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Clients or prospective clients may obtain a copy of our Code of Ethics by contacting us at the e-mail or phone
number listed on the cover page of this Brochure.
Almega’s policies and procedures attempt to mitigate conflicts of interest. However, conflicts of interest
discussed here and in other sections of this brochure still exist and cannot be removed or eliminated.
Principal Trading
Almega does not engage in principal trading (i.e., the practice of selling individual securities to advisory clients
from our inventory or buying stocks from advisory clients into our inventory).
Agency Cross-Transactions
Almega may engage in agency cross-transactions. An agency cross transaction occurs when Almega, through
the clients’ custodian, sells a security for one client while simultaneously purchasing the security for another
client. This practice is used infrequently and only for securities that are thinly traded or there is no market for.
Almega will only affect agency cross transactions in publicly traded securities (private placements and other
illiquid investments are prohibited). The client’s custodian will determine the pricing for these trades; the
custodian may charge a fee/markup/commission for such a transaction. Before any agency cross-transaction,
both clients involved must provide written consent in advance; separate written consent is required with each
principal trade or agency cross-trade – blanket authorization is strictly prohibited. Written consent for the
agency cross-transaction must include the agreed pricing for the security so both parties are fully aware of the
pricing for the transaction. Almega Wealth Management prohibits agency cross-transactions involving its
principals, employees, or employee-related accounts.
Timing of Securities Purchases or Sales
We may combine orders to purchase securities for Almega, its associated persons and/or their families, with a
client's order to purchase securities ("block trading"). Please refer to Item 12 for more information on block
trading. A conflict of interest exists in these events because we could trade ahead of clients and receive more
favorable prices (for Almega, its associated persons and/or their families) than the client will receive. Almega
will make reasonable attempts to trade securities in client accounts at or before trading the securities in
Almega accounts or accounts of associated persons and/or their families. Trades executed the same day will
likely be subject to an average pricing calculation. Moreover, our policy is that neither Almega, nor its
associated persons, will have priority over a client's account(s) in the purchase or sale of securities.
Mutual funds are priced at the end of each business day the financial markets are open. Therefore, the
timing of purchases and sales of mutual fund shares does not introduce a potential conflict of interest.
ITEM 12 – BROKERAGE PRACTICES
Selection of Custodian
You may be permitted to direct us to utilize your desired brokers. However, if such brokers are used, we may
not have access to certain mutual funds and other investments available only to institutional investors or
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approved investment advisors. Also, commissions or transaction fees to buy or sell securities may be higher
than the fees we negotiated with our preferred brokers.
We have negotiated fees with the custodians we recommend and have selected these custodians for their
generally low fees. Also, we prefer to recommend custodians with significant size and financial resources for
the enhanced safety of your assets. For these reasons, the lowest-cost custodian may not be recommended.
As a fiduciary, we endeavor to always act in your best interests.
For our wealth management clients, our desire is that you maintain much of your assets in accounts at Charles
Schwab. Charles Schwab Institutional, and/or other custodians, may be used in part due to certain benefits to
our firm (i.e., the availability of some products and services at no cost to us or at reduced cost). This may
create a potential conflict of interest (please see Almega’s Benefits Provided by Custodians below).
We understand our duty for best execution and consider all factors in making recommendations to you. These
custodial services may be useful in servicing all our clients and may not be used in connection with any
particular account that may have paid compensation to the firm providing such services. While we may not
always obtain the lowest commission rate, we believe the rate is reasonable in relation to the value of the
brokerage and research services provided.
Benefits Provided by Custodians
The custodians for the assets of Almega clients assist in the management of client accounts in the following
ways:
• We receive duplicate client confirmations.
• We receive duplicate client statements.
• We have access to a trading desk that exclusively serves clients of investment advisory firms.
• We have access to the investment advisor portion of their websites, which includes practice
management articles, compliance updates, and other financial-planning-related information and
research materials.
• We have access to other vendors (such as insurance or compliance providers or providers of research
or other materials) on a discounted fee basis through discounts arranged by the custodians.
• We have access to an electronic communication network for client order entry and access to client
account information, which may otherwise assist us with our back-office functions, including record-
keeping and client reporting.
• We are sometimes invited to conferences at which advisors and employees of our firm may attend
(with no registration fees) and receive education on issues such as practice management, marketing,
investment theory, financial planning, business succession, regulatory compliance, and information
technology.
• We have access to software programs not available to the public, such as ThinkPipes and iRebal, which
help us manage clients’ accounts.
• We may participate in client referral or solicitor programs offered by custodians (see Item 14 – Client
Referrals and Other Compensation).
• Participation in the custodians’ programs also provides access to certain mutual funds, which generally
require significantly higher minimum initial investments or are generally available only to institutional
investors, such as the mutual funds of Dimensional Funds Advisors (DFA).
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Benefits received through participation in a custodian’s program may depend upon the number of
transactions directed to or the amount of assets placed with the custodian.
Generally, many of these services may be utilized to service all or a substantial number of our clients’
accounts. Educational, research, or other services provided by our custodians, as well as mutual fund
companies, may benefit all our clients or only some clients.
Order Aggregation
Almega 's advice to certain clients and the action of Almega for those and other clients are frequently
premised not only on the merits of a particular investment but also on the suitability of that investment for
the particular client in light of his/her applicable investment objective, guidelines, risk tolerance, and
circumstances. Thus, any action of Almega concerning a particular investment may, for a specific client, differ
or be opposed to the recommendation, advice, or actions of Almega to or on behalf of other clients. Almega
acts according to our duty to seek the best price and execution and will not continue any arrangements if we
determine that such arrangements are no longer in the best interest of our client(s).
As Almega may be managing accounts with similar investment objectives, Almega may aggregate orders for
securities for such accounts. In this event, allocation of the securities so purchased or sold, as well as
expenses incurred in the transaction, is made by Almega in the manner it considers to be the most equitable
and consistent with its fiduciary obligations to such accounts. Such aggregate orders may include transactions
for accounts for employees or affiliates of Almega.
