Overview
- Headquarters
- Leander, TX
- Total Firm Assets
- $146 million
- Average High-Net-Worth Client Portfolio Size
- $1.3 million
Fee Structure
Primary Fee Schedule (ADV PART 2A - ANKERSTAR WEALTH, LLC)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $500,000 | 0.95% |
| $500,001 | $1,000,000 | 0.90% |
| $1,000,001 | $2,000,000 | 0.85% |
| $2,000,001 | $3,000,000 | 0.80% |
| $3,000,001 | $5,000,000 | 0.70% |
| $5,000,001 | $7,500,000 | 0.60% |
| $7,500,001 | $10,000,000 | 0.50% |
| $10,000,001 | and above | 0.40% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $9,250 | 0.92% |
| $5 million | $39,750 | 0.80% |
| $10 million | $67,250 | 0.67% |
| $50 million | $227,250 | 0.45% |
| $100 million | $427,250 | 0.43% |
Clients
- High-Net-Worth Share of Firm Assets
- 66.87%
- Number of High-Net-Worth Clients
- 77
- Total Client Accounts
- 881
- Discretionary Accounts
- 844
- Non-Discretionary Accounts
- 37
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Regulatory Filings
- SEC CRD Number
- 170819
Additional Brochure: ADV PART 2A - ANKERSTAR WEALTH, LLC (2026-08-31)
View Document Text
Ankerstar Wealth, LLC
Firm Brochure - Form ADV Part 2A
This brochure provides information about the qualifications and business practices of Ankerstar Wealth, LLC. If
you have any questions about the contents of this brochure, please contact us at (512) 614-0085 or by email at:
vipservices@ankerstarwealth.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 Ankerstar Wealth, LLC
is also available on the SEC’s website at
Additional
www.adviserinfo.sec.gov. Ankerstar Wealth, LLC’s CRD number is: 170819.
3835 CR 175, Unit #840
Leander, TX, 78641
(512) 614-0085
www.ankerstarwealth.com
vipservices@ankerstarwealth.com
Registration does not imply a certain level of skill or training.
Version Date: 08/31/2026
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Item 2: Material Changes
The material changes in this brochure from the last annual updating amendment of Ankerstar Wealth,
LLC on 01/22/2026, are described below. Material changes relate to Ankerstar Wealth, LLC’s policies,
practices or conflicts of interests.
• Ankerstar Wealth LLC has updated its Assets Under Management. (Item 4 E)
• Ankerstar Wealth LLC has updated its Financial Planning fees and services provided for each
planning package. (Item 5)
• Ankerstar Wealth LLC has updated other financial industry activities and affiliations. (Item 10)
• Ankerstar Wealth LLC has disclosed sub-advisory arrangements. (Items 4, 5, 8, 10, 12 and 14)
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Item 3: Table of Contents
Item 1: Cover Page
Item 2: Material Changes....................................................................................................................................... ii
Item 3: Table of Contents ...................................................................................................................................... iii
Item 4: Advisory Business ...................................................................................................................................... 4
Item 5: Fees and Compensation ............................................................................................................................ 9
Item 6: Performance-Based Fees and Side-By-Side Management .................................................................. 13
Item 7: Types of Clients ........................................................................................................................................ 13
Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss .................................... 14
Item 9: Disciplinary Information ......................................................................................................................... 20
Item 10: Other Financial Industry Activities and Affiliations ......................................................................... 20
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 22
Item 12: Brokerage Practices ................................................................................................................................ 23
Item 13: Reviews of Accounts .............................................................................................................................. 25
Item 14: Client Referrals and Other Compensation ......................................................................................... 26
Item 15: Custody .................................................................................................................................................... 27
Item 16: Investment Discretion ............................................................................................................................ 28
Item 17: Voting Client Securities (Proxy Voting) .............................................................................................. 28
Item 18: Financial Information ............................................................................................................................ 28
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Item 4: Advisory Business
Business Description
We provide services to individuals and high-net-worth individuals concerning mutual funds,
fixed income securities, real estate funds (including REITs), insurance products including
annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury
inflation protected/inflation linked bonds, commodities, non-U.S. securities and venture capital
funds. As a registered investment adviser, we are held to the highest standard of client care – a
fiduciary standard. As a fiduciary, we always put our client’s interests first and must fully
disclose any potential conflict of interest. We do not hold customer funds or securities.
A. Description of the Advisory Firm
Ankerstar Wealth, LLC (hereinafter “AW”) formerly Afterburner Financial, LLC, is a
Limited Liability Company organized in the State of Texas. The firm was formed in
February 2014, and the principal owner is Steven Ankerstar.
B. Types of Advisory Services
Portfolio Management Services
AW offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. AW creates an Investment Policy
Statement for each client, which outlines the client’s current situation (income, desired
retirement age, and risk tolerance levels) and then constructs a plan to aid in the selection
of a portfolio that matches each client's specific situation.. Portfolio management services
include, but are not limited to, the following:
•
•
•
Investment strategy •
•
Asset allocation
•
Risk tolerance
Personal investment policy
Asset selection
Regular portfolio monitoring
AW evaluates the current investments of each client with respect to their risk tolerance
levels and time horizon. AW will request discretionary authority from clients in order to
select securities and execute transactions without permission from the client prior to each
transaction. Risk tolerance levels are documented in the Investment Policy Statement,
which is given to each client.
AW seeks to provide that investment decisions are made in accordance with the fiduciary
duties owed to its accounts and without consideration of AW’s economic, investment or
other financial interests. To meet its fiduciary obligations, AW attempts to avoid, among
other things, investment or trading practices that systematically advantage or
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disadvantage certain client portfolios, and accordingly, AW’s policy is to seek fair and
equitable allocation of investment opportunities/transactions among its clients to avoid
favoring one client over another over time. It is AW’s policy to allocate investment
opportunities and transactions it identifies as being appropriate and prudent, including
initial public offerings ("IPOs") and other investment opportunities that might have a
limited supply, among its clients on a fair and equitable basis over time.
Participant Account Management (Discretionary)
We use a third-party platform to facilitate management of held away assets such as
defined contribution plan participant accounts, with discretion. The platform allows us to
avoid being considered to have custody of Client funds since we do not have direct access
to Client log-in credentials to affect trades. We are not affiliated with the platform in any
way and receive no compensation from them for using their platform. A link will be
provided to the Client allowing them to connect an account(s) to the platform. Once Client
account(s) is connected to the platform, Adviser will review the current account
allocations. When deemed necessary, Adviser will rebalance the account considering
client investment goals and risk tolerance, and any change in allocations will consider
current economic and market trends. The goal is to improve account performance over
time, minimize loss during difficult markets, and manage internal fees that harm account
performance. Client account(s) will be reviewed at least quarterly, and allocation changes
will be made as deemed necessary.
