ALTERI WEALTH LLC

ALTERI WEALTH LLC FORM ADV PART 2A BROCHURE Item 1 – Cover Page 4195 East Thousand Oaks Blvd., Suite 250 Westlake Village, California 91362 805-809-0400 www.alteriwealth.com telephone at This brochure provides information about the qualifications and business practices of Alteri Wealth LLC. If you have any questions regarding the contents of this brochure, please do not hesitate to contact our Chief (513) 977-8459 or by email at Compliance Officer, Roseann Higgins, by roseann.higgins@dinsmorecomplianceservices.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. information about Alteri Wealth LLC is available on Alteri Wealth LLC is a registered investment adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. Additional the SEC’s website at www.adviserinfo.sec.gov. March 12, 2025  Alteri Wealth Disclosure Brochure Item 2 – Material Changes Form ADV Part 2A requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser’s disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. There are no material changes to report for Alteri Wealth at this time. 2  Alteri Wealth Disclosure Brochure Item 3 - Table of Contents Item 1 – Cover Page ...................................................................................................................................... 1 Item 2 – Material Changes ............................................................................................................................ 2 Item 3 - Table of Contents ............................................................................................................................ 3 Item 4 - Advisory Business ........................................................................................................................... 5 A. Description of the Advisory Firm .................................................................................................... 5 B. Types of Advisory Services ............................................................................................................. 5 C. Client-Tailored Advisory Services .................................................................................................. 6 D. Information Received From Clients ................................................................................................. 6 E. Assets Under Management .............................................................................................................. 6 Item 5 - Fees and Compensation ................................................................................................................... 6 A. Investment Management Services ................................................................................................... 6 B. Payment of Fees ............................................................................................................................... 7 C. Clients Responsible for Fees Charged by Financial Institutions and External Money Managers ... 8 D. Prepayment of Fees .......................................................................................................................... 8 E. Outside Compensation for the Sale of Securities or Other Investment Products to Clients ............ 8 Item 6 - Performance-Based Fees and Side-by-Side Management ............................................................... 8 Item 7 - Types of Clients .............................................................................................................................. 9 Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss ...................................................... 9 A. Methods of Analysis and Risk of Loss ............................................................................................ 9 B. Material Risks Involved ................................................................................................................... 9 Item 9 – Disciplinary Information .............................................................................................................. 13 Item 10 – Other Financial Industry Activities and Affiliations .................................................................. 13 Item 11 – Code of Ethics, Participation or Interest in Client Transactions ................................................. 14 A. Description of Code of Ethics ........................................................................................................ 14 Item 12 – Brokerage Practices .................................................................................................................... 15 A. Factors Used to Select Custodians and/or Broker-Dealers ............................................................ 15 B. Trade Aggregation ......................................................................................................................... 18 Item 13 – Review of Accounts .................................................................................................................... 19 A. Periodic Reviews ........................................................................................................................... 19 B. Other Reviews and Triggering Factors .......................................................................................... 19 C. Regular Reports ............................................................................................................................. 19 Item 14 – Client Referrals and Other Compensation .................................................................................. 19 3  Alteri Wealth Disclosure Brochure A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients ............................ 19 B. Compensation to Non-Supervised Persons for Client Referrals .................................................... 19 Item 15 – Custody ....................................................................................................................................... 19 Item 16 – Investment Discretion ................................................................................................................. 20 Item 17 – Voting Client Securities .............................................................................................................. 20 Item 18 – Financial Information ................................................................................................................. 