Almega’s allocation procedures seek to allocate investment opportunities among clients in the fairest possible
way, considering clients' best interests. Almega will follow procedures to ensure that allocations do not
involve a practice of favoring or discriminating against any client or group of clients. Account performance is
never a factor in trade allocations.
Almega will aggregate, i.e., "block," trades where possible and when advantageous to our client(s). We must
reasonably believe that the order aggregation will benefit and enable us to seek best execution for each client
participating in the aggregated order. This requires a good faith judgment when the order is placed for
execution. It does not mean that the determination made before the transaction must always prove to have
been correct in the light of a "20-20 hindsight" perspective. Best execution includes the duty to seek the best
quality of execution, as well as the best net price. Block trading may allow us to execute equity trades in a
timelier, more equitable manner, and at an average share price.
Almega will block trades among clients whose accounts can be traded at a given broker-dealer. Blocking of
trades permits the trading of aggregate blocks of securities composed of assets from multiple client accounts,
as long as transaction costs are shared equally and on a pro-rata basis between all accounts included in the
block. Subsequent orders for the same security entered during the same trading day may be aggregated with
any previously unfilled orders. Subsequent orders may also be aggregated with filled orders if the market
price for the security has not materially changed and the aggregation does not cause any unintended
exposure. All clients participating in each aggregated order will generally receive the average price and,
subject to minimum ticket charges and possible step-outs, pay a pro-rata portion of commissions, provided
that an adjustment may be appropriate in some circumstances.
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Prior to entry of an aggregated order, each client account participating is identified along with the proposed
allocation of the order. If the order cannot be executed in full at the same price or time, the securities actually
purchased or sold by the close of each business day must be allocated pro rata among the participating client
accounts in accordance with the initial order ticket or other written statement of allocation. However,
adjustments to this pro rata allocation may be made to participating client accounts in accordance with the
initial order ticket or other written statement of allocation. Furthermore, adjustments to this pro rata
allocation may be made to avoid having odd amounts of shares held in any client account or to avoid excessive
ticket charges in smaller accounts. Our client account records separately reflect, for each account in which the
aggregated transaction occurred, the securities which are held by, and bought and sold for, that account.
Funds and securities for aggregated orders are clearly identified in our records and to the broker-dealers or
other intermediaries handling the transactions by the appropriate account numbers for each participating
client.
To minimize performance dispersion, "strategy" trades should be aggregated and average-priced. However,
when a trade is to be executed for an individual account, and the trade is not in the best interests of other
accounts, then the trade will only be performed for that account. This is true even if Almega believes that a
larger block trade would lead to the best overall price for the security being transacted.
All allocations will be completed prior to settlement. If an aggregated order is only "partially filled," the
allocation will be made in the best interests of all the clients in the order, considering all relevant factors
including, but not limited to, the size of each client's allocation, clients' liquidity needs, and previous
allocations. In most cases, accounts will get a pro forma allocation based on the initial allocation. This policy
also applies if an order is "over-filled."
Transactions for any client account may not be aggregated for execution if the client prohibits the practice.
To the best of our knowledge, Altruist does not provide order aggregation services.
Directed Brokerage
Clients may direct Almega to use a particular broker for custodial or transaction services on behalf of their
portfolio. In directed brokerage arrangements, the client is responsible for negotiating the commission rates
and other fees to be paid to the broker. Accordingly, a client who directs brokerage should consider whether
such designation may result in certain costs or disadvantages to the client, either because the client may pay
higher commissions or obtain less favorable execution or the designation limits the investment options
available to the client.
Almega's arrangements with the Custodians are designed to maximize efficiency and be cost-effective. By
directing brokerage arrangements, the client acknowledges that these economies of scale and levels of
efficiency are generally compromised when alternative brokers are used. While every effort is made to treat
clients fairly over time, the fact that a client chooses to use the brokerage and/or custodial services of these
alternative service providers may result in a certain degree of delay in executing trades for their account(s)
and otherwise adversely affect the management of their account(s).
Trading Away
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Client accounts may be established to be "prime broker" eligible so that, if and when the need arises, we may
effect securities transactions from those accounts at broker-dealers other than with their then-current
custodian ("executing brokers"), such custodian will accept delivery or deliver the applicable security from/to
the executing brokers. The custodian broker may charge a "trade away" fee which is charged against the
client's account(s) for each "trade away" occurrence. Other custodians have their own policies concerning
prime broker accounts and trade-away fees. The fees or commissions charged by the prime broker are
determined by the prime broker and allocated to clients on a pro-rata basis.
Prime brokerage services are utilized to purchase or sell securities through a broker other than the client’s
custodian. This typically happens when the contra broker offers a security that is otherwise unavailable
through the client’s custodian broker, such as an initial public offering (IPO) or, in the case of a thinly traded
fixed-income security. Consistent with its fiduciary responsibilities, Almega may also use prime brokerage
services to ensure that clients receive the best execution concerning the client's transactions when
appropriate to reduce commissions, improve purchase/sale pricing, and reduce transaction costs.
If the client is receiving discretionary advisory services, Almega, pursuant to the terms of its management
agreement with clients, will have discretionary authority to determine which securities are to be bought and
sold and the price of such securities to effect such transactions. Almega recognizes that the analysis of
execution quality involves several qualitative and quantitative factors. Almega will follow a process to ensure
that it seeks to obtain the most favorable execution under the prevailing circumstances when placing client
orders. These factors include, but are not limited, to the following:
• The financial strength, reputation, and stability of the broker-dealer;
• The efficiency with which the transaction is effected; the ability to effect prompt and reliable
executions at favorable prices (including the applicable dealer spread or commission, if any);
• The availability of the broker-dealer to stand ready to effect transactions of varying degrees of
difficulty in the future;
• The efficiency of error resolution, clearance, and settlement;
• Block trading and positioning capabilities;
• Performance measurements;
• Online access to computerized data regarding customer accounts;
• Availability, comprehensiveness, and frequency of brokerage and research services;
• Commission rate;
• The economic benefit to the clients; and
• Related matters involved in the receipt of brokerage services.