Financial Planning
Financial plans and financial planning may include but are not limited to: investment
planning; life insurance; tax concerns; retirement planning; college planning; and
debt/credit planning.
Investment planning involves working with clients to make sure their investments match
their respective risk tolerance and goals. Tax concerns are addressed by working with the
client to determine and compare effective tax rates for income, capital gains and other
earnings or investments, then attempting to allocate the client’s resources accordingly.
Life insurance planning entails reviewing the life insurance and/or disability insurance
needs of the client, together with any applicable dependents, spouse or other relatives,
and assessing appropriate coverage for these individuals. College planning entails
helping clients save for higher education, whether for the client or his/her children or
other dependents, in the ideal manner to suit the client’s overall financial goals and means.
Financial planning to address retirement entails making sure clients are financially
equipped for retirement in light of the client’s anticipated income and expenses,
investments, and other assets. Debt/credit planning consists of breaking down client
budgets and aiding clients in decision-making as to current debt, anticipated significant
expenses and potential debt, and avoiding excessive debt.
5
Written Acknowledgement of Fiduciary Status
When we provide investment advice to you regarding your retirement plan account or
individual retirement account, we are fiduciaries within the meaning of Title I of the
Employee Retirement Income Security Act and/or the Internal Revenue Code, as
applicable, which are laws governing retirement accounts. 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 interest ahead of yours. Under this special
rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations
(give prudent advice);
• Never put our financial interests ahead of yours when making recommendations
(give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in
your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
Proprietary Investment Models
The Firm develops and manages proprietary investment models that may be made
available through third-party investment platforms. Unaffiliated investment advisers may
offer these models to their clients through such platforms as part of the advisory services
they provide. The Firm is responsible for the ongoing management of the investment
models, including changes to the model allocations and underlying securities, while the
participating investment adviser remains responsible for determining whether the models
are appropriate for its clients and for providing ongoing advisory services to those clients.
Sub-Advisory Arrangement
AW has entered into an arrangement with 55I, LLC ("55ip"), an SEC-registered investment
adviser, under which 55ip provides discretionary sub-advisory services, including trade
execution, portfolio rebalancing, and tax-management overlay services, for certain client
accounts (the "Program"). Under this arrangement, 55ip has discretionary authority to
trade and rebalance Program accounts in accordance with the selected model(s), subject
to AW's right to override, restrict, or otherwise direct trading activity in individual client
accounts.
Clients invested in the Program are not charged an additional advisory or sub-advisory
fee by 55ip beyond the Firm's standard advisory fee described in Item 5. AW has
conducted and documented a due diligence review comparing the models and exchange-
traded funds ("ETFs") required under the Program to the strategies and products AW
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utilized prior to entering into the arrangement, and to other reasonably available
alternatives, evaluating factors including expense ratios, tax efficiency, and anticipated
net benefit to clients. Based on this review, AW has determined that use of the Program is
consistent with, and in AW's assessment beneficial to, the best interests of clients for whom
it is deemed suitable. AW will periodically re-evaluate this determination and the
appropriateness of the Program for individual clients on an ongoing basis.
AW receives an economic benefit in connection with this arrangement that creates a
conflict of interest. See Item 14 below for a description of this benefit and how AW
addresses the related conflict.
Clients are under no obligation to participate in the Program and should discuss with their
investment adviser representative whether the Program, and the models/ETFs required
under it, are appropriate for their individual circumstances.
Services Limited to Specific Types of Investments
AW does not limit its investment advice to specific types of investments. The Adviser may
recommend a variety of securities, including equities, fixed income securities, ETFs,
mutual funds, and other investments as appropriate.
C. Client Tailored Services and Client Imposed Restrictions
AW will tailor a program for each individual client. This will include an interview session
to get to know the client’s specific needs and requirements as well as a plan that will be
executed by AW on behalf of the client. AW may use “model portfolios” together with a
specific set of recommendations for each client based on their personal restrictions, needs,
and targets. Model portfolios were solely designed by AW utilizing the expertise of the
Investment Adviser Representatives. Each model portfolio is designed around a risk score
and risk range. The process begins with a Risk Questionnaire for the client from
Nitrogen® and continues with a conversation with the client after a thorough review of
their financial situation and risk tolerance utilizing the risk methodology and scoring
system provided by Nitrogen®. The agreed upon risk score and risk range are signed and
attached as an Exhibit to the Investment Advisory Contract. AW then manages each
account as well as the overall portfolio to remain within the contracted risk range. Any
situation that would necessitate a change would be formalized by a contract amendment
where the client can then change any specific account risk score/range and/or the overall
portfolio risk score/range. Clients may impose restrictions in investing in certain
securities or types of securities in accordance with their values or beliefs.
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D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees, transaction costs, fund expenses, and other administrative
fees. AW does not participate in any wrap fee programs.
E. Assets Under Management
As of July 22, 2026, AW manages approximately $146M in regulatory assets under
management (“RAUM”). RAUM represents client assets for which AW provides
continuous and regular supervisory or management services in accordance with the
definition of regulatory assets under management adopted by the U.S. Securities and
Exchange Commission.
In addition to RAUM, AW provides investment advice and recommendations regarding
certain other client assets that are not included in RAUM (“Assets Under Advisement” or
“AUA”). These assets may include, among other things, certain retirement plan accounts,
such as 401(k) accounts, and private investments, for which AW provides investment
advice but does not have discretionary authority, custody, or continuous and regular
supervisory authority.
AW reports AUA separately from RAUM because the methodology used to calculate
AUA differs from the methodology required for calculating RAUM. AUA values may be
based on information obtained from clients, account statements, custodians, plan
providers, private investment sponsors, or other third-party sources. The value of AUA
used for reporting purposes may not reflect the current market value of such assets and
may be calculated differently from RAUM.
AW may charge advisory fees based on certain AUA. The methodology used to calculate
fees on AUA will be calculated for the quarter using an end of month average based on
the valuations provided by the clients, account statements, custodians, plan providers,
private investment sponsors, or other third-party sources.