21 4  Alteri Wealth Disclosure Brochure Item 4 - Advisory Business A. Description of the Advisory Firm Alteri Wealth LLC (“Alteri” or the “Firm”) is a limited liability company organized in the State of Delaware. Alteri is an investment advisory firm registered with the United States Securities and Exchange Commission (“SEC”). Alteri is owned by Michelle Gruber and Alex Markowitz. B. Types of Advisory Services Alteri provides discretionary and non-discretionary investment management services to affluent individuals and families, including, business owners, athletes, physicians, entrepenuers, and entertainment industry executives, as well as entities, including, but not limited to, family offices, trusts, estates, private foundations, and qualified retirement plans. Financial planning services also are provided as part of the delivery of investment management services. Depending upon individual client requirements, the financial planning will include recommendations for retirement planning, educational planning, estate planning, tax planning and insurance needs and analysis. All investment advice provided is customized to each client’s investment objectives and financial needs. The information provided by the client, together with any other information relating to the client’s overall financial circumstances, will be used by Alteri to determine the appropriate portfolio asset allocation and investment strategy for the client. The securities utilized by Alteri for investment in client accounts mainly consist of individual equity securities, municipal and corporate bonds, but we will also invest in, exchange traded funds (ETFs), registered mutual funds, REITS, variable annuities, private funds/alternative investments, and closed-end funds, if we determine such investments fit within a client’s objectives and are in the best interest of our clients. Alteri may further recommend to clients that all or a portion of their investment portfolio be managed on a discretionary basis by one or more unaffiliated money managers or investment platforms (“External Managers”). The client may be required to enter into a separate agreement with the External Manager(s), which will set forth the terms and conditions of the client’s engagement of the External Manager. Alteri generally renders services to the client relative to the discretionary selection of External Managers. Alteri also assists in establishing the client’s investment objectives for the assets managed by External Managers, monitors and reviews the account performance and defines any restrictions on the account. Unless otherwise provided in the agreement with a client, the investment advisory fees charged by any designated External Managers are paid by Alteri and, therefore, are not in addition to the the annual advisory fee charged by Alteri. Investment Management Services to Retirement Plans Alteri offers discretionary and non-discretionary advisory services to qualified plans, including 401k plans. These services include, depending upon the needs of the plan client, recommending, or for discretionary clients selecting, investment options for plans to offer to participants, ongoing monitoring of a plan’s investment options, assisting plan fiduciaries in creating and/or updating the plan’s written investment 5  Alteri Wealth Disclosure Brochure policy statements, working with plan service providers, and providing general investment education to plan participants. Note for IRA and Retirement Plan Clients: When Alteri provides investment advice to you regarding your retirement plan account or individual retirement account, Alteri is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way Alteri makes money creates some conflicts with your interests, so Alteri operates under a special rule that requires Alteri to act in your best interest and not put Alteri’s interest ahead of yours. C. Client-Tailored Advisory Services Clients may impose reasonable restrictions on the management of their accounts if Alteri determines, in its sole discretion, that the conditions would not materially impact the performance of a management strategy or prove overly burdensome for Alteri’s management efforts. D. Information Received From Clients Alteri will not assume any responsibility for the accuracy or the information provided by clients. Alteri is not obligated to verify any information received from a client or other professionals (e.g., attorney, accountant) designated by a client, and Alteri is expressly authorized by the client to rely on such information provided. Under all circumstances, clients are responsible for promptly notifying Alteri in writing of any material changes to the client’s financial situation, investment objectives, time horizon, or risk tolerance. E. Assets Under Management As of December 31, 2024, Alteri manages approximately $771, 265, 644 in Client assets, of which $462,447,295 is discretionary and $308,818,349 is non- discretionary. Item 5 - Fees and Compensation Alteri charges fees based on a percentage of assets under management. The specific fees charged by Alteri for services provided will be set forth in each client’s agreement. A. Investment Management Services Alteri charges an annual advisory fee that is agreed upon with each client and set forth in an agreement executed by Alteri and the client. The advisory fee for the initial month shall be paid, on a pro rata basis, in arrears, based on the value of the net billable assets under management at the end of such initial month. For subsequent months, the advisory fee shall be paid, in advance, based on the asset value of the client’s accounts as of the last business day of the preceding month as provided by third-party sources, such as pricing services, custodians, fund administrators, and client-provided sources For purposes of fee calculation, assets under management include cash and cash equivalents. Alteri’s maximum annual advisory fee is 1.5% (per annum). As provided above in Item 4, unless otherwise provided in the agreement 6  Alteri Wealth Disclosure Brochure with a client, the investment advisory fees charged by any designated External Managers are paid by Alteri and, therefore, are not in addition to the the annual advisory fee charged by Alteri. Notwithstanding the foregoing, Alteri and the client may choose to negotiate an annual advisory fee that varies from the range set forth above. Factors upon which a different annual advisory fee may be based include, but are not limited to, the size and nature of the relationship, the services rendered, the nature and complexity of the products and investments involved, time commitments, and travel requirements. The advisory fee charged by the Firm will apply to all of the client’s assets under management, unless specifically excluded in the client agreement. The advisory fee includes the financial planning services described above. Although Alteri believes that its fees are competitive, clients should understand that lower fees for comparable services may be available from other sources and firms. The investment advisory agreement between Alteri and the client may be terminated at will by either Alteri or the client upon written notice. Alteri does not impose termination fees when the client terminates the investment advisory relationship, except when agreed upon in advance. B. Payment of Fees Alteri generally deducts its advisory fee from a client’s investment account(s) held at his/her custodian. Upon engaging Alteri to manage such account(s), a client grants Alteri this limited authority through a written instruction to the custodian of his/her account(s). The client is responsible for verifying the accuracy of the calculation of the advisory fee; the custodian will not determine whether the fee is accurate or properly calculated. Although clients generally are required to have their investment advisory fees deducted from their accounts, in some cases, Alteri will directly bill a client for investment advisory fees if it determines that such billing arrangement is appropriate given the circumstances. The custodian of the client’s accounts provides each client with a statement, at least quarterly, indicating separate line items for all amounts disbursed from the client's account(s), including any fees paid directly to Alteri. Clients may make additions to and withdrawals from their account at any time, subject to Alteri’s right to terminate an account. Additions may be in cash or securities provided that the Firm reserves the right to liquidate transferred securities or decline to accept particular securities into a client’s account. Clients may withdraw account assets at any time on notice to Alteri, subject to the usual and customary securities settlement procedures. However, the Firm generally designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. Alteri may consult with its clients about the options and implications of transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, short-term redemption fees, fees assessed at the mutual fund level (e.g. contingent deferred sales charges) and/or tax ramifications. 