Consistent with its fiduciary responsibilities, Almega seeks to ensure that clients receive best execution
concerning the client's transactions by blocking client trades to reduce commissions and transaction costs. To
the best of Almega’s knowledge and due diligence inquiries, Charles Schwab Institutional and Altruist provide
high-quality execution, and clients will pay competitive rates for such execution. Based upon its own
knowledge of the securities industry, Almega believes that Schwab and Altruist’s commission rates are
competitive within the securities industry. Lower commissions or better execution may be able to be achieved
elsewhere.
Trade Errors
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When Almega causes a trade error, it takes prompt action to resolve the error to return the client's account to
the position that it would have been if there had been no error. Almega pays to correct the error and
reimburses a client for any loss resulting from the error. Clients do not retain any gains resulting from the
correction of a trade error. At the end of each day, any net profits from trade corrections are swept to a
specially designated account by the custodian and subsequently distributed to charity.
Brokerage for Client Referrals
Almega does not receive client referrals from broker-dealers in exchange for directed trading or prime
brokerage services.
ITEM 13 – REVIEW OF ACCOUNTS
Timing and Nature of Account Reviews
Reviews are undertaken to ascertain if the agreed-upon percentages invested in any asset class, or specific
investment, have strayed beyond their target minimums or maximums, if client risk tolerances/parameters
have changed, and for purposes of meeting client cash flow needs.
Reviews are performed at least once annually. Reviews may also occur upon request, as necessary when
determined by Almega, when assets are added or withdrawn from your accounts, or upon substantial asset
class decline or appreciation. All accounts are internally reviewed at least annually by management personnel.
Rebalancing Reviews
If one or more asset class, or specific investment, target allocation percentages change by a predetermined
amount according to the client’s written Investment Policy Statement (usually plus or minus 20%), we will
consider rebalancing the portfolio back to target (policy) percentages. We may determine not to rebalance
the asset class or specific investment for various reasons, such as avoiding short-term capital gains, deferring
the realization of long-term capital gains, and minimizing transaction costs.
Almega will generally rebalance client accounts opportunistically, when Almega determines, based on our
research and the research of others, rebalancing a client’s account is in their best interest. Alternatively, if
allowed by the client’s written Investment Policy Statement, Almega may, based on our research and the
research of others, overweight or underweight any asset class or individual securities when we determine it is
in the client's best interest. Almega may also rebalance client accounts systematically (i.e., quarterly) based
on the client’s written Investment Policy Statement.
Normally when we rebalance portfolios, we will purchase additional shares in those investments you currently
own, unless for such valid reason as we determine (avoiding wash sale rules, fund closing, etc.) a substitute
investment is more appropriate. We may also buy or sell shares for tax purposes, including realizing losses to
offset realized gains and/or taxable income (“tax loss harvesting”).
Regular Portfolio Reports
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We provide all clients written quarterly reports of their investment portfolio, including an inventory of the
investments upon which advice is provided to you. Such reports may also include a review of their portfolio.
Clients may also access these reports via our secure client web portal. Mid-cycle portfolio reports are
available upon request by the client.
Monthly or quarterly statements from account custodians are sent directly to the client. These statements
reflect the assets in the custodian’s custody, together with confirmations of each transaction executed in the
account(s) if desired by the client. For most custodians, clients may elect to receive these statements
electronically rather than via U.S. mail.
Clients are strongly encouraged to review the monthly or quarterly statements they receive from custodians.
We also encourage clients to compare the account reports received from us with those received directly from
their custodians. Should a client detect any unauthorized trading in an account, or unauthorized transfers of
cash or securities, they are asked to contact our Chief Compliance Officer, Bryan Wisda, at (480) 770-4700.
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION
Economic Benefits to Almega for Investment Advice
Other than the fees paid by you directly to Almega Wealth Management, Almega does NOT receive economic
benefits for providing investment advice to you from any person or entity.
Referrals from Almega
Almega does not accept referral fees or any form of compensation, commission, or other financial incentives
from other professionals when we refer a prospect or client to them.
Referrals from Other Persons or Entities
Almega and its Investment Advisor Representatives are fortunate to receive client referrals for which no
compensation or benefit is paid. Referrals of this nature come from current clients, past clients, attorneys,
accountants, employees, personal friends of employees, custodians, mutual fund companies, associations, and
other similar sources.
We may also compensate Solicitors (see next paragraph) for client referrals based on fully disclosed and
transparent agreements.
Solicitors
Almega may engage Solicitors (Promoters) to provide client referrals to Almega Wealth Management. If a
client is referred to us by a Solicitor, this practice is disclosed to the client in writing by the Solicitor. Almega
pays the solicitor out of its own funds. Specifically, Almega pays the solicitor a portion of the advisory fees
earned for managing the assets of the client who was referred to Almega by the Solicitor. The use of Solicitors
is strictly regulated under applicable federal and state laws. Almega’s policy is to fully comply with the
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requirements of Rule 206(4)-3, under the Investment Advisors Act of 1940, as amended, and similar rules
applicable in the State of Arizona, the State of North Carolina, or any other state in which Almega conducts
investment advisory business.
Solicitors are not authorized to provide investment advice on behalf of Almega, to bind Almega to any
agreement, or to make representations about Almega other than as expressly authorized in writing. Almega
Wealth Management does not control and is not responsible for any separate services offered independently
by a solicitor. Solicitors are required to immediately forward any/all client communications to Almega Wealth
Management; communications between a client and a solicitor are not binding on Almega until confirmed by
an Almega Wealth Management employee.
Each client an independent solicitor refers to Almega is made aware of the relationship between Almega and
the solicitor by means of a separate written “Solicitor’s Disclosure Statement” when the client’s account is
opened. The name of the solicitor and the basis of the compensation to the solicitor are detailed in the
Solicitor’s Disclosure Statement.
We will never charge any client referred to Almega by a solicitor any fees or costs higher than our standard fee
schedule offered to clients as published in Item 5 – Fees and Compensation.
Zoe Financial
As of the date of this filing, Almega has terminated its relationship with Zoe Financial (CRD#285158).
