Overview
- Headquarters
- Tumwater, WA
- Total Firm Assets
- $110 million
- Average High-Net-Worth Client Portfolio Size
- $2.6 million
Fee Structure
Primary Fee Schedule (ARMOUR WEALTH ADVISORS JUNE 2026)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $3,000,000 | 1.14% |
| $3,000,001 | $5,000,000 | 0.75% |
| $5,000,001 | and above | 0.50% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $11,400 | 1.14% |
| $5 million | $49,200 | 0.98% |
| $10 million | $74,200 | 0.74% |
| $50 million | $274,200 | 0.55% |
| $100 million | $524,200 | 0.52% |
Clients
- High-Net-Worth Share of Firm Assets
- 75.24%
- Number of High-Net-Worth Clients
- 32
- Total Client Accounts
- 306
- Discretionary Accounts
- 306
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Regulatory Filings
- SEC CRD Number
- 306171
Primary Brochure: ARMOUR WEALTH ADVISORS JUNE 2026 (2026-06-11)
View Document Text
Item 1: Cover Page for Part 2A of Form ADV
Investment Advisor Brochure
June 9, 2026
Armour Wealth Advisors, LLC
344 Cleveland Avenue SE, Suite B
Tumwater, WA 98501
CRD # 306171
This Form ADV Part 2A (“Brochure”) provides information about the qualifications and business
practices of Armour Wealth Advisors, LLC. If you have any questions about the contents of this
Brochure, please contact us at (360) 918-8291 or sam@armourwa.com. The information in this
Brochure has not been approved or verified by the United States Securities and Exchange
Commission (“SEC”) or by any state securities authority. Registration as an investment advisor
does not imply any certain level of skill or training.
Additional information about Armour Wealth Advisors, LLC is available on the SEC’s website at:
www.adviserinfo.sec.gov.
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Item 2. Material Changes
Since our annual update in February 2026, we have added details to Item 10 of this brochure
about out affiliate, Armour Inc., a firm offering trustee services and tax preparation services. We
encourage you to read this brochure in its entirety and contact us if you have any questions.
Clients will receive an annual summary of any material changes to this and subsequent
Brochures no later than 120 days after our year-end of December 31. At that time, we will offer
a copy of our most current Disclosure Brochure. We will also promptly provide ongoing
disclosure information about material changes as necessary.
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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 ............................................................................................................... 4
Item 5. Fees & Compensation ......................................................................................................... 6
Item 6. Performance-Based Fees and Side-by-Side Management ................................................. 9
Item 7. Types of Clients & Account Requirements ......................................................................... 9
Item 8. Methods of Analysis, Investment Strategies & Risk of Loss ............................................. 10
Item 9. Disciplinary Information ................................................................................................... 14
Item 10. Other Financial Industry Activities & Affiliations ........................................................... 15
Item 11. Code of Ethics, Participation or Interest in Client Transactions & Personal Trading ..... 15
Item 12. Brokerage Practices ........................................................................................................ 16
Item 13. Review of Accounts ........................................................................................................ 19
Item 14. Client Referrals & Other Compensation ......................................................................... 19
Item 15. Custody ........................................................................................................................... 20
Item 16. Investment Discretion .................................................................................................... 20
Item 17. Voting Client Securities................................................................................................... 20
Item 18. Financial Information ..................................................................................................... 21
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Item 4. Advisory Business
Description of our Advisory Firm
Armour Wealth Advisors, LLC (“Armour Wealth Advisors,” “we,” “our”, or “us”) is a Washington
State limited liability company established May 1, 2014. Effective January 1, 2020, Sam Armour,
CFP®, CPA, CIMA®, is the sole member and sole principal of the firm.
Types of Advisory Services We Offer
Armour Wealth Advisors offers comprehensive financial planning and investment advisory
services. Advisory services are based on our clients’ financial goals, risk tolerance and investment
experience.
Individual client portfolios will be constructed primarily with mutual funds and ETFs (Exchange
Traded Funds). Through our mutual fund and ETF selections, client portfolios are broadly
diversified across asset classes, including but not limited to: US Equities, International Equities,
Emerging Market Equities, Government Bonds, Corporate Bonds (both investment grade and
high yield), International Bonds, Emerging Market Bonds, Mortgage-backed Bonds, Inflation-
Protected Bonds, and REITS (Real Estate Investment Trusts).