7  Alteri Wealth Disclosure Brochure C. Clients Responsible for Fees Charged by Financial Institutions and External Money Managers In connection with Alteri’s management of an account, a client will incur fees and/or expenses separate from and in addition to Alteri’s advisory fee. These additional fees may include transaction charges and the fees/expenses charged by any custodian, mutual fund, ETF, limited partnership, transfer taxes, odd lot differentials, exchange fees, interest charges, ADR processing fees, and any charges, taxes or other fees mandated by any federal, state or other applicable law, retirement plan account fees (where applicable), margin interest, brokerage commissions, mark-ups or mark-downs and other transaction-related costs, electronic fund and wire fees, and any other fees that reasonably may be borne by a brokerage account. As referenced above, unless otherwise provided in the agreement with a client, the investment advisory fees charged by any designated External Managers are paid by Alteri and, therefore, are not in addition to the the annual advisory fee charged by Alteri. If provided for in the agreement with a client, the client will be responsible for the fees and expenses charged by any External Manager, and the External Manager’s platform manager, if any. For External Managers, clients should review each External Manager’s Form ADV 2A disclosure brochure and any contract they sign with the External Manager (in a dual contract relationship). The client is responsible for all such fees and expenses if provided in the client’s agreement that Alteri is not paying the External Managers fees and expenses. Please see Item 12 of this brochure regarding brokerage practices. D. Prepayment of Fees As noted in Item 5(B) above, Alteri’s advisory fees generally are paid in advance. Upon the termination of a client’s advisory relationship, Alteri will issue a refund equal to any unearned management fee for the remainder of the month. The client may specify how he/she would like such refund issued (i.e., a check sent directly to the client or a check sent to the client’s custodian for deposit into his/her account). E. Outside Compensation for the Sale of Securities or Other Investment Products to Clients Alteri does not buy or sell securities and does not receive any compensation for securities transactions in any client account, other than the investment advisory fees noted above. However, as further described in Item 10, certain personnel of Alteri, in their individual capacities, are registered representatives of Purshe Kaplan Sterling Investments, Inc. (“PKS”). In this capacity these individuals will engage in various types of securities or investment products transactions and will receive separate and typical compensation for doing so. In addition, certain representatives of Alteri, in their individual capacities, may also be licensed as insurance professionals. Such persons earn commission-based compensation for selling insurance products to clients. Item 6 - Performance-Based Fees and Side-by-Side Management Alteri does not charge performance-based fees or participate in side-by-side management. Performance- based fees are fees that are based on a share of capital gains or capital appreciation of a client’s account. Side-by-side management refers to the practice of managing accounts that are charged performance-based 8  Alteri Wealth Disclosure Brochure fees while at the same time managing accounts that are not charged performance-based fees. Alteri’s fees are calculated as described in Item 5 above. Item 7 - Types of Clients Alteri provides discretionary and non-discretionary investment management services to affluent individuals and families, including, business owners, athletes, physicians, entrepenuers, and entertainment industry executives, as well as entities, including, but not limited to, family offices, trusts, estates, private foundations, and qualified retirement plans. Alteri does not impose a minimum portfolio size or a minimum initial investment to open an account. However, Alteri does reserve the right to accept or decline a potential client for any reason in its sole discretion. Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis and Risk of Loss A primary step in Alteri’s investment strategy is getting to know the clients – to understand their financial condition, risk profile, investment goals, tax situation, liquidity constraints – and assemble a complete picture of their financial situation. To aid in this understanding, Alteri offers clients financial planning that is highly customized and tailored. This comprehensive approach is integral to the way that Alteri does business. Once Alteri has a true understanding of the client and their goals, the investment process can begin, and the Firm can recommend strategies and investments that it believes are aligned with the client’s goals and risk profile. Alteri primarily employs fundamental analysis methods in developing investment strategies for its clients. Research and analysis from Alteri is based on numerous sources, including third-party research materials and publicly-available materials, such as company annual reports, prospectuses, and press releases. Alteri generally employs a long-term investment strategy for its clients, as consistent with their financial goals. At times, the Firm may also buy and sell positions that are more short-term in nature, depending on the goals of the client and/or the fundamentals of the security, sector or asset class. Client portfolios with similar investment objectives and asset allocation goals may own different securities and investments. The client’s portfolio size, tax sensitivity, desire for simplicity, income needs, long-term wealth transfer objectives, time horizon and choice of custodian are all factors that influence Alteri’s investment recommendations. Investing in securities involves a risk of loss. A client can lose all or a substantial portion of his/her investment. A client should be willing to bear such a loss. Some investments are intended only for sophisticated investors and can involve a high degree of risk. B. Material Risks Involved Investing in securities involves a significant risk of loss which clients should be prepared to bear. Alteri’s investment recommendations are subject to various market, currency, economic, political and business risks, and such investment decisions will not always be profitable. Clients should be aware that there may 9  Alteri Wealth Disclosure Brochure be a loss or depreciation to the value of the client’s account. There can be no assurance that the client’s investment objectives will be obtained and no inference to the contrary should