Almega received client referrals from Zoe Financial, Inc. (Zoe) through its participation in the Zoe Advisor
Network (ZAN). Zoe is independent of and unaffiliated with Almega, and there is no employment relationship
between us. Zoe established the Zoe Advisor Network to refer individuals and other investors seeking
fiduciary personal investment management services or financial planning services to independent investment
advisors. Zoe does not supervise Almega and has no responsibility for Almega’s management of client
portfolios or Almega’s other advice or services. We pay Zoe an ongoing fee for each client referral it received
while participating in the program. This fee is usually a percentage of the advisory fee that the client pays to
the Advisor (“Solicitation Fee”), typically 0.35% of assets under management. Almega does not charge clients
referred through Zoe any fees or costs higher than the standard fee schedule offered to its clients. For
information regarding additional or other fees paid directly or indirectly to Zoe Financial Inc, please refer to
the Zoe Financial Disclosure and Acknowledgement Form.
David Ramsey
Almega receives client referrals from the Dave Ramsey organization through its participation in the Ramsey
SmartVestor Pro and Ramsey Trusted Pro programs. The Dave Ramsey organization is independent of and
unaffiliated with Almega, and there is no employment relationship between us. Dave Ramsey established the
Ramsey SmartVestor Pro and Ramsey Trusted Pro to refer individuals and other investors seeking fiduciary
personal investment management services or financial planning services to independent investment advisors.
The David Ramsey organization does not supervise Almega and has no responsibility for Almega’s
management of client portfolios or Almega’s other advice or services. We pay the Ramsey Organization a
fixed monthly fee regardless of how many referrals we receive for participating in the program. Almega will
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not charge clients referred by the Ramsey organization any fees or costs higher than the standard fee schedule
offered to its clients.
Investment Advisor Representatives (IARs)
In certain states, natural persons soliciting new client relationships for Almega Wealth Management are
required to be registered as an Investment Advisor Representative (IAR). As such, the relationship Almega has
with each IAR is unique. Almega prefers that each IAR soliciting client referrals for Almega Wealth
Management be a supervised person subject to our compliance rules and regulations, regardless of whether
the solicitor is required to be registered as an IAR. We may compensate solicitors pursuant to our agreements
with them, typically less than 0.50% of assets under management. Almega may or may not establish an
employment relationship with Solicitors who are natural persons based on the laws of the state in which the
Solicitor resides, and/or in the best interest of Almega Wealth Management. Almega will not charge clients
obtained through any Solicitor, including those who are registered IARs with Almega, any fees or costs higher
than its standard fee schedule offered to clients.
Please note, an IAR soliciting new client relationships for Almega (Solicitor) may have material conflicts of
interest with both Almega and the client(s) being introduced to Almega. If such a conflict exists, Almega will
promptly disclose the existence and nature of the conflict to the client; these conflicts of interest will also be
disclosed in our Form ADV Part 2B – Supervised Persons. Under no circumstances may Almega receive any
compensation or other incentives from the activities of any IAR/Solicitor other than receipt of the client
referral. Additionally, Solicitors are strictly prohibited from owning shares, partnership interests, phantom
stock, or profit interests in Almega Wealth Management LLC, Almega Tax LLC, Wisda Family Management Inc.,
or any other entity related to Almega Wealth Management.
Almega will NOT refer any client to a Solicitor if a material conflict of interest exists.
Examples of Almega Solicitors who may have material conflicts of interest with Almega and/or our clients:
• Real Estate Agents
•
Insurance Agents
• Registered Representatives
• Business Brokers
• Registered Investment Advisors
Currently, the following Investment Advisor Representatives (IARs) are supervised by Almega Wealth
Management as Solicitors for Almega Wealth Management:
• Daniel Scott Braddock
o As of March 1, 2026, Mr. Braddock has communicated to Almega his intent to establish Scott
Braddock Financial LLC as a Registered Investment Advisor under the laws of the State of North
Carolina. Subsequently, he will remain an IAR with Almega per North Carolina law, but will
cease being compensated and supervised as an employee of Almega.
For information regarding our agreement with any Solicitor, please contact our Chief Compliance Officer,
Bryan Wisda, by calling 480-770-4700 or emailing info@almega-wealth.com.
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ITEM 15 – CUSTODY
Almega Wealth Management LLC does not custody client assets.
We have previously disclosed in Item 5 (Fees and Compensation) that we may directly debit advisory and
other fees from client accounts. As part of this billing process, the independent, qualified custodian of the
client’s account(s) (Schwab or Altruist) is advised of the amount of the advisory or other fee to be deducted
from the client’s account(s). The clients will receive account statements at least quarterly from the custodian
holding the account(s). These statements will show all transactions within the account during that reporting
period, including the amount of advisory or other fees debited from the client’s account(s). Clients will also
receive a quarterly report from us that details the amount invoiced and/or debited from their account(s).
Because the custodian does not calculate the amount of the fees to be deducted, it is essential for clients to
carefully review their account statements to verify the accuracy of the fee calculation, among other things. A
client should contact us directly if he/she believes there is an error or has a question regarding an account
statement. As a result of the foregoing, we are “deemed” to have “custody” under applicable law when (1) we
deduct fees directly from clients’ account(s), and (2) clients have a third-party standing letter of authorization
(SLOA) with Almega directing us to make payments or transfers to authorized third parties, such as for
charitable donations. As a matter of policy, Almega does not accept third-party SLOAs; clients are instead
directed to contact their custodian to make alternate arrangements.
Almega may not have client login or password information for any ERISA account, insurance contract, certain
accounts at other financial institutions, and/or certain client accounts where a non-Almega advisor is
responsible for the accounts. It is our customary practice to establish login credentials identifiable to Almega
or our Investment Advisor Representatives instead and/or through a program like Ponterra as described in
Item 4 under the sub-section, Held Away Assets. As such, we are enabled to make investment decisions within
these accounts and/or determine the value of the assets in these accounts for the purpose of including these
values in Almega’s financial planning software to provide comprehensive financial planning for our clients. As
a result of these circumstances, under the law, we may be “deemed” to have “custody” of the assets in these
accounts.