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$137,259,668
$8,805,305
July 2026
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Item 5: Fees and Compensation
A. Fee Schedule
Portfolio Management Fees
For portfolio advisory and management services, the Firm does not charge
implementation, set-up, upfront, or termination fees. Instead, clients pay a single ongoing
advisory fee for the monitoring, management, and administration of their investment
portfolios.
The annual advisory fee is generally calculated as a percentage of assets and is billed
according to the tiered fee schedule below. Under this schedule, each successive asset tier
is charged at a lower annual rate than the preceding tier. The rates are additive; for
example, the first $500,000 of assets is billed at an annual rate of 0.95%, the next $500,000
is billed at an annual rate of 0.90%, and so on as asset levels increase.
Depending on the services provided and the terms of the applicable advisory agreement,
advisory fees may be calculated based on Regulatory Assets Under Management
("RAUM") and/or Assets Under Advisement ("AUA"). For certain assets, including
certain retirement plan accounts and private investments, the Firm provides investment
advice and recommendations but does not have discretionary authority or continuous and
regular supervisory authority over such assets. Accordingly, these assets are not included
in the Firm's RAUM as reported in Form ADV Part 1A but may be included as AUA for
purposes of calculating advisory fees if provided for in the applicable advisory agreement.
When advisory fees are calculated based on AUA, the valuation methodology used to
determine fees may differ from the methodology required to calculate RAUM under the
Investment Advisers Act of 1940. Unless otherwise provided in the applicable advisory
agreement, AUA-based fees are calculated quarterly using the average month-end value
of the applicable assets during the billing period, based on valuations obtained from
clients, custodians, account statements, retirement plan providers, private investment
sponsors, or other independent third-party sources. As a result, the assets used to calculate
advisory fees may differ from the assets reported as RAUM in Form ADV Part 1A.
Compensation Based on Assets Under Advisement
The Firm may receive advisory fees based on certain Assets Under Advisement, including
assets held in retirement plan accounts or private investments where the Firm does not
have discretionary authority. This creates a conflict because the Firm may have an
incentive to recommend that clients retain assets in accounts or investments that generate
advisory fees. The Firm seeks to mitigate this conflict by providing recommendations that
are consistent with clients’ investment objectives, financial circumstances, and best
interests.
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NOTE: 0.95% annually is the maximum fee for all AUM clients.
Total Assets Under Management
Management Fee
First $500K ($1-$500K)
0.95% annually (0.2375% quarterly)
Next $500K ($500K - $1M)
0.90% annually (0.225% quarterly)
Next $1M ($1M - $2M)
0.85% annually (0.2125% quarterly)
Next $1M ($2M - $3M)
0.80% annually (0.200% quarterly)
Next $2M ($3M - $5M)
0.70% annually (0.175% quarterly)
Next $2.5M ($5M - $7.5M)
0.60% annually (0.150% quarterly)
Next $2.5M ($7.5M - $10M)
0.50% annually (0.125% quarterly)
Above $10M
0.40% annually (0.100% quarterly)
The final fee schedule is attached as Exhibit II of the Investment Advisory Contract.
Advisory fees are negotiable at the discretion of the Firm. As a result, similarly situated
clients may pay different fees. Clients may terminate the agreement without penalty for a
full refund of AW's fees within five business days of signing the Investment Advisory
Contract. Thereafter, clients may terminate the Investment Advisory Contract generally
with 1 days' written notice.
All Asset-based portfolio management fees are withdrawn directly from a client account
that AW has authorization to deduct fees from with client's written authorization or may
be invoiced/billed directly to the client. Clients may select the method in which they are
billed. All fees are paid quarterly in arrears.
The AW advisory fee is based on the valuation provided by the custodian at the end of
each quarter with adjustments being made for cash flows throughout the quarter. Any
AW managed investments whose custodian is unable to be linked to our billing platform
will be calculated for the quarter using an end of month average based on the valuations
provided by the client.
Additional Fees for Separately Managed Accounts and Third-Party Managers
If Client elects (this is not common) to allocate assets to one or more separately managed
accounts("SMAs") or other vehicles managed by unaffiliated third-party investment
10
managers ("External Managers" or "Asset Managers"), Client understands and agrees
that:(i) Client will be required to execute a separate investment management or sub-
advisory agreement directly with each External Manager;(ii) Client will be solely
responsible for paying all fees and expenses charged by the External Manager(s) pursuant
to the terms of such separate agreement(s), which fees are in addition to, and not included
in, the advisory fee charged by Adviser under this Agreement;(iii) Such additional fees
may be deducted directly from the Client's Account by the custodian or paid separately
by Client, as specified in the External Manager's agreement; and(iv) Adviser receives no
compensation from the External Manager(s) in connection with such allocations unless
otherwise specifically disclosed to Client in writing. Adviser will provide Client with
information regarding the External Manager's fees and terms prior to any allocation, but
Client remains responsible for reviewing and agreeing to those terms independently.
Financial Planning Fees
Fixed Fees
Our initial half-hour discovery meeting is complimentary, where we can interview each
other. This meeting will conclude with a recommendation and specific price quote which
will depend on the client’s unique circumstances and needs. Clients will have the option
to choose the service package after consultation with the Adviser.
The fixed rate for creating Client financial plans is below. Fixed financial planning fees are
paid via check, cash, or wire. These fees are charged in arrears upon completion. The fees
are negotiable, and the final fee schedule will be attached as Exhibit II of the Financial
Planning Agreement.
• Basic Planning Package – $500, for 1-hour meeting & basic plan.
• Comprehensive Planning Package – $1,500, for 1-hour meeting & full plan.
• Continuous Planning Package - $3,000, for initial 2-hour meeting plus three quarterly
2hour meetings & full plan.
Clients may terminate the agreement without penalty for a full refund of AW's fees within
five business days of signing the Financial Planning Agreement. Thereafter, clients may
terminate the Financial Planning Agreement generally upon written notice.
Model Subscription Compensation
In addition to the advisory fees described above and as described in Item 4, the Firm
makes proprietary investment models available through a third-party investment
platform (Autopilot). The Firm receives compensation in connection with the availability
of these models. Clients who elect to subscribe to these models through the platform pay
subscription fees established by the platform. The Firm receives a percentage of those
subscription fees pursuant to its agreement with the platform and/or participating
adviser.
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The receipt of subscription fee revenue creates a conflict of interest because the Firm has
a financial incentive for investors to subscribe to its proprietary models. The Firm
addresses this conflict by managing the models in accordance with its fiduciary
obligations and maintaining policies and procedures reasonably designed to ensure that
investment decisions are made in the best interests of clients.