be made. Generally, the market value of equity stocks will fluctuate with market conditions, and small-stock prices generally will fluctuate more than large-stock prices. The market value of fixed income securities will generally fluctuate inversely with interest rates and other market conditions prior to maturity. Fixed income securities are obligations of the issuer to make payments of principal and/or interest on future dates, and include, among other securities: bonds, notes and debentures issued by corporations; debt securities issued or guaranteed by the U.S. government or one of its agencies or instrumentalities, or by a non-U.S. government or one of its agencies or instrumentalities; municipal securities; and mortgage-backed and asset-backed securities. These securities may pay fixed, variable, or floating rates of interest, and may include zero coupon obligations and inflation-linked fixed income securities. The value of longer duration fixed income securities will generally fluctuate more than shorter duration fixed income securities. Investments in overseas markets also pose special risks, including currency fluctuation and political risks, and it may be more volatile than that of a U.S. only investment. Such risks are generally intensified for investments in emerging markets. In addition, there is no assurance that a mutual fund or ETF will achieve its investment objective. Past performance of investments is no guarantee of future results. Additional risks involved in the securities recommended by Alteri include, among others: • Stock market risk, which is the chance that stock prices overall will decline. The market value of equity securities will generally fluctuate with market conditions. Stock markets tend to move in cycles, with periods of rising prices and periods of falling prices. Prices of equity securities tend to fluctuate over the short term as a result of factors affecting the individual companies, industries or the securities market as a whole. Equity securities generally have greater price volatility than fixed income securities. • • Sector risk, which is the chance that significant problems will affect a particular sector, or that returns from that sector will trail returns from the overall stock market. Daily fluctuations in specific market sectors are often more extreme than fluctuations in the overall market. Issuer risk, which is the risk that the value of a security will decline for reasons directly related to the issuer, such as management performance, financial leverage, and reduced demand for the issuer's goods or services. • Non-diversification risk, which is the risk of focusing investments in a small number of issuers, industries or foreign currencies, including being more susceptible to risks associated with a single economic, political or regulatory occurrence than a more diversified portfolio might be. • Value investing risk, which is the risk that value stocks not increase in price, not issue the anticipated stock dividends, or decline in price, either because the market fails to recognize the stock’s intrinsic value, or because the expected value was misgauged. If the market does not recognize that the securities are undervalued, the prices of those securities might not appreciate as anticipated. They also may decline in price even though in theory they are already undervalued. Value stocks are typically less volatile than growth stocks, but may lag behind growth stocks in an up market. • Smaller company risk, which is the risk that the value of securities issued by a smaller company will go up or down, sometimes rapidly and unpredictably as compared to more widely held securities. Investments in smaller companies are subject to greater levels of credit, market and issuer risk. 10  Alteri Wealth Disclosure Brochure • • Foreign (non-U.S.) investment risk, which is the risk that investing in foreign securities result in the portfolio experiencing more rapid and extreme changes in value than a portfolio that invests exclusively in securities of U.S. companies. Risks associated with investing in foreign securities include fluctuations in the exchange rates of foreign currencies that may affect the U.S. dollar value of a security, the possibility of substantial price volatility as a result of political and economic instability in the foreign country, less public information about issuers of securities, different securities regulation, different accounting, auditing and financial reporting standards and less liquidity than in the U.S. markets. Interest rate risk, which is the chance that prices of fixed income securities decline because of rising interest rates. Similarly, the income from fixed income securities may decline because of falling interest rates. • Credit risk, which is the chance that an issuer of a fixed income security will fail to pay interest and principal in a timely manner, or that negative perceptions of the issuer’s ability to make such payments will cause the price of that fixed income security to decline. • Exchange Traded Fund (ETF) risk, which is the risk of an investment in an ETF, including the possible loss of principal. ETFs typically trade on a securities exchange and the prices of their shares fluctuate throughout the day based on supply and demand, which may not correlate to their net asset values. Although ETF shares will be listed on an exchange, there can be no guarantee that an active trading market will develop or continue. Owning an ETF generally reflects the risks of owning the underlying securities it is designed to track. ETFs are also subject to secondary market trading risks. In addition, an ETF may not replicate exactly the performance of the index it seeks to track for a number of reasons, including transaction costs incurred by the ETF, the temporary unavailability of certain securities in the secondary market, or discrepancies between the ETF and the index with respect to weighting of securities or number of securities held. • Management risk, which is the risk that the investment techniques and risk analyses applied by Alteri may not produce the desired results and that legislative, regulatory, or tax developments, affect the investment techniques available to Alteri. There is no guarantee that a client’s investment objectives will be achieved. • • Real Estate risk, which is the risk that an investor’s investments in Real Estate Investment Trusts (“REITs”) or real estate-linked derivative instruments will subject the investor to risks similar to those associated with direct ownership of real estate, including losses from casualty or condemnation, and changes in local and general economic conditions, supply and demand, interest rates, zoning laws, regulatory limitations on rents, property taxes and operating expenses. An investment in REITs or real estate-linked derivative instruments subject the investor to management and tax risks. Investment Companies (“Mutual Funds”) risk, when an investor invests in mutual funds, the investor will bear additional expenses based on his/her pro rata share of the mutual fund’s operating expenses, including the management fees. The risk of owning a mutual fund generally reflects the risks of owning the underlying investments the mutual fund holds. • Commodity risk, generally commodity prices fluctuate for many reasons, including changes in market and economic conditions or political circumstances (especially of key energy-producing and consuming countries), the impact of weather on demand, levels of domestic production and imported commodities, energy conservation, domestic and foreign governmental regulation (agricultural, trade, fiscal, monetary and exchange control), international politics, policies of OPEC, taxation and the availability of local, intrastate and interstate transportation systems and the emotions of the marketplace. The risk of loss in trading commodities can be substantial. 