From time to time, Almega may receive checks and security certificates on behalf of clients, and with authority
from the clients, we deposit the checks and certificates into the client’s accounts. Under the law, we are
“deemed” to have “custody” of these checks and certificates.
As to the accounts for which Almega has been “deemed” to have “custody,” we adhere to the SEC’s and
applicable state’s rules and guidance regarding custody.
Account Statements
Monthly or quarterly statements from account custodians are sent directly to the client. These statements
reflect the assets in the custodian’s custody, together with confirmations of each transaction executed in the
account(s) if desired by the client. For most custodians, clients may elect to receive these statements
electronically rather than via U.S. mail.
Clients are strongly encouraged to review the monthly or quarterly statements they receive from custodians.
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We also encourage clients to compare our account reports with those received directly from Charles Schwab
Institutional, Altruist, or other custodians. Should a client detect any unauthorized trading in an account, or
unauthorized transfers of cash or securities, they are asked to contact our Chief Compliance Officer, Bryan
Wisda, at (480) 770-4700 or by emailing info@almega-wealth.com.
ITEM 16 – INVESTMENT DISCRETION
As described above under Item 4 - Advisory Business, Almega typically manages portfolios on a discretionary
basis. This means that after an Investment Plan is developed for the client’s investment portfolio, Almega will
execute that plan without specific consent from the client for each transaction. For discretionary accounts, a
Limited Power of Attorney ("LPOA") is executed by the client, giving Almega the authority to carry out various
activities in the account, generally including the following: trade execution; the ability to request distributions
on behalf of the client; and, the withdrawal of advisory fees directly from the account. Almega then directs
the investment of the client's portfolio using its discretionary authority. The client may limit the terms of the
LPOA to the extent consistent with the client's investment advisory agreement with Almega and the
requirements of the client's custodian. In certain circumstances, and at our discretion, however, we may
consult you in advance of certain activities (such as those pertaining to any aspect of “tax management”). The
discretionary relationship is further described in the agreement between Almega and the client.
Almega Wealth Management requires each client to have a written Investment Policy Statement for each
portfolio prior to accepting Discretionary Authority. This means that even though the client has opened an
account(s) with our preferred custodian and executed an LPOA we will not take any discretionary action in the
account(s) until an Investment Policy Statement is signed by the client.
At the client’s request, or as the account type requires, we will manage portfolios on a non-discretionary basis.
This means that after an Investment Plan is developed for the client’s investment portfolio, Almega will
execute that plan only with specific approval from the client for each transaction.
ITEM 17 – VOTING CLIENT SECURITIES AND CLASS-ACTION LAWSUITS
Regardless of whether we have discretion over a client's account(s), we will not vote proxies on behalf of any
client. We will instruct the qualified, independent custodian to forward all proxy materials to the client to
review and make his or her own informed decision on how to vote. If we receive the proxy material, we will
forward them directly to the client by mail or electronic mail (if the client has authorized electronic
communication). Almega will not provide guidance on how to vote a proxy.
Almega Wealth Management has entered into an agreement with the American Endowment Foundation to
provide investment consulting services for clients’ donor-advised funds (DAFs). This agreement requires
Almega Wealth Management to vote proxies on behalf of the American Endowment Foundation. Without
specific instructions from the American Endowment Foundation, Almega Wealth Management will vote the
proxies in accordance with the “board recommendations” provided with the proxy voting materials.
Sometimes securities held in clients' accounts will become the subject of a class action lawsuit. We have
engaged a third-party service provider, Chicago Clearing Corporation ("CCC"), to provide a comprehensive
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review of our clients’ possible claims to a settlement throughout the class action lawsuit process. CCC actively
seeks out any open and eligible class action lawsuits. Additionally, CCC files, monitors, and expedites the
distribution of settlement proceeds in compliance with SEC guidelines on behalf of our clients. CCC's filing fee
is contingent upon the successful completion and distribution of the settlement proceeds from a class action
lawsuit. In recognition of CCC’s services, CCC receives 15% of our client’s share of the settlement distribution.
We do not receive any fees or remuneration in connection with this service, nor do we receive any payments
from the third-party provider(s) related to this service. When we receive written or electronic notice of a class
action lawsuit, settlement, or verdict affecting securities owned by clients, we will work to assist clients and
CCC in the gathering of required information and submission of claims. It may be necessary to share client
information with CCC in connection with this service. Clients are automatically included in this service but
may Opt-Out by providing written notice to us. If a client Opts-Out, neither Almega nor CCC will monitor class
action filings for that client.
ITEM 18 – FINANCIAL INFORMATION
Under no circumstances do we require or solicit payment of fees in excess of $500 more than six months in
advance of services rendered.
Almega Wealth Management does not have any financial issues that would impair its ability to provide
services to clients, and Almega has not been the subject of a bankruptcy petition at any time. We have no
additional financial circumstances to report.
ITEM 19 - REQUIREMENTS FOR STATE-REGISTERED ADVISORS
Principal Executive Officers & Management Persons
Bryan Craig Wisda
CERTIFIED FINANCIAL PLANNER™
NAPFA-Registered Financial Advisor
Formal Education After High School:
University of Arizona, 1996-2000, Philosophy
Boston University, 2006, Financial Planning
Prior Career Background: Maricopa County Sheriff’s Office (2014-2021), Almega Life Solutions (2015-2021),
Summit Wealth Management of Arizona LLC (2012-2015), Summit Wealth Management, Inc. (2007-2012), UBS
Financial Services fka PaineWebber (2001-2007), Farmers Insurance (2000-2001), Bank of America (1995-
2000).
Outside Business Activities: Mr. Wisda is a professional musician and the owner of Zezz Music Ltd. LLC, which
produces the ADHD Lullaby™ series of albums, and other musical works, to help children and adults with
ADHD sleep. He spends less than 2 hours per week on this activity and not during regular business hours.