Our primary investment philosophy is to help client avoid mistakes driven by emotions. We work
with clients to set up a disciplined investment program focused on (1) investing consistently and
prudently through all market conditions; and (2) encouraging clients to maintain adequate cash
reserves, or focus on building adequate cash, ideally to provide one to two years of liquidity
without having to sell investments.
As an investment advisor we are a fiduciary to all of our clients. When we recommend that you
rollover retirement assets or transfer existing retirement assets, such as a 401(k) or an IRA, to
our management, we have a conflict of interest. This is because we will generally earn additional
revenue when we manage more assets. In making the recommendation, however, we do so only
after determining that the recommendation is in your best interest. Further, in making any
recommendation to transfer or rollover retirement assets, we do so as a “fiduciary,” as that term
is defined in ERISA or the Internal Revenue Code, or both. We also acknowledge we are a fiduciary
under ERISA or the Internal Revenue Code with respect to our ongoing investment advisory
recommendations and discretionary asset management services, as described in the advisory
agreement we execute with you. To the extent we provide non-fiduciary services to you, those
will be described in the advisory agreement.
We provide portfolio management services on a discretionary basis.
Individual Client Needs and Client Ability to Impose Investment Restrictions
Advisory services are tailored to each client’s needs based on financial goals, but may also be
based on their environmental, social, and governance (ESG) considerations (also referred to as
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socially-responsible investing). Where ESG factors are important to the client, Armour Wealth
Advisors recommends a combination of ETFs and mutual funds that have been screened for ESG
criteria and which Armour Wealth Advisors believes also address fundamental investment
concerns, such as diversification, risk, and total return objectives. ESG restrictions limit the
investment options available and may result in lower overall returns than if the portfolio were
not subject to these limitations.
Although Armour Wealth Advisors has discretion over client accounts, clients may impose
reasonable restrictions on certain securities or sectors.
For each client, we conduct an initial interview and complete a data gathering questionnaire to
determine the client’s financial situation and investment objectives, and to give the client the
opportunity to understand Armour Wealth Advisors’ investment process and philosophy of client
management. We will make a reasonable effort to meet with each client at least annually to
confirm or update their suitability information. We also expect the client to notify Armour Wealth
Advisors at the time of any change that could impact your risk tolerance, investment objective,
and/or long- or short-term goals. Clients may contact us during normal business hours to discuss
their account, their financial situation, or emerging investment needs.
Participation in Wrap Fee Programs
Wrap Fee Programs usually involve a broker-dealer referring clients to third-party money
managers and charging one, all-inclusive, fee that covers brokerage commissions, as well as the
investment advisory fees for the primary investment advisor and any third-party managers.
We work with clients solely using what we call a “bundled fee,” though the disclosures you
received from the custodian, Charles Schwab & Co., Inc. (“Schwab”) may refer to the
arrangement as a “wrap fee.” Under this arrangement, clients pay a single fee to Armour Wealth
Advisors for our investment advisory services and we pay the custodian directly for any typical
transaction costs incurred in your account. Armour Wealth Advisors is the portfolio manager for
all assets and we do not share any portion of our advisory fees with any third party, including
Schwab. Currently Charles Schwab & Co. (“Schwab”) is our custodian and handles all trade
executions (see Item 12 of this brochure for additional details on Schwab and the related
brokerage practices).
Billing clients under a wrap fee or bundled arrangement presents conflicts of interest that are
important for clients to understand.
Assets Under Management
As of December 31, 2025, Armour Wealth Advisors managed assets of $110,366,065, all on a
discretionary basis.
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Item 5. Fees & Compensation
We are required to describe all forms of compensation we receive, as well as other costs clients
will incur, so that you will know how much you are charged for advisory services we provide, and
by whom clients are charged.
Financial planning services are offered to all of our clients as part of our overall advisory services;
we do not charge a separate or additional fee for financial planning services.
How We are Compensated for our Advisory Services
We charge a percentage of assets under management (“AUM”) on a tiered fee schedule. This
means we charge different rates on different asset levels. For fee calculation purposes all of the
client’s accounts under management at our firm are identified as part of client’s household are
included to determine the fee schedule. Such accounts are identified on an addendum to our
client advisory agreement.