Sub-Advisory Program Fees
For clients participating in the Program described in Item 4, AW's standard advisory fee,
as described elsewhere in this Item 5, applies and is not increased as a result of Program
participation. Clients do not pay a separate or additional advisory, sub-advisory, or
platform fee to 55I, LLC ("55ip") in connection with the Program; AW's arrangement
with 55ip, including the fee waiver described in Item 14, does not result in any
additional direct or indirect fee or cost being charged to clients.
Clients should be aware that the underlying investment models and/or exchange-traded
funds ("ETFs") utilized within the Program carry their own internal expense ratios, as is
the case with any pooled investment vehicle, which are borne by the client as an investor
in those funds and are separate from, and in addition to, AW's advisory fee. These
internal fund-level expenses are not compensation to AW or to 55ip and are disclosed in
each fund's prospectus or offering documents. AW's due diligence process, described in
Item 4, includes a comparison of expense ratios associated with the Program's required
models/ETFs relative to the strategies and products previously utilized by AW.
B. Payment of Fees
Payment of Portfolio Management Fees
Asset-based portfolio management fees are withdrawn directly from the client's accounts
with client's written authorization on a quarterly basis or may be invoiced and billed
directly to the client on a quarterly basis. Clients may select the method in which they are
billed. Fees are paid in arrears.
Payment of Financial Planning Fees
Fixed financial planning fees are paid via check, cash, or wire. These fees are charged in
arrears after the first meeting or upon completion depending on the scope of services
performed.
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C. Client Responsibility For Third Party Fees
Clients are responsible for the payment of all third-party fees (i.e. custodian fees,
brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and
distinct from the fees and expenses charged by AW. These fees can include service
providers managing separately managed accounts or subscription fees paid to service
providers. Please see Item 12 of this brochure regarding broker-dealer/custodian.
D. Prepayment of Fees
AW collects its fees in arrears. It does not collect fees in advance.
E. Outside Compensation For the Sale of Securities to Clients
Neither AW nor its supervised persons accept any compensation for the sale of securities
or other investment products, including asset-based sales charges or service fees from the
sale of mutual funds.
Item 6: Performance-Based Fees and Side-By-Side Management
AW does not accept performance-based fees or other fees based on a share of capital gains on or
capital appreciation of the assets of a client.
Item 7: Types of Clients
AW generally provides advisory services to the following types of clients:
Individuals
High-Net-Worth Individuals
Corporations or Business Entities
There is no account minimum for any of AW’s services.
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Item 8: Methods of Analysis, Investment Strategies, and Risk of
Investment Loss
A. Methods of Analysis and Investment Strategies
Methods of Analysis
AW’s methods of analysis include fundamental analysis, technical analysis, cyclical
analysis and the use of model portfolios.
Fundamental analysis involves the analysis of financial statements, the general financial
health of companies, and/or the analysis of management or competitive advantages.
Technical analysis involves the analysis of past market data; primarily price and volume.
Cyclical analysis involves the analysis of business cycles to find favorable conditions for
buying and/or selling a security.
Model portfolios are designed to capture return and risk at market rates. This seeks to
provide clients with diversification benefits help to smooth returns, reduce volatility and
decrease asset-class and single-strategy risks.
Investment Strategies
AW uses long term trading, short term trading, short sales, margin transactions and
options trading (including covered options, uncovered options, or spreading strategies).
Investing in securities involves a risk of loss that you, as a client, should be prepared
to bear.
B. Material Risks Involved
Methods of Analysis
Fundamental analysis concentrates on factors that determine a company’s value and
expected future earnings. This strategy would normally encourage equity purchases in
stocks that are undervalued or priced below their perceived value. The risk assumed is
that the market will fail to reach expectations of perceived value.
Technical analysis attempts to predict a future stock price or direction based on market
trends. The assumption is that the market follows discernible patterns and if these patterns
can be identified then a prediction can be made. The risk is that markets do not always
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follow patterns and relying solely on this method may not take into account new patterns
that emerge over time.
Cyclical analysis assumes that the markets react in cyclical patterns which, once
identified, can be leveraged to provide performance. The risks with this strategy are
twofold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors
begin to implement this strategy, then it changes the very cycles these investors are trying
to exploit.
Investment Strategies
AW's use of short sales, margin transactions and options trading generally holds greater
risk, and clients should be aware that there is a material risk of loss using any of those
strategies.
Long term trading is designed to capture market rates of both return and risk. Due to its
nature, the long-term investment strategy can expose clients to various types of risk that
will typically surface at various intervals during the time the client owns the investments.
These risks include but are not limited to inflation (purchasing power) risk, interest rate
risk, economic risk, market risk, and political/regulatory risk.
Short term trading risks include liquidity, economic stability, and inflation, in addition to
the long-term trading risks listed above. Frequent trading can affect investment
performance, particularly through increased brokerage and other transaction costs and
taxes.
Short sales entail the possibility of infinite loss. An increase in the applicable securities’
prices will result in a loss and, over time, the market has historically trended upward.
Margin transactions use leverage that is borrowed from a brokerage firm as collateral.
When losses occur, the value of the margin account may fall below the brokerage firm’s
threshold thereby triggering a margin call. This may force the account holder to either
allocate more funds to the account or sell assets on a shorter time frame than desired.
Options transactions involve a contract to purchase a security at a given price, not
necessarily at market value, depending on the market. This strategy includes the risk that
an option may expire out of the money resulting in minimal or no value, as well as the
possibility of leveraged loss of trading capital due to the leveraged nature of stock options.
Model portfolios are designed to capture return and risk at market rates. This seeks to
provide clients with diversification benefits help to smooth returns, reduce volatility and
decrease asset-class and single-strategy risks. Risks specific to using model portfolios
include the possibility that the model portfolio will underperform the market and the
possibility that the model will not be able take advantage of opportunities that a nonmodel
portfolio management approach might capture. Model portfolios entail inflation
15
(purchasing power) risk, interest rate risk, economic risk, market risk, political/regulatory
risk, and asset allocation risk – meaning that any given asset allocation strategy does not
guarantee any specific result or profit nor protect against a loss.