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Mr. Wisda was elected to the National Association of Personal Financial Planners Western Regional Board. He
also serves on its national membership committee. His term runs until September 2027. He is expected to
attend board meetings and various trainings. This is a non-investment-related business. He expects to spend
less than 2-4 hours per month on average on this activity, which may coincide with Almega Wealth
Management’s normal business hours.
Mr. Wisda owns a controlling interest in Almega Tax LLC. During “tax season,” he expects to spend 8-12 hours
per week on tax preparation-related activities, which may coincide with Almega Wealth Management’s
normal business hours. Outside of “tax season,” he expects to spend 2-4 hours per week on tax preparation-
related activities, which may coincide with Almega Wealth Management’s normal business hours.
Mr. Wisda is the President of Wisda Family Management Inc., the management company for Mr. Wisda’s
personal assets, including Almega Wealth Management and Almega Tax LLC. He expects to spend
approximately 1 hour per week on this activity, not during Almega Wealth Management’s normal business
hours.
Mr. Wisda is not actively engaged in any outside securities-related business activities.
Disciplinary Information: In May 2025, Almega Wealth Management and Mr. Wisda signed a consent decree
and was fined $4,000 for accepting a 6th client in the State of Indiana before registering in the state in violation
of the state’s De Minimis rules. This was a minor administrative violation. For further information, see Item 9
– Disciplinary Information.
Almega Wealth Management LLC: Almega Wealth Management LLC is a manager-managed LLC. The manager
is Wisda Family Management Inc.
Performance-Based Fees: Almega does not charge performance-based fees, nor are any supervised persons
compensated with performance-based fees.
Outside Relationships & Conflicts of Interest: Other than those relationships disclosed previously with Charles
Schwab Institutional, neither Almega Wealth Management LLC, its managers, nor its supervised persons have
any relationships or arrangements with any issuers of securities.
We have disclosed any and all material conflicts of interest of Almega Wealth Management LLC, its investment
advisor representatives, and any of its employees which could be reasonably expected to impair the rendering
of unbiased and objective advice.
PRIVACY NOTICE: Almega has adopted policies and procedures designed to keep client information private
and secure. We do not disclose any nonpublic personal information about our clients or former clients to any
nonaffiliated third parties except at a client's request or as permitted or required by law. While servicing a
client's account, we may share some information with our service providers, such as transfer agents,
custodians, broker-dealers, accountants, and lawyers. We restrict internal access to nonpublic personal
information about the client to those persons who need access to that information to provide services to the
client and to perform administrative functions. For the full text of our Privacy Policy, please contact our Chief
Compliance Officer.
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BROCHURE SUPPLEMENT (“SUPERVISED PERSONS”)
This supplement contains the required information on any supervised persons at Almega who:
• Provide investment advice and have direct contact with clients
• Have discretionary authority over client accounts
General Education, Experience, and Business Standards
We require that Almega’s investment advisor representatives have a combination of education and work
experience that demonstrates their aptitude for investment management and advanced financial planning.
Professional Certifications
CERTIFIED FINANCIAL PLANNER™ (CFP®):
Certified Financial Planners are licensed by the Certified Financial Planner Board of Standards, Inc. to use the
CFP® mark. CFP® certification requirements are as follows:
• Complete an advanced college-level course of study addressing the financial planning subject areas
that the CFP Board’s studies have determined necessary for the competent and professional delivery of
financial planning services.
• Those certified in 2007 or later, must attain a Bachelor’s Degree from a regionally accredited United
States college or university (or its equivalent from a foreign university) in any discipline.
• Pass the comprehensive CFP Certification Examination; the examination includes case studies and
client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply
one’s knowledge of financial planning to real-world circumstances.
• Complete at least three years of full-time financial planning-related experience (or the equivalent,
measured as 2,000 hours per year).
• Agree to be bound by the CFP Board’s Standards of Professional Conduct, a set of documents outlining
the ethical and practice standards for CFP professionals.
• Complete 30 continuing education hours every two years, including two hours on the Code of Ethics
and other parts of the Standards of Professional Conduct, to maintain competence and keep up with
developments in the financial planning field.
• Renew an agreement to be bound by the Standards of Professional Conduct; the Standards
prominently require that CFP professionals provide financial planning services at a fiduciary standard of
care, which means CFP professionals must provide financial planning services in the best interest of
their clients.
IRS Enrolled Agent
The Enrolled Agent (EA) designation is a federal tax credential awarded by the Internal Revenue Service. The
designation relates to federal tax practice and does not, by itself, indicate special training or expertise in
investment management, securities analysis, or financial planning. EA certification requirements are as
follows:
• An Enrolled Agent is authorized to represent taxpayers before the IRS and may obtain the designation
either by passing a three-part IRS examination covering individual and business tax matters or through
qualifying prior IRS employment experience.
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• Enrolled Agents are subject to Treasury Department Circular 230 standards governing practice before
the IRS and must satisfy continuing education requirements to maintain the credential.
NAPFA-Registered Financial Advisor:
NAPFA-Registered Financial Advisor is a designation granted by the National Association of Personal Financial
Advisors (NAPFA). NAPFA-Registered Financial Advisor designation requirements are currently as follows:
• Be a Fee-only financial advisor and subject to a third-party ADV review.
• Have a Bachelor’s degree in any discipline from an accredited institution.
• Have a CFP® certification.
• Sign the NAPFA Fiduciary Oath
• Earn 60 continuing education credits every two years.
• Demonstrate the ability to take a comprehensive approach to financial planning by either submitting a
sample comprehensive financial plan or participating in a peer review dialogue with a third-party
Plan/Peer Reviewer.
BRYAN CRAIG WISDA, CFP® EA
President & Chief Compliance Officer
Bryan Craig Wisda, is a Financial Advisor with Almega Wealth Management. He also serves as the President
and Chief Compliance Officer of Almega Wealth Management LLC. He has been a CERTIFIED FINANCIAL
PLANNER™ since 2006 and has over 30 years of experience in financial services. Mr. Wisda is also a IRS
Enrolled Agent and NAPFA-REGISTERED FINANCIAL ADVISOR.