Our annual fee is billed quarterly in advance according to the following fee schedule:
AUM
First $3 million
Next $2 million
Over $5 million
Annual Fee
1.14%
0.75%
0.50%
The client does not pay additional fees for typical transactions through our custodian, Charles
Schwab, as those fees are borne by Armour.
Our wrap/bundled fee takes into consideration the transaction fees we pay to Schwab. As
discussed in more detail below, this fee arrangement is not appropriate for all accounts,
especially when trading volume is very low. We offer only the wrap/bundled fee option, which
means that separation of the costs is not an option in working with us. See Item 12 of this
brochure for more information about the Schwab platform and the services they provide to
Armour and our clients.
Fees for our advisory services are negotiable, but the transaction fees we pay to Schwab are not
negotiable. If fees clients pay to us are reduced through negotiation below the annual rate
detailed above, Schwab will continue to receive the agreed-on transaction charges and Armour
Wealth Advisors’ net income would decline. Similarly, if we obtain better pricing from Schwab
but don’t decrease advisory fees, that increases our net income. We have a financial incentive to
negotiate our fees for service, as well as rates paid to vendors, in a manner designed to increase
our profitability. We mitigate the conflict by disclosing it and by stating that other advisers offer
different billing approaches that may result in lower overall costs.
The practice of bundling our advisory fees with Schwab’s transaction costs may cost clients more
or less than purchasing our investment advice and Schwab’s brokerage services separately. The
relative cost of the bundled fee to clients is influenced by various factors, including the cost of
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our investment advice and Schwab’s brokerage services if purchased separately, the types of
investments held in the account, and the frequency and size of trades we make for the account.
For example, if the number of transactions in an account is low enough, the bundled fee paid
may exceed the stand-alone investment advisory fee and separate brokerage commissions that
the client would otherwise have paid. In addition, because we are charged only for certain
transactions, with certain mutual funds the most expensive trades, we have a financial incentive
to minimize trading or to trade in those securities that result in the lowest cost to us. At the same
time, our portfolios are constructed with mutual funds and ETFs and we therefore have a
significant philosophical and operational commitment in continuing to use those securities. We
believe that helps mitigate the conflict, in addition to our disclosures and our obligation to act in
accordance with our fiduciary duty, and not based on the compensation we receive. In general,
a bundled/wrap arrangement based on trades benefits clients who have higher trade volumes
and/or trade in securities that are generally more costly to execute. It is likely more expensive
for clients who don’t trade much or whose portfolios contain securities with zero or lost-cost
commissions.
Armour Wealth Advisors does not offer advisory services on a stand-alone, unbundled basis.
We do not recommend alternative investments. In the event a client brings in an existing, illiquid
position, we neither manage that asset, nor charge a fee on that asset. This will be documented
on your advisory agreement with us.
How We Charge Clients
Fees are deducted quarterly, in advance, directly from client accounts at the beginning of each
calendar quarter. The fee is equal to the previous quarter-end market values of all managed
assets in the client’s account(s) at the close of trading on the last business day of the prior
calendar quarter, multiplied by one-fourth of the annual fee. The initial fee for new accounts will
be based on the opening account value and will be adjusted on a pro rata basis to cover the
period from the date the account is opened through the end of the calendar quarter.
Advisory fees are deducted directly from the client’s account, agreed to in our investment
advisory agreement and your custodial account opening paperwork.
Investment management services will continue until either party terminates the investment
advisory by written notice. If a client provides us with verbal notice of termination, we will
capture that in writing to provide to the client. We will not provide advisory services under our
client Agreement as of the earlier of the effective date of the client’s notice of termination to us
or when our access is revoked by the custodian as a result of the client’s actions. If the Agreement
terminates on any date other than the last day of a calendar quarter, the fee previously paid with
respect to that calendar quarter will be prorated based on the number of days the account was
open during the billing period and Advisor will promptly refund to client any portion relating to
full days remaining in the calendar quarter.
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Neither Armour Wealth Advisors nor its IARs accept any compensation for the sale of securities
or other investment products, including asset-based sales charges or services fees from the sale
of mutual funds.