11  Alteri Wealth Disclosure Brochure • Cybersecurity risk, which is the risk related to unauthorized access to the systems and networks of Alteri and its service providers. The computer systems, networks and devices used by Alteri and service providers to us and our clients to carry out routine business operations employ a variety of protections designed to prevent damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches. Despite the various protections utilized, systems, networks or devices potentially can be breached. A client could be negatively impacted as a result of a cybersecurity breach. Cybersecurity breaches can include unauthorized access to systems, networks or devices; infection from computer viruses or other malicious software code; and attacks that shut down, disable, slow or otherwise disrupt operations, business processes or website access or functionality. Cybersecurity breaches cause disruptions and impact business operations, potentially resulting in financial losses to a client; impediments to trading; the inability by us and other service providers to transact business; violations of applicable privacy and other laws; regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or other compliance costs; as well as the inadvertent release of confidential information. Similar adverse consequences could result from cybersecurity breaches affecting issues of securities in which a client invests; governmental and other regulatory authorities; exchange and other financial market operators, banks, brokers, dealers and other financial institutions; and other parties. In addition, substantial costs may be incurred by those entities in order to prevent any cybersecurity breaches in the future. • Alternative Investments / Private Funds risk, investing in alternative investments is speculative, not suitable for all clients, and intended for experienced and sophisticated investors who are willing to bear the high economic risks of the investment, which can include: • • • • • • • • • loss of all or a substantial portion of the investment due to leveraging, short-selling or other speculative investment practices; lack of liquidity in that there may be no secondary market for the investment and none expected to develop; volatility of returns; restrictions on transferring interests in the investment; potential lack of diversification and resulting higher risk due to concentration of trading authority when a single adviser is utilized; absence of information regarding valuations and pricing; delays in tax reporting; less regulation and higher fees than mutual funds; risks associated with the operations, personnel, and processes of the manager of the funds investing in alternative investments. • Closed-End Funds risk, Closed-end funds typically use a high degree of leverage. They may be diversified or non-diversified. Risks associated with closed-end fund investments include liquidity risk, credit risk, volatility and the risk of magnified losses resulting from the use of leverage. Additionally, closed-end funds may trade below their net asset value. There also are risks surrounding various insurance products that are recommended to Alteri clients from time to time. Such risks include, but are not limited to loss of premiums. Prior to purchasing any insurance product, clients should carefully read the policy and applicable disclosure documents. Clients are advised that they should only commit assets for management that can be invested for the long term, that volatility from investing can occur, and that all investing is subject to risk. Alteri does not 12  Alteri Wealth Disclosure Brochure guarantee the future performance of a client’s portfolio, as investing in securities involves the risk of loss that clients should be prepared to bear. Past performance of a security or a fund is not necessarily indicative of future performance or risk of loss. Use of External Managers Alteri may select certain External Managers to manage a portion of its clients’ assets. In these situations, the success of such recommendations relies to a great extent on the External Managers’ ability to successfully implement their investment strategies. In addition, Alteri generally may not have the ability to supervise the External Managers on a day-to-day basis. Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client’s evaluation of the adviser and the integrity of the adviser’s management. Ms. Gruber, while at UBS Financial Services Inc., received a client complaint regarding the safety and liquidity of auction rate securities (“ARS”) in 2008. The complaint arose in connection with the industry wide breakdown of the liquidity in the market for auction rate securities. UBS Financial Services Inc. agreed to repurchase the ARS securities at issue, at par value, from the client pursuant to a global repurchase agreement it entered into with several regulatory bodies. This was not a settlement of a dispute between the client and Ms. Gruber and was not based on the merits of the client’s specific concerns or any finding of fault or wrongdoing by Ms. Gruber. Ms. Gruber was not a party to, and did not agree to participate in, the repurchase agreement between the Firm and the relevant regulatory bodies. Item 10 – Other Financial Industry Activities and Affiliations Insurance Agent Activities As mentioned above in Item 5, advisory persons of Alteri are licensed as insurance professionals. Such persons earn commission-based compensation for selling insurance products to clients. Insurance commissions earned by advisory persons who are insurance professionals are separate from and in addition to Alteri’s advisory fee. This practice presents a conflict of interest as an advisory person who is an insurance professional has an incentive to recommend insurance products for the purpose of generating commissions rather than solely based on client needs. Alteri addresses this conflict through disclosure and strives to make recommendations which are in the best interests of its clients. Clients are under no obligation to purchase insurance products through any person affiliated with Alteri. Alteri clients should understand that lower fees and/or commissions for comparable services may be available from other insurance providers. Registered Representative Activities As mentioned above in Item 5(E), two representatives of Alteri (Michelle Gruber and Matthew Mullaly) are also registered representatives with PKS. PKS is a registered broker-dealer and member of FINRA. In this capacity, such representatives of Alteri offer securities or alternative investments 13  Alteri Wealth Disclosure Brochure and receive normal and customary fees or commissions as a result of these transactions. As a result of this relationship, PKS has access to certain confidential information (e.g., financial information, investment objectives, transactions and holdings) about