Program Investment Strategy and Limitations
For client accounts participating in the Program described in Item 4 (55ip), assigned
investment models are limited to a subset of investment products, rather than the Firm's
full universe of otherwise available products. Models on 55ip used by the Firm only
include investments that fall into the following subset: publicly traded ETFs, equities, and
mutual funds. Client accounts may still utilize investments that fall outside of that subset
at the discretion of their Advisor, but those investments will typically not be traded by
55ip, nor considered in their tax-efficient outcome software. Additionally, certain client
accounts may be invested in the JPMorgan Investment Management Strategic model set
on 55ip. This model set is invested in exclusively JPMorgan-issued ETFs and Mutual
Funds. Because the JPMorgan model set draws exclusively from a single fund family,
client accounts using that model set have less diversification across investment managers
and fund sponsors than an account allocated across multiple fund families and are
correspondingly more exposed to risks specific to JPMorgan as a manager and product
sponsor (including manager, operational, and product-level risk). These limitations are a
factor clients should consider, together with the conflict-of-interest disclosure in Item 14,
in evaluating whether Program participation is appropriate for their circumstances.
Within these parameters, for taxable accounts on the platform, 55ip utilizes a tax-
management overlay methodology intended to pursue tax-efficient outcomes for client
accounts, including techniques such as tax-loss harvesting, coordination of wash-sale
rules, and tax-aware transition management when accounts are initially funded or
rebalanced. 55ip's methodology relies on proprietary, rules-based technology to
implement and maintain target portfolios, which may deviate in its analytical approach
from methods used elsewhere in the Firm's business.
In addition to the general risks described elsewhere in this Item 8, clients participating in
the Program should understand the following:
Sub-adviser discretion: 55ip exercises discretionary trading authority over Program
accounts, subject to the Firm's override rights described in Item 4. There is a risk that
trading or rebalancing activity may occur that the Firm would not have independently
initiated, and a risk that the Firm's override, when exercised, may not fully mitigate the
effect of a given trade.
Tax-management strategy risk: Tax-loss harvesting and related tax-management
techniques involve trading decisions made primarily to pursue tax efficiency, which may,
in some circumstances, result in transaction costs, tracking error relative to a stated
benchmark, or outcomes that differ from a purely investment-merit-based trading
approach. The tax benefits of these techniques are not guaranteed and depend on each
client's individual tax circumstances; clients should consult their own tax advisor
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regarding the application of these strategies to their personal situation. Tax-loss
harvesting and related techniques generally provide no benefit to accounts held in tax-
deferred or tax-exempt vehicles (such as IRAs, Roth IRAs, or other qualified retirement
accounts).
Wash-sale coordination limitations: 55ip's wash-sale coordination applies only to
accounts participating in the Program of which the Firm and 55ip are aware. The Firm and
55ip cannot monitor or coordinate wash-sale activity with respect to securities held in
accounts outside the Program, including accounts held away from the Firm, accounts held
by a client's spouse, or employer-sponsored retirement accounts. Trading within the
Program could inadvertently trigger a wash sale as a result of holdings or transactions in
those other accounts.
Reliance on third-party technology and processes: The Program's execution and tax-
management functions depend on 55ip's proprietary technology and operational
processes, which are outside the Firm's direct control, though subject to the Firm's ongoing
due diligence and monitoring described in Item 4.
Model and technology risk: 55ip's rules-based models and technology may contain
errors, may not perform as intended, and may not adapt effectively to unusual, volatile,
or fast-moving market conditions. Reliance on automated, rules-based processes involves
the risk that trading decisions may not reflect the judgment the Firm would apply if
managing the account directly.
Model and provider change risk: JPMorgan or another model provider may modify,
restrict the availability of, or discontinue a given model, and 55ip may substitute or
modify the models available on its platform. Any such change could alter a client account's
risk and return characteristics, potentially without an affirmative decision by the client or
the Firm at the time the change occurs.
Transition and onboarding risk: When an account is initially funded into, or transitioned
between, models on the platform, the process of aligning the account to its target model
may generate realized capital gains and cause the account to deviate from its target model
allocation for a period of time until the transition is complete.
Dependence on data accuracy: 55ip's tax-management techniques rely on the accuracy
and completeness of cost-basis and other account information provided to it by the
account custodian and/or the client. Errors, delays, or gaps in this data could affect the
accuracy of tax-management outcomes, including tax-loss harvesting and wash-sale
coordination.
Investing in securities involves a risk of loss that you, as a client, should be prepared
to bear.
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C. Risks of Specific Securities Utilized
AW's use of short sales, margin transactions and options trading generally holds greater
risk of capital loss. Clients should be aware that there is a material risk of loss using any
investment strategy. The investment types listed below (leaving aside Treasury Inflation
Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other
government agency.
Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may
lose money investing in mutual funds. All mutual funds have costs that lower investment
returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity”
nature.
Equity investment generally refers to buying shares of stocks in return for receiving a
future payment of dividends and/or capital gains if the value of the stock increases. The
value of equity securities may fluctuate in response to specific situations for each
company, industry conditions and the general economic environments.
Fixed income investments generally pay a return on a fixed schedule, though the amount
of the payments can vary. This type of investment can include corporate and government
debt securities, leveraged loans, high yield, and investment grade debt and structured
products, such as mortgage and other asset-backed securities, although individual bonds
may be the best-known type of fixed income security. In general, the fixed income market
is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond
prices usually fall, and vice versa. This effect is usually more pronounced for longer-term
securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and
credit and default risks for both issuers and counterparties. The risk of default on treasury
inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting
(extremely unlikely); however, they carry a potential risk of losing share price value, albeit
rather minimal. Risks of investing in foreign fixed income securities also include the
general risk of non-U.S. investing described below.
Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges,
similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100%
loss in the case of a stock holding bankruptcy). Areas of concern include the lack of
transparency in products and increasing complexity, conflicts of interest and the
possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver,
or Palladium Bullion backed “electronic shares” not physical metal) specifically may be
negatively impacted by several unique factors, among them (1) large sales by the official
sector which own a significant portion of aggregate world holdings in gold and other
precious metals, (2) a significant increase in hedging activities by producers of gold or
other precious metals, (3) a significant change in the attitude of speculators and investors.
Cryptocurrency ETPs are exposed to cryptocurrency, which are decentralized digitized
assets that often rely on blockchain technology. Cryptocurrency ETPs are highly
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speculative and extremely volatile. Cryptocurrency is part of a new and evolving
industry, and neither the technology nor regulatory regime for cryptocurrency is settled.