Mr. Wisda owns a controlling interest in Almega Tax LLC. During “tax season,” he expects to spend 8-12 hours
per week on tax preparation-related activities, which may coincide with Almega Wealth Management’s
normal business hours. Outside of “tax season,” he expects to spend 2-4 hours per week on tax preparation-
related activities, which may coincide with Almega Wealth Management’s normal business hours.
Mr. Wisda is a professional musician and the owner of Zezz Music Ltd. LLC, which produces the ADHD
Lullaby™ series of albums, and other musical works, to help children and adults with ADHD sleep. He spends
less than 2 hours per week on this activity and not during regular business hours.
Mr. Wisda was elected to the National Association of Personal Financial Planners Western Regional Board. He
also serves on its national membership committee. His term runs until September 2027. He is expected to
attend board meetings and various trainings. This is a non-investment-related business. He expects to spend
less than 2-4 hours per month on average on this activity, which may coincide with Almega Wealth
Management’s normal business hours.
Mr. Wisda is the President of Wisda Family Management Inc., the management company for Mr. Wisda’s
personal assets, including Almega Wealth Management and Almega Tax LLC. He expects to spend
approximately 1 hour per week on this activity, not during Almega Wealth Management’s normal business
hours.
Mr. Wisda is not actively engaged in any outside securities-related business activities.
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Mr. Wisda worked for Bank of America as a Teller (1995-2000), Farmers Insurance as an Agent (2000-2001),
UBS Financial Services (fka PaineWebber) as a Financial Advisor (2001-2007), Summit Wealth Management as
a Senior Financial Planner (2007-2012), and President of Summit Wealth Management of Arizona (2012-2015).
He was self-employed as an Insurance Agent from April 2015 to August 2021 while concurrently serving as a
Deputy Sheriff with the Maricopa County Sheriff's Office (2014-2021). Finally, as a Senior Investment Advisor
and Regional Director for Southport Capital (2021) before starting Almega Wealth Management (2021). He
studied Economic Philosophy at the University of Arizona (1996-2000) and Financial Planning at Boston
University (2005-2006); he completed additional coursework in adult education through Rio Salado College
(2010).
Mr. Wisda has never been the subject of a bankruptcy petition. Mr. Wisda has never had arbitration or civil
suit brought against him. In May 2025, he signed a consent decree and paid a $4,000 fine to the State of
Indiana for accepting a 6th client in the state, an administrative violation of the state’s De Minimis rules.
Additional information about Mr. Wisda can be obtained by contacting Mr. Wisda at the contact information
on the cover page of this firm brochure.
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DANIEL SCOTT BRADDOCK
Investment Advisor Representative
Daniel Scott Braddock is a Solicitor for Almega Wealth Management and is registered as an Investment Advisor
Representative with Almega Wealth Management pursuant to North Carolina securities regulation for
solicitors.
Since 2003, Mr. Braddock has owned Scott Braddock Financial, an independent insurance agency.
In total, Mr. Braddock has approximately twenty-three years of experience in financial services.
Mr. Braddock is not engaged in any other outside securities businesses.
Mr. Braddock has never been the subject of a bankruptcy petition. He has never had an arbitration claim or
civil suit brought against him. He had a regulatory claim brought against him by the State of North Carolina
prior to his affiliation with Almega Wealth Management. For further information, please see Item 3 –
Disciplinary History or Part 2B of Form ADV.
Daniel Scott Braddock, a supervised person, paid a fine of $8,500 and signed a Consent Decree with the State
of North Carolina regarding unregistered investment-related business activity from 2018 – 2021, prior to his
association with Almega Wealth Management.
Mr. Braddock has a material conflict of interest regarding the solicitation/sale of insurance products inasmuch
as he is a licensed insurance agent and may receive a commission from the sale of an insurance product.
Supervised Persons and Investment Advisor Representatives are prohibited from soliciting current Almega
Wealth Management clients for any product for which they will receive a financial incentive. Mr. Braddock is
prohibited from selling any new insurance or financial products to individuals/entities once they become a
client of Almega Wealth Management. Any insurance-related compensation Mr. Braddock receives after a
person(s) becomes a client of Almega Wealth Management is based on activity completed/contracted before
the client’s advisory engagement with Almega Wealth Management. For further information, see Item 10 –
Other Financial Industry Activities and Affiliations.
Additional information about Mr. Braddock can be obtained by contacting our Chief Compliance Officer, Bryan
Wisda, at 480-770-4700.
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Colin Frank Taylor
Investment Advisor Representative
Colin Frank Taylor is a Financial Advisor with Almega Wealth Management and is registered as an Investment
Advisor Representative.
Mr. Taylor worked for Elliott Davis as a Tax Intern (2010), Deloitte Touche as an Senior Consultant (2011-
2013), KPMG as a Senior Consultant (2014-2016), Northbound Executive Search as a Executive Recruiter
(2016-2018), Guardian Wealth Partners as an Investment Advisor Representative (2018-2024), and Raleigh
Capital Management as an Investment Advisor Representative (2024), prior joining Almega Wealth
Management as an Investment Advisor Representative (2024). He studied Accounting & Finance at the
University of North Carolina at Wilmington (2006-2010) and received a Master’s in Accounting from the
University of North Carolina at Wilmington (2010-2011).
Mr. Taylor is not engaged in any outside securities businesses, and is not engaged in any activity which
coincides with Almega Wealth Management’s normal business hours.
Mr. Taylor has never been the subject of a bankruptcy petition. Mr. Taylor has never had an arbitration, civil
suit, or regulatory administrative claim brought against him.
Additional information about Mr. Taylor can be obtained by contacting Bryan Wisda, our Chief Compliance
Officer, at 480-770-4700.
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Colin Joseph Bybee
Investment Advisor Representative
Colin Joseph Bybee is a Financial Advisor with Almega Wealth Management and is registered as an Investment
Advisor Representative.
Prior to joining Almega Wealth Management as an Investment Advisor Representative (2026), Mr. Bybee was
a Summer Intern for Almega Wealth Management (2025). He studied Finance, with an emphasis on Financial
Planning, at California Baptist University (2023-2026) and was undeclared at Ottawa University (2022-2023).