Fees We Pay Schwab
In addition to compensating us for our portfolio management, other investment advisory, and
other services to clients, the bundled fees clients pay us also allow us to pay Schwab for the
brokerage services it provides to our clients, as described above, as well as additional services
Schwab provides us, as described below. We pay Schwab transaction-based fees assessed in
each of our clients’ accounts that are maintained at Schwab.
In addition to the transaction-based fee described above, we pay Schwab certain other fees that
it would otherwise charge to clients, which at this time include short-term redemption fees on
mutual funds available through Schwab’s Mutual Fund OneSource®.
The fees we pay Schwab may be more than what we would pay solely for Schwab’s brokerage
services. More detail on this arrangement appears below under “Additional Compensation We
Receive.”
Additional Compensation We Receive.
Our relationship with Schwab is significant to our business and provides important benefits, some
of which benefit clients and others which benefit only or primarily Armour Wealth Advisors. The
benefits we obtain from Schwab influence our selection of Schwab as custodian. See Section 12,
Brokerage Practices, for more information.
investment advisory services and Schwab’s
We may receive more compensation from clients’ participation in this bundled fee approach than
(or another
if clients purchased our
broker/custodian’s) services separately. Consequently, we may have an incentive to recommend
that clients utilize the bundled fee option and open their accounts with Schwab. This creates a
conflict of interest. We believe, however, that our recommendation of Schwab and using a
bundled fee, including the use of Schwab as custodian and broker, is in the best interests of those
clients to whom we recommend it based on an assessment of their investment objectives,
financial situation, our investment plans and anticipated trading activity in their accounts and all
other relevant factors.
Other Types of Fees or Expenses Clients May Pay
Because we work on an all-inclusive bundled platform with clients, there are no transaction
charges (commissions) assessed by the custodian, and the custodian does not charge other
custodial fees, such as account maintenance fees. The custodian may charge for other services
such as wire transfers and account transfer fees.
Mutual funds and ETFs include management fees as part of their expense structures. These fees
are built into the price of mutual funds and ETFs. We do not recommend mutual funds with
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“loads” (commissions payable to brokers and included in the price of the fund) or trails (ongoing
asset service charges payable to a broker).
Our bundled fee does not cover the fees and costs listed below, which may apply to assets in
client accounts to which our bundled fee also applies, and to transactions in those accounts.
•
• Commissions and other fees for services provided by broker-dealers other than
Schwab for transactions executed or effected by or through them that settle into or
from Armour Wealth Advisors’ client accounts at Schwab such as through use of
Schwab’s Prime Brokerage or Trade Away Services. We do not use these services in
the normal course of business but could use them upon client request. Clients will be
responsible for paying any commissions and other fees or compensation charged by
broker-dealers other than Schwab. Because clients will pay our bundled fee in
addition to any commissions and/or other charges paid to broker-dealers other than
Schwab who execute transactions for client accounts, we have an incentive to execute
transactions for client accounts through Schwab.
Fees charged by mutual fund companies, unit investment trusts (UITs), closed-end
funds and other collective investment vehicles, including, but not limited to, sales
loads (a portion of which are paid to Schwab) and/or charges and short-term
redemption fees.
• Markups and markdowns, bid-ask spreads, selling concessions and the like received
by Schwab in connection with transactions it executes as principal by selling or buying
securities to or from clients for its own account. Principal transactions contrast with
those in which Schwab acts as the client’s agent in effecting trades between the client
and a third party. Schwab may make a profit or incur a loss on trades in which it acts
as principal. Markups and markdowns and bid-ask spreads are not separate fees, but
rather are reflected in the net price at which a trade order is executed.
• Costs imposed by third parties, such as transfer taxes, odd-lot differentials, certificate
•
delivery fees, reorganization fees, and any other fees required by law
Schwab may also charge for additional services such as wire transfer fees and custody
fees for alternative investments.
A complete list of Schwab’s charges and fees is contained in their account-opening paperwork.
Item 6. Performance-Based Fees and Side-by-Side Management
We do not charge any performance-based fees. This item does not apply to our business.
Item 7. Types of Clients & Account Requirements
We provide advisory services to individuals, trusts, estates, and other business entities. There is
no account size minimum. As discussed in our responses to Item 4 and Item 12, as a practical
matter, clients are required to open their accounts with Schwab to permit bundled fee billing.
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Item 8. Methods of Analysis, Investment Strategies & Risk of Loss
Approach and Primary Risks
Investing in securities involves risk of loss that clients should be prepared to bear.