Cryptocurrency ETPs may trade in over-the-counter markets and may not be afforded all
of the investor protections of other exchange-traded products. Complex exchange-traded
products, such as cryptocurrency ETFs are often designed to not be held long term.
Real Estate funds (including REITs) face several kinds of risk that are inherent in the real
estate sector, which historically has experienced significant fluctuations and cycles in
performance. Revenues and cash flows may be adversely affected by: changes in local real
estate market conditions due to changes in national or local economic conditions or
changes in local property market characteristics; competition from other properties
offering the same or similar services; changes in interest rates and in the state of the debt
and equity credit markets; the ongoing need for capital improvements; changes in real
estate tax rates and other operating expenses; adverse changes in governmental rules and
fiscal policies; adverse changes in zoning laws; the impact of present or future
environmental legislation and compliance with environmental laws.
Annuities are a retirement product for those who may have the ability to pay a premium
now and want to guarantee they receive certain monthly payments or a return on
investment later in the future. Annuities are contracts issued by a life insurance company
designed to meet requirement or other long-term goals. An annuity is not a life insurance
policy. Variable annuities are designed to be long-term investments, to meet retirement
and other long-range goals. Variable annuities are not suitable for meeting short-term
goals because substantial taxes and insurance company charges may apply if you
withdraw your money early. Variable annuities also involve investment risks, just as
mutual funds do.
Venture capital funds invest in start-up companies at an early stage of development in
the interest of generating a return through an eventual realization event; the risk is high
as a result of the uncertainty involved at that stage of development.
Commodities are tangible assets used to manufacture and produce goods or services.
Commodity prices are affected by different risk factors, such as disease, storage capacity,
supply, demand, delivery constraints and weather. Because of those risk factors, even a
well-diversified investment in commodities can be uncertain.
Options are contracts to purchase a security at a given price, risking that an option may
expire out of the money resulting in minimal or no value. An uncovered option is a type
of options contract that is not backed by an offsetting position that would help mitigate
risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss
for an uncovered call option is limitless. Spread option positions entail buying and selling
multiple options on the same underlying security, but with different strike prices or
expiration dates, which helps limit the risk of other option trading strategies. Option
transactions also involve risks including but not limited to economic risk, market risk,
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sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk
and interest rate risk.
Non-U.S. securities present certain risks such as currency fluctuation, political and
economic change, social unrest, changes in government regulation, differences in
accounting and the lesser degree of accurate public information available.
Past performance is not indicative of future results. Investing in securities involves a
risk of loss that you, as a client, should be prepared to bear.
Item 9: Disciplinary Information
A. Criminal or Civil Actions
There are no criminal or civil actions to report.
B. Administrative Proceedings
There are no administrative proceedings to report.
C. Self-regulatory Organization (SRO) Proceedings
There are no self-regulatory organization proceedings to report.
Item 10: Other Financial Industry Activities and Affiliations
A. Registration as a Broker/Dealer or Broker/Dealer Representative
Neither AW nor its representatives are registered as, or have pending applications to
become, a broker/dealer or a representative of a broker/dealer.
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B. Registration as a Futures Commission Merchant, Commodity Pool
Operator, or a Commodity Trading Advisor
Neither AW nor its representatives are registered as or have pending applications to
become either a Futures Commission Merchant, Commodity Pool Operator, or
Commodity Trading Advisor or an associated person of the foregoing entities.
C. Registration Relationships Material to this Advisory Business and
Possible Conflicts of Interests
Steven Eric Ankerstar serves as a member of the Advisory Board of AdvizorStack, a
provider of technology platforms and operational support services to independent
registered investment advisers. In this role, Mr. Ankerstar provides strategic guidance and
industry input to AdvizorStack. This relationship may present a conflict of interest
because AdvizorStack offers services and technology solutions that AW could potentially
use in its operations or recommend to clients. AW’s selection and use of any third-party
technology platform or service provider, including AdvizorStack, is based solely on an
objective evaluation of factors such as functionality, pricing, reliability, security,
integration with existing systems, and overall benefit to clients. AW does not receive any
compensation, referral fees, or other economic benefit from AdvizorStack in connection
with client assets or referrals. No client is obligated to use AdvizorStack or any particular
technology platform or service provider.
D. Selection of Other Advisers or Managers and How This Adviser is
Compensated for Those Selections
For client accounts participating in one or more of AW's sub-advisory programs, AW
selects and utilizes the following unaffiliated, SEC-registered investment advisers as
discretionary sub-advisers: 55I, LLC ("55ip"), Charles Schwab Investment Management's
Direct Indexing SPI program ("Schwab Direct Indexing"), and Legacy Investment
Solutions, LLC, doing business as Ancorato ("Ancorato"). AW may utilize one or more
investment strategies offered by Ancorato for client accounts, depending on individual
client circumstances. For all other client accounts, assets continue to be managed directly
by AW.
AW receives an economic benefit in connection with its selection and use of 55ip as
described in Item 14 below. AW receives no compensation from Schwab Direct Indexing
or Ancorato in connection with its selection and use of those sub-advisers or any of their
strategies.
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Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
A. Code of Ethics
AW has a written Code of Ethics that covers the following areas: Prohibited Purchases and
Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions,
Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality,
Service on a Board of Directors, Compliance Procedures, Compliance with Laws and
Regulations, Procedures and Reporting, Certification of Compliance, Reporting
Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual
Review, and Sanctions. AW's Code of Ethics is available free upon request to any client or
prospective client.
B. Recommendations Involving Material Financial Interests
AW does not recommend that clients buy or sell any security in which a related person to
AW or AW has a material financial interest. If a security falls under this category , the
CCO will publish this security on a “no trade” list using the CCO read file which will be
acknowledged by all AW personnel.
C. Investing Personal Money in the Same Securities as Clients
Representatives of AW, from time to time, purchase or hold securities or other
investments that are also recommended to advisory clients. This creates a potential
conflict of interest because a related person may have a personal financial interest in
securities or investment themes that are also considered for client portfolios.
The Firm employs a thematic investment approach in evaluating investment
opportunities and constructing portfolios. The Firm's investment professionals may
personally invest in securities that are consistent with these investment themes and
research views. Examples of the Firm's high-conviction investment themes include:
•Drones and Modern Warfare
• Space Technology
• Artificial Intelligence Infrastructure
• Quantum Computing
• Humanoid Robotics
• Cybersecurity
• Digital Assets, including Bitcoin
These themes represent areas that the Firm believes may provide attractive long-term
investment opportunities and may influence investment research, portfolio construction,
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and recommendations. However, the Firm does not recommend investments solely
based on a theme, and client recommendations are based on each client's individual
investment objectives, financial circumstances, risk tolerance, and investment profile.