Mr. Bybee is not engaged in any outside securities businesses and is not engaged in any activity that coincides
with Almega Wealth Management’s normal business hours.
Mr. Bybee has never been the subject of a bankruptcy petition. Mr. Bybee has never had an arbitration, civil
suit, or regulatory administrative claim brought against him.
Additional information about Mr. Bybee can be obtained by contacting Bryan Wisda, our Chief Compliance
Officer, at 480-770-4700.
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Additional Brochure: ALMEGA WEALTH MANAGEMENT - FORM ADV PART 3 (2026-06-26)
View Document Text
Part 3 of Form ADV: Client Relationship Summary
June 26, 2026
Item 1 | Introduction
Almega Wealth Management LLC (“Almega”, “Firm”, “We”, “Our”) is an Investment Advisor, with registration pending with the Securities and
Exchange Commission (SEC), that provides advisory services for a fee rather than brokerage commissions. It is important for you, a retail investor,
to understand the differences between the services and fees of an investment advisor and a broker-dealer. Investor.gov/CRS offers free and simple
tools to research firms and financial professionals. It also provides educational materials about broker-dealers, investment advisors, and investing.
Item 2 | Relationships and Services
What investment services and advice can you provide me?
Almega Wealth Management offers services to high-net-worth and retail investors: Investment Management, Financial Planning, Retirement Plan
Services, and Tax Planning. We customize our services to our clients’ individual needs by determining their specific goals, objectives, risk tolerance,
time horizon, investment restrictions, and other factors that shape the financial advice they receive. We develop an investment risk profile with
you, which we use in our relationship with you to help you understand the potential risks and rewards associated with your investments; this risk
profile also helps guide us in the management of your investments. Almega regularly monitors investment accounts for, among other things,
allocations of investments that are outside our clients’ stated goals and objectives.
Almega Wealth Management typically receives discretionary authority from the client to select investments to be bought or sold during an advisory
relationship. This means we may place trades to purchase or sell securities on your behalf without seeking approval from you for each transaction.
We exercise investment discretion only in accordance with an Investment Policy Statement, based on the stated risk profile for the particular client
account. In limited circumstances, Almega also offers non-discretionary services, in which we obtain the client's prior authorization before
implementing investment recommendations.
As a condition for starting and maintaining an investment advisory relationship, Almega Wealth Management generally requires a minimum
portfolio size of $1,000,000 and a minimum investment advisory annual fee of $10,000. We, in our sole discretion, may waive our stated account
minimums. Typically, we waive this minimum based on the individual client’s circumstances, for family members of clients, and for clients referred
to us. These minimums may have the effect of making our services impractical for certain individuals.
Additional information about our services can be found in Form ADV Part 2A, Item 4 and Item 7.
You could consider asking us questions like the following:
• Given my financial situation, should I choose an investment advisory service? Why or why not?
• How will you choose investments to recommend to me?
• What is your relevant experience, including your licenses, education, and other qualifications? What do these qualifications mean?
Item 3 | Fees, Cost, Conflicts and Standard of Conduct
What fees will I pay?
Almega Wealth Management charges asset-based fees for its services. Our fee for wealth management services, including investment advisory, is
based on your total assets under management with our firm, not to exceed 1.1% annually (billed quarterly). The more assets there are in your
advisory account(s), the more you will pay in fees; our firm may therefore have an incentive to encourage you to increase the assets in your
account(s).
You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on
your investments over time. Please make sure you understand what fees and costs you are paying.
Additional information on fees and cost can be found in our Form ADV Part 2A, Item 5.
You could consider asking us questions like the following:
• Help me understand how these fees and costs might affect my investments. If I give you $10,000 to invest, how much will go to fees and
costs, and how much will be invested for me?
• What are your legal obligations to me when acting as my investment adviser?
• How else does your firm make money, and what conflicts of interest do you have?
When we act as your investment adviser, we have to act in your best interest and not put our interest ahead of yours. At the same time, the way
we make money creates some conflicts with your interests. You should understand and ask us about these conflicts because they can affect the
investment advice we provide you. Here are some examples to help you understand what this means:
• Generally, we are paid based on the assets in your account. We may recommend you add assets or funds to that account. Even though
that advice may be in your best interest, it is conflicted because the more money in your account, the more fees we would collect from
you.
• We receive client referrals from third parties to whom we pay referral fees. This is a conflict of interest because we have an incentive to
pay referral fees to encourage third parties to refer clients to us, whom they might otherwise not refer.
For additional information on conflicts, please refer to our Form ADV Part 2A, Item 4 and Item 10.
You could consider asking us questions like the following:
• How might your conflicts of interest affect me, and how will you address them?
How do your financial professionals make money?
Our advisors are primarily compensated based on the amount of assets under management that they personally manage.
Regardless of how our advisors are compensated, there is an inherent conflict of interest because our financial professionals have an incentive to
encourage you to increase your assets in your accounts, recommend our advisory services to you, and recommend you purchase investments that
result in additional compensation to them.
Item 4 | Disciplinary History
Do you or your financial professionals have legal or disciplinary history?
Yes. Please visit Investor.gov/CRS for a free and simple search tool to research Almega and our financial professionals.
For additional information about our Disciplinary History, please refer to our Form ADV Part 2A, Item 9, as well as Form ADV Part 2B.
You could consider asking us questions like the following:
•
As a financial professional, do you have any disciplinary history? For what type of conduct?
Item 5 | Additional Information
To find additional information about Almega, such as a full copy of the ADV Part 2, and to request a copy of the Customer Relationship
Summary, please go to https://almega-wealth.com and reach out via our contact form. If you would like to request up-to-date information or a
copy of the relationship summary, please call us at 480-770-4700 or email info@almega-wealth.com.
You may also find a copy of the most recent ADV Part 2 at https://adviserinfo.sec.gov/firm/summary/316840.
You could consider asking us questions like the following:
• Who is my primary contact person? Is he or she a representative of an investment advisor or a broker-dealer?
• Who can I talk to if I have concerns about how this person is treating me?”