Though our objective is to construct portfolios with less risk of large drops from peak prices to
the lowest prices, there is risk in all investments. There is no guarantee that the investment
strategy we select for the client will result in the client’s goals being met, nor is there any
guarantee of profit or protection from loss.
Our investment process is built on a foundation of three core beliefs:
Traditional investment markets are largely efficient most of the time and securities are
therefore usually accurately priced. This means we don’t attempt to “beat the market”
through market timing, but we do pay attention to our allocations and to the relative risk
of different asset classes.
Valuations exhibit mean reversion over longer time horizons. This means that a security’s
high and low prices are usually anomalies and that prices will tend to return to an
“average” price over time, although the specific timing of transitions is impossible to
forecast.
It is important to establish a disciplined process of ongoing investment and portfolio
rebalancing.
Performance Objectives
The risk-return objectives of Armour Wealth Advisors’ investment strategies are not geared
toward any traditional formula of volatility and performance. This is simply because we cannot
predict the circumstances we will be faced with in the future, so it would be arbitrary to select
these targets in advance. We will, however, seek a robust return in light of our judgment of what
prudent risk management requires at the time. We will favor capital preservation (avoiding loss)
over return-seeking (increasing gains). The primary risk of this approach is that it is highly
dependent on our ongoing capacity to accurately assess and appropriately respond to changing
conditions. It also assumes an ability to maintain consistent application of underlying behavioral
principles in all manner of market conditions. This may be more difficult to do when the firm is
not relying on a pre-determined set of metrics to guide our decision-making.
“Robust Return”
Through selection of a “core” portfolio of traditional asset classes we will seek to efficiently
capture risk premium (the potential reward investors hope to achieve by putting their money at
risk) in a thoughtful way. We will attempt to add value by taking advantage of the tendency for
markets to be mean-reverting and to exhibit boom-and-bust cycles. The primary risk of this
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approach is that we misjudge the length or pattern of the cycle and expose client portfolios to
extended periods of under-performance.
Risk Management
We seek to be diligent and creative in defining the myriad states of the world that our portfolios
may be exposed to and intend to construct portfolios that are built to survive. We will seek to
manage risk through, among other things: diversification, position size controls, and diligent
study of valuations, and portfolio hedging.
Research
Our process begins by developing, researching, and vetting views on investment approaches,
environments, and styles. This process guides our research and allocation choices. Once we have
established our sense of the relative risk and reward of different combinations of asset classes,
we try to identify the most efficient ways to get the desired asset class exposure in the portfolio.
We use a variety of research models and methods and employ both qualitative and quantitative
analysis. We derive information from a wide variety of sources, including without limitation,
securities information services, reporting by fund managers, manager interviews and due
diligence, periodicals, trade journals, research reports, and industry contacts.
Our research methods and their general associated risks include:
Fundamental Research, which is analysis of industries and companies based on factors such as
sales, assets, earnings, products and services, markets and management. Fundamental analysis
of economic trends includes interest rates, unemployment, inventories, consumer savings and
gross national products(s). The risk of fundamental analysis is that information obtained may be
incorrect and the analysis may not provide an accurate estimate of earnings, which may be the
basis for a stock’s value. If securities prices adjust rapidly to new information, utilizing
fundamental analysis may not result in favorable performance.
Charting, which is the graphic tracking of price movements and other trends to determine typical
movement and to identify historical peaks and troughs, as well as obtain information about
average prices. The risk of chart analysis is that it may not accurately predict future price
movements. Current prices of securities may reflect all information known about the security
and day-to-day changes in the market prices of securities may follow random patterns and may
not be predictable with any reliable degree of accuracy.
Cyclical Analysis, which reviews securities in industries that are particularly sensitive to swings in
general economic conditions. Economic/business cycles may not be predictable and may have
many fluctuations between long-term expansions and contractions. The lengths of economic
cycles may be difficult to predict with accuracy and therefore the risk of cyclical analysis is the
difficulty in predicting economic trends and consequently the changing value of securities that
would be affected by these changing trends.
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Asset Allocation, which is an attempt to identify an appropriate ratio of securities and cash
suitable to the client’s investment goals and risk tolerance. A risk of asset allocation is that the
client may not