The Firm manages potential conflicts arising from personal trading through its Code of
Ethics and Personal Securities Trading Policy, which are designed to ensure that client
interests are placed ahead of personal interests and that supervised persons comply with
applicable reporting, review, and monitoring requirements.
D. Trading Securities At/Around the Same Time as Clients’ Securities
From time to time, representatives of AW may buy or sell securities for themselves at or
around the same time as clients. This may provide an opportunity for representatives of
AW to buy or sell securities before or after recommending securities to clients resulting in
representatives profiting off the recommendations they provide to clients. Such
transactions may create a conflict of interest; however, AW will never engage in trading
that operates to the client’s disadvantage if representatives of AW buy or sell securities at
or around the same time as clients.
To avoid said conflicts of interest, AW defines a “Blackout Period” for IARs regarding
their trading. The “Blackout Period” will begin once an IAR transacts in a security on a
given trading day, defined as a full one-day cycle of pre-market trading through after-
market extended hours. Upon a transaction triggering a “Blackout Period,” the IAR will
not transact in the specific security for clients until the “Blackout Period” expires.
In effect, to respect this “Blackout Period: on a security-by-security basis, AW IARs will
always complete their personal transactions after client transactions during a trading day.
Item 12: Brokerage Practices
A. Factors Used to Select Custodians and/or Broker/Dealers
the market expertise and research access provided by
Custodians/broker-dealers will be recommended based on AW’s duty to seek “best
execution,” which is the obligation to seek execution of securities transactions for a client
on the most favorable terms for the client under the circumstances. Clients will not
necessarily pay the lowest commission or commission equivalent, and AW may also
consider
the broker
dealer/custodian, including but not limited to access to written research, oral
communication with analysts, admittance to research conferences and other resources
provided by the brokers that may aid in AW's research efforts. AW will never charge a
premium or commission on transactions, beyond the actual cost imposed by the broker
dealer/custodian.
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AW will require clients to use Charles Schwab & Co., Inc. Member FINRA/SIPC
(“Schwab”). Schwab is an independent and unaffiliated SEC-registered broker-dealer.
55ip Program Trade Execution
For client accounts participating in AW's tax-managed model/ETF program offered in
connection with 55I, LLC ("55ip") (the "Program"), trade execution, rebalancing, and tax-
management overlay trading is performed by 55ip acting as discretionary sub-adviser.
55ip executes trades for Program accounts through Client's existing account custodian;
AW does not select or recommend a different broker-dealer for Program accounts as a
result of Program participation, and Program participation does not change Client's
custodial relationship. 55ip's trade execution for Program accounts is therefore subject to
the same brokerage and custodial arrangements otherwise described in this Item 12.
1. Research and Other Soft-Dollar Benefits
AW does not participate in soft dollar arrangements and does not receive research,
products, or services in exchange for directing client brokerage transactions. AW does
not receive products or services that are paid for with client brokerage commissions
within the meaning of Section 28(e) of the Securities Exchange Act of 1934.
AW may receive customary products, services, and support made generally available
by custodians, including Schwab Advisor Services, to institutional advisory firms.
These services may include technology, educational resources, practice management
support, and other administrative services. These products and services are not
provided in exchange for client brokerage transactions or commissions and are not
considered soft dollar benefits
2. Brokerage for Client Referrals
AW receives no referrals from a broker-dealer or third party in exchange for using that
broker-dealer or third party.
3. Clients Directing Which Broker/Dealer/Custodian to Use
AW will require clients to use a specific broker-dealer to execute transactions. Not all
advisers require clients to use a particular broker-dealer.
B. Aggregating (Block) Trading for Multiple Client Accounts
If AW buys or sells the same securities on behalf of more than one client, it might, but
would be under no obligation to, aggregate or bunch, to the extent permitted by applicable
law and regulations, the securities to be purchased or sold for multiple clients in order to
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seek more favorable prices, lower brokerage commissions or more efficient execution. In
such case, AW would place an aggregate order with the broker on behalf of all such clients
in order to ensure fairness for all clients; provided, however, that trades would be
reviewed periodically to ensure that accounts are not systematically disadvantaged by
this policy. AW would determine the appropriate number of shares to place with brokers
and will select the appropriate brokers consistent with AW’s duty to seek best execution,
except for those accounts with specific brokerage direction (if any).
Item 13: Reviews of Accounts
A. Frequency and Nature of Periodic Reviews and Who Makes Those
Reviews
All client accounts, including accounts which utilize model portfolios for AW's advisory
services are provided on an ongoing basis by the assigned financial advisor and are
reviewed at least monthly by Steven Ankerstar, CCO with regard to clients’ respective
investment policies and risk tolerance levels. All accounts at AW are assigned to this
reviewer.
For all financial planning-only clients, all financial plans will be created by the assigned
financial advisor and are reviewed prior to delivery to the client by Steven Ankerstar,
CCO.
B. Factors That Will Trigger a Non-Periodic Review of Client Accounts
Reviews for all client accounts, including accounts which utilize model portfolios may be
triggered by material market, economic or political events, or by changes in client's
financial situations (such as retirement, termination of employment, physical move, or
inheritance).
With respect to financial plans, AW’s services will generally conclude upon delivery of
the financial plan.
C. Content and Frequency of Regular Reports Provided to Clients
The custodian or other qualified third party holding the client’s funds and securities will
send the client a confirmation of every securities transaction and a custodial statement at
least quarterly. AW also provides periodic statements to clients which state account
holdings and value of portfolio holdings. This will typically be provided on an annual
basis during the contract update period.
For financial planning-only clients, each client will receive the written financial plan upon
completion.
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Item 14: Client Referrals and Other Compensation
A. Economic Benefits Provided by Third Parties for Advice Rendered to
Clients (Includes Sales Awards or Other Prizes)
Charles Schwab & Co., Inc. Advisor Services provides AW with access to Charles Schwab
& Co., Inc. Advisor Services’ institutional trading and custody services, which are
typically not available to Charles Schwab & Co., Inc. Advisor Services retail investors.