clients, even if a client does not establish an account through PKS. If you would like a copy of the PKS privacy policy, please contact Alteri as described on the cover page of this brochure. Clients should be aware that the receipt of additional compensation itself creates an inherent conflict of interest, and may affect the judgment of these individuals when making recommendations. Alteri and PKS are separate, nonaffiliated entities. Nevertheless, to the extent that an Alteri representative recommends the purchase of securities or other investment products where the representative receives commissions for doing so, a conflict of interest exists because the representative is incentivized to make recommendations based on the compensation received rather than on a client’s needs. Alteri has adopted certain procedures designed to mitigate the effects of this conflict. As part of Alteri’s fiduciary duty to clients, Alteri and its representatives endeavor at all times to put the interests of clients first, and recommendations will only be made to the extent that they are reasonably believed to be in the best interests of clients. Additionally, the conflicts presented by this relationship are disclosed to clients through this brochure, client agreement and/or verbally prior to or at the time of entering into an Agreement. Clients are not obligated to implement recommended transactions through any Alteri representative or any particular broker-dealer. Clients have the option to purchase any recommended investment through broker-dealers other than PKS. Alteri clients should understand that lower fees and/or commissions for comparable services may be available from other broker-dealers. Recommendation of External Managers Alteri may recommend that clients use External Managers based on clients’ needs and suitability. Alteri does not receive separate compensation, directly or indirectly, from such External Managers for recommending that clients use their services. Alteri does not have any other business relationships with the recommended External Managers. Item 11 – Code of Ethics, Participation or Interest in Client Transactions A. Description of Code of Ethics Alteri has a Code of Ethics (the “Code”) which requires Alteri’s employees (“supervised persons”) to comply with their legal obligations and fulfill the fiduciary duties owed to the Firm’s clients. Among other things, the Code of Ethics sets forth policies and procedures related to conflicts of interest, outside business activities, gifts and entertainment, compliance with insider trading laws and policies and procedures governing personal securities trading by supervised persons. Personal securities transactions of supervised persons present potential conflicts of interest with the price obtained in client securities transactions or the investment opportunity available to clients. The Code addresses these potential conflicts by prohibiting securities trades that would breach a fiduciary duty to a client and requiring, with certain exceptions, supervised persons to report their personal securities holdings and transactions to Alteri for review by the Firm’s Chief Compliance Officer. The Code also requires 14  Alteri Wealth Disclosure Brochure supervised persons to obtain pre-approval of certain investments, including initial public offerings and limited offerings. Alteri will provide a copy of the Code of Ethics to any client or prospective client upon request. Item 12 – Brokerage Practices A. Factors Used to Select Custodians and/or Broker-Dealers Alteri generally recommends that its investment management clients utilize the custody and brokerage services of an unaffiliated broker/dealer custodians (a “BD/Custodian”) with which Alteri has an institutional relationship. Currently, this includes Charles Schwab & Co., Inc. (“Schwab”), which is a “qualified custodian” as that term is described in Rule 206(4)-2 of the Advisers Act. Each BD/Custodian provides custody of securities, trade execution, and clearance and settlement of transactions placed on behalf of clients by Alteri. If your accounts are custodied at Schwab, Schwab will hold your assets in a brokerage account and buy and sell securities when we instruct them to. Clients will pay fees to Schwab for custody and the execution of securities transactions in their accounts. In making BD/Custodian recommendations, Alteri will consider a number of judgmental factors, including, without limitation: 1) clearance and settlement capabilities; 2) quality of confirmations and account statements; 3) the ability of the BD/Custodian to settle the trade promptly and accurately; 4) the financial standing, reputation and integrity of the BD/Custodian; 5) the BD/Custodian’s access to markets, research capabilities, market knowledge, and any “value added” characteristics; 6) Alteri’s past experience with the BD/Custodian; and 7) Alteri’s past experience with similar trades. Recognizing the value of these factors, clients may pay a brokerage commission in excess of that which another broker might have charged for effecting the same transaction. In exchange for using the services of Schwab, Alteri may receive, without cost, computer software and related systems support that allows Alteri to monitor and service its clients’ accounts maintained with Schwab. Schwab also makes available to the Firm products and services that benefit the Firm but may not directly benefit the client or the client’s account. These products and services assist Alteri in managing and administering client accounts. They include investment research, both Schwab’s own and that of third parties. Alteri may use this research to service all or some substantial number of client accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • provide access to client account data (such as duplicate trade confirmations and account statements); facilitate trade execution and allocate aggregated trade orders for multiple client accounts; facilitate payment of our fees from our clients’ accounts; and assist with back-office functions, recordkeeping, and client reporting. • • provide pricing and other market data; • • Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: 15  Alteri Wealth Disclosure Brochure educational conferences and events; technology, compliance, legal, and business consulting; access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession; and • Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to the Firm. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide the Firm with other benefits such as occasional business entertainment of Firm personnel. In addition, Alteri receives financial support from Schwab up to capped dollar amount to be used toward qualifying marketing, technology, consulting and/or research expenses incurred by Alteri in registering and launching the operations of Alteri. This financial support is available to Alteri during the first 12 months from the start of Alteri clients having assets custodied at Schwab, and the ultimate amount payable by Schwab is dependent upon the amount of Alteri client assets custodied at Schwab. Furthermore, Schwab has agreed to reimburse account termination fees charged to Alteri clients by the former custodian of the clients’ accounts up to a capped dollar amount. This reimbursement is available during an initial 12 month period. Charles Schwab & Co., Inc. (“Schwab”) has provided a loan to Advisor to assist its business operations, and the loan is guaranteed by Michelle Gruber and Alexander Markowitz, principal(s) of Advisor. The terms of the loan require that management fees to Advisor be paid to an account at Schwab for deduction of interest and principal payments on the loan before Advisor may access such management fees. The loan agreement contains various representations and covenants by Advisor, including, among others, that Advisor will maintain at least 80% of AUM in end client net assets held at Schwab (“Assets Under Management at Schwab”), and that Advisor will comply with all applicable laws, regulations, and agreements, and obtain all necessary licenses, consents and permits. Upon the occurrence and during the continuance of an event of default under the loan agreement, Schwab may terminate and/or accelerate the loan, which may have a material adverse effect on the Advisor's ability to perform services for you. Some of the products, services and other benefits provided by Schwab, including the loan noted above, benefit Advisor and may not benefit Advisor's client accounts. Advisor's recommendation or requirement that a client place assets in Schwab's custody may be based in part on benefits Schwab provides to Advisor, or Advisor’s agreement to maintain certain Assets Under Management at Schwab, and not solely on the nature, cost or quality of custody and execution services provided by Schwab. Advisor places trades for its clients' accounts subject to its duty to seek best execution and its other fiduciary duties. Advisor may use broker-dealers other than Schwab to execute trades for client accounts maintained at Schwab, but this practice may result in additional costs to clients so that Advisor is more likely to place trades through Schwab rather than other broker-dealers. Schwab's execution quality may be different than other broker-dealers. 16  Alteri Wealth Disclosure Brochure The benefits received by Alteri through its participation in the Schwab custodial platform do not depend on the amount of brokerage transactions directed to Schwab. In addition, there is no corresponding commitment made by Alteri to Schwab to invest any specific amount or percentage of client assets in any specific mutual funds, securities or other investment products as a result of participation in the program. While as a fiduciary, we endeavor to act in our clients’ best interests, our recommendation that clients maintain their assets in accounts at Schwab will be based in part on the benefit to Alteri of the availability of some of the foregoing products and services and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab. The receipt of these benefits creates a potential conflict of interest and may indirectly influence Alteri’s choice of Schwab for custody and brokerage services. Alteri will periodically review its arrangements with the BD/Custodians and other broker-dealers against other possible arrangements in the marketplace as it strives to achieve best execution on behalf of its clients. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker- dealer’s services, including, but not limited to, the following: • • • • • a broker-dealer’s trading expertise, including its ability to complete trades, execute and settle difficult trades, obtain liquidity to minimize market impact and accommodate unusual market conditions, maintain anonymity, and account for its trade errors and correct them in a satisfactory manner; a broker-dealer’s infrastructure, including order-entry systems, adequate lines of communication, timely order execution reports, an efficient and accurate clearance and settlement process, and capacity to accommodate unusual trading volume; a broker-dealer’s ability to minimize total trading costs while maintaining its financial health, such as whether a broker-dealer can maintain and commit adequate capital when necessary to complete trades, respond during volatile market periods, and minimize the number of incomplete trades; a broker-dealer’s ability to provide research and execution services, including advice as to the value or advisability of investing in or selling securities, analyses and reports concerning such matters as companies, industries, economic trends and political factors, or services incidental to executing securities trades, including clearance, settlement and custody; and a broker-dealer’s ability to provide services to accommodate special transaction needs, such as the broker-dealer’s ability to execute and account for client-directed arrangements and soft dollar arrangements, participate in underwriting syndicates, and obtain initial public offering shares. Alteri’s clients may utilize qualified custodians other than Schwab for certain accounts and assets, particularly where clients have a previous relationship with such qualified custodians. Brokerage for Client Referrals Alteri does not select or recommend BD/Custodians based solely on whether or not it may receive client referrals from a BD/Custodian or third party. Client Directed Brokerage 17  Alteri Wealth Disclosure Brochure Generally, in the absence of specific instructions to the contrary, for brokerage accounts that clients engage Alteri to manage on a discretionary basis, Alteri has full discretion with respect to securities transactions placed in the accounts. This discretion includes the authority, without prior notice to the client, to buy and sell securities for the client’s account and establish and affect securities transactions through the BD/Custodian of the client’s account or other broker-dealers selected by Alteri. In selecting a broker-dealer to execute a client’s securities transactions, Alteri seeks prompt execution of orders at favorable prices. A client, however, may instruct Alteri to custody his/her account at a specific broker-dealer and/or direct some or all of his/her brokerage transactions to a specific broker-dealer. In directing brokerage transactions, a client should consider whether the commission expenses, execution, clearance, settlement capabilities, and custodian fees, if any, are comparable to those that would result if Alteri exercised its discretion in selecting the broker-dealer to execute the transactions. Directing brokerage to a particular broker-dealer may involve the following disadvantages to a directed brokerage client: • Alteri’s ability to negotiate commission rates and other terms on behalf of such clients • could be impaired; such clients could be denied the benefit of Alteri’s experience in selecting broker-dealers that are able to efficiently execute difficult trades; • opportunities to obtain lower transaction costs and better prices by aggregating (batching) • the client’s orders with orders for other clients could be limited; and the client could receive less favorable prices on securities transactions because Alteri may place transaction orders for directed brokerage clients after placing batched transaction orders for other clients. In addition to accounts managed by Alteri on a discretionary basis where the client has directed the brokerage of his/her account(s), certain institutional accounts may be managed by Alteri on a non- discretionary basis and are held at custodians selected by the institutional client. The decision to use a particular custodian and/or broker-dealer generally resides with the institutional client. Alteri endeavors to understand the trading and execution capabilities of any such custodian and/or broker-dealer, as well as its costs and fees. Alteri may assist the institutional client in facilitating trading and other instructions to the custodian and/or broker-dealer in carrying out Alteri’s investment recommendations. Trade Errors Alteri’s goal is to execute trades seamlessly and in the best interests of the client. In the event a trade error occurs, Alteri endeavors to identify the error in a timely manner, correct the error so that the client’s account is in the position it would have been had the error not occurred, and, after evaluating the error, assess what action(s) might be necessary to prevent a recurrence of similar errors in the future. Trade errors generally are corrected through the use of a “trade error” account or similar account at Schwab or another BD/Custodian, as the case may be. In the event an error is made in a client account custodied elsewhere, Alteri works directly with the broker in question to take corrective action. In all cases, Alteri will take the appropriate measures to return the client’s account to its intended position. B. Trade Aggregation 18  Alteri Wealth Disclosure Brochure To the extent that the Firm determines to aggregate client orders for the purchase or sale of securities, including securities in which the Firm’s supervised persons may invest, the Firm will generally do so in a fair equitable manner in accordance with applicable rules promulgated under the Advisers Act and guidance provided by the staff of the SEC and consistent with policies and procedures established by the Firm. Item 13 – Review of Accounts A. Periodic Reviews While investment management accounts are monitored on an ongoing basis, Alteri’s investment adviser representatives seek to have one annual meeting with each client to conduct a formal review of the clients’ portfolio. Accounts are reviewed for consistency with the investment strategy and other parameters set forth for the account and to determine if any adjustments need to be made. B. Other Reviews and Triggering Factors In addition to the periodic reviews described above, reviews may be triggered by changes in an account holder’s personal, tax or financial status. Other events that may trigger a review of an account are material changes in market conditions as well as macroeconomic and company- specific events. Clients are encouraged to notify Alteri of any changes in his/her personal financial situation that might affect his/her investment needs, objectives, or time horizon. C. Regular Reports Written brokerage statements are generated no less than quarterly and are sent directly from the qualified custodian. These reports list the account positions, activity in the account over the covered period, and other related information. Clients are also sent confirmations following each custodial account transaction unless confirmations have been waived. Alteri may also determine to provide account statements and other reporting to clients on a periodic basis. Clients are urged to carefully review all custodial account statements and compare them to any statements and reports provided by Alteri. Alteri statements and reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Item 14 – Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients Alteri does not receive benefits from third parties for providing investment advice to clients. B. Compensation to Non-Supervised Persons for Client Referrals Alteri does not enter into agreements with individuals or organizations for the referral of clients. Item 15 – Custody 19  Alteri Wealth Disclosure Brochure All clients must utilize a “qualified custodian” as detailed in Item 12. Clients are required to engage the custodian to retain their funds and securities and direct Alteri to utilize the custodian for the client’s securities transactions. Alteri’s agreement with clients and/or the clients’ separate agreements with the B/D Custodian may authorize Alteri through such BD/Custodian to debit the clients’ accounts for the amount of Alteri’s fee and to directly remit that fee to Alteri in accordance with applicable custody rules. The BD/Custodian recommended by Alteri has agreed to send a statement to the client, at least quarterly, indicating all amounts disbursed from the account including the amount of management fees paid directly to Alteri. Alteri encourages clients to review the official statements provided by the custodian, and to compare such statements with any reports or other statements received from Alteri. For more information about custodians and brokerage practices, see “Item 12 - Brokerage Practices.” Standing Letters of Authorization Alteri Wealth will allow clients to utilize standing letters of authorization (“SLOA”) and will have custody due to clients giving the Firm limited power of attorney to disburse funds to one or more third parties as specifically designated by the client. In such circumstances, the Firm will implement the steps in the SEC’s no-action letter on February 21, 2017 which includes (in summary): i) client will provide instruction for the SLOA to the custodian; ii) client will authorize the Firm to direct transfers to the specific third party; iii) the custodian will perform appropriate verification of the instruction and provide a transfer of funds notice to the client promptly after each transfer; iv) the client will have the ability to terminate or change the instruction; v) the Firm will have no authority or ability to designate or change the identity or any information about the third party; vi) the Firm will keep records showing that the third party is not a related party of the Firm or located at the same address as the Firm; and vii) the custodian will send the client an initial and annual notice confirming the SLOA instructions. Item 16 – Investment Discretion Clients have the option of providing Alteri with investment discretion on their behalf, pursuant to a grant of a limited power of attorney contained in Alteri’s client agreement. By granting Alteri investment discretion, a client authorizes Alteri to direct securities transactions and determine which securities are bought and sold, the total amount to be bought and sold, and the costs at which the transactions will be effected. Clients may impose reasonable limitations in the form of specific constraints on any of these areas of discretion with the consent and written acknowledgement of Alteri if Alteri determines, in its sole discretion, that the conditions would not materially impact the performance of a management strategy or prove overly burdensome for Alteri. See also Item 4(C), Client-Tailored Advisory Services. Item 17 – Voting Client Securities 20  Alteri Wealth Disclosure Brochure Alteri does not accept the authority to and does not vote proxies on behalf of clients. Clients retain the responsibility for receiving and voting proxies for all and any securities maintained in client portfolios. Item 18 – Financial Information Alteri is not required to disclose any financial information pursuant to this item due to the following: a) Alteri does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance of rendering services; b) Alteri is unaware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments relating to its discretionary authority over certain client accounts; and c) Alteri has never been the subject of a bankruptcy petition. 21