These services generally are available to independent investment advisers on an
unsolicited basis, at no charge to them so long as a total of at least $10 million of the
adviser’s clients’ assets are maintained in accounts at Charles Schwab & Co., Inc. Advisor
Services. Charles Schwab & Co., Inc. Advisor Services includes brokerage services that are
related to the execution of securities transactions, custody, research, including that in the
form of advice, analyses and reports, and access to mutual funds and other investments
that are otherwise generally available only to institutional investors or would require a
significantly higher minimum initial investment. For AW client accounts maintained in
its custody, Charles Schwab & Co., Inc. Advisor Services generally does not charge
separately for custody services but is compensated by account holders through
commissions or other transaction-related or asset-based fees for securities trades that are
executed through Charles Schwab & Co., Inc. Advisor Services or that settle into Charles
Schwab & Co., Inc. Advisor Services accounts.
Charles Schwab & Co., Inc. Advisor Services also makes available to AW other products
and services that benefit AW but may not benefit its clients’ accounts. These benefits may
include national, regional or AW specific educational events organized and/or sponsored
by Charles Schwab & Co., Inc. Advisor Services. Other potential benefits may include
occasional business entertainment of personnel of AW by Charles Schwab & Co., Inc.
Advisor Services personnel, including meals, invitations to sporting events, including golf
tournaments, and other forms of entertainment, some of which may accompany
educational opportunities. Other of these products and services assist AW in managing
and administering clients’ accounts. These include software and other technology (and
related technological training) that provide access to client account data (such as trade
confirmations and account statements), facilitate trade execution (and allocation of
aggregated trade orders for multiple client accounts, if applicable), provide research,
pricing information and other market data, facilitate payment of AW’s fees from its clients’
accounts (if applicable), and assist with back-office training and support functions,
recordkeeping and client reporting. Many of these services generally may be used to
service all or some substantial number of AW’s accounts. Charles Schwab & Co., Inc.
Advisor Services also makes available to AW other services intended to help AW manage
and further develop its business enterprise. These services may include professional
compliance, legal and business consulting, publications and conferences on practice
management, information technology, business succession, regulatory compliance,
employee benefits providers, and human capital consultants, insurance and marketing. In
addition, Charles Schwab & Co., Inc. Advisor Services may make available, arrange
26
and/or pay vendors for these types of services rendered to AW by independent third
parties. Charles Schwab & Co., Inc. Advisor Services may discount or waive fees it would
otherwise charge for some of these services or pay all or a part of the fees of a third-party
providing these services to AW. AW is independently owned and operated and not
affiliated with Charles Schwab & Co., Inc. Advisor Services.
AW receives compensation from third-party investment platforms in connection with
making its proprietary investment models available through those platforms. This
compensation is described in greater detail in Item 5. AW does not receive compensation
for client referrals in connection with these arrangements.
AW receives an economic benefit from 55I, LLC ("55ip"), an unaffiliated sub-adviser, in
the form of a waiver of platform and/or sub-advisory fees that AW would otherwise be
required to pay in connection with the sub-advisory arrangement described in Item 4. This
fee waiver is conditioned on AW committing to place and maintain an agreed-upon level
of client assets in specified investment models and/or exchange-traded funds made
available through 55ip's platform.
This arrangement creates a conflict of interest: because AW's own cost of using the
platform is reduced or eliminated based on client asset placement, AW has a financial
incentive apart from its standard advisory fee to recommend the Program and the specific
models/ETFs required under it. This incentive could, in the absence of appropriate
safeguards, conflict with AW's duty to recommend investments that are in each client's
best interest. This benefit does not result in any additional fee or cost to clients beyond
AW's standard advisory fee described in Item 5.
B. Compensation to Non – Advisory Personnel for Client Referrals
AW does not compensate non-advisory personnel (solicitors/promoters) for client
referrals.
C. Employee Referrals
The Firm may pay bonuses or other compensation to supervised persons or employees
for referring prospective clients to the Firm. Such compensation is paid solely by the
Firm and does not result in any additional fee or cost to the client.
Item 15: Custody
When it deducts fees directly from client accounts at a selected custodian, AW will be deemed to
have limited custody of client’s assets and must have written authorization from the client to do
so. Clients will receive all account statements and billing invoices that are required in each
jurisdiction, and they should carefully review those statements for accuracy.
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Item 16: Investment Discretion
AW provides discretionary and non-discretionary investment advisory services to clients. The
Investment Advisory Contract established with each client sets forth the discretionary authority
for trading. Where investment discretion has been granted, AW generally manages the client’s
account and makes investment decisions without consultation with the client as to when the
securities are to be bought or sold for the account, the total amount of the securities to be
bought/sold, what securities to buy or sell, or the price per share. In some instances, AW’s
discretionary authority in making these determinations may be limited by conditions imposed
by a client (in investment guidelines or objectives, or client instructions otherwise provided to
AW. AW will also have discretionary authority to determine the broker or dealer to be used for
a purchase or sale of securities for a client's account. Clients may, but typically do not, impose
restrictions in investing in certain securities or types of securities in accordance with their values
or beliefs.
Item 17: Voting Client Securities (Proxy Voting)
AW will not ask for, nor accept voting authority for client securities. Clients will receive proxies
directly from the issuer of the security or the custodian. Clients should direct all proxy questions
to the issuer of the security.
AW has engaged a third‐party service provider, Chicago Clearing Corporation (CCC), to monitor
and file securities claims class action litigation paperwork with claims administrators on behalf
of the Firm’s clients. When a claim is settled and payments are awarded to Ankerstar Wealth
clients, it may be necessary to share client information, such as name and account number, with
CCC in connection with this service.
AW does not receive any fees or remuneration in connection with this service nor does it receive
any fees from the third‐party provider(s). CCC earns a fee based on a flat percentage of all claims
it collects on behalf of Ankerstar Wealth, LLC’s clients. This fee is collected and retained by CCC
out of the claims paid by the claim administrator. Clients may opt out of this service at any time.
If a client opts out, AW does not have an obligation to advise or take any action on behalf of a
client with regard to class action litigation involving investments held in or formerly held in a
clients account.
Item 18: Financial Information
A. Balance Sheet
AW neither requires nor solicits prepayment of more than $1,200 in fees per client, six
months or more in advance, and therefore is not required to include a balance sheet with
this brochure.
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B. Financial Conditions Reasonably Likely to Impair Ability to Meet
Contractual Commitments to Clients
Neither AW nor its management has any financial condition that is likely to reasonably
impair AW’s ability to meet contractual commitments to clients.
C. Bankruptcy Petitions in Previous Ten Years
AW has not been the subject of a bankruptcy petition in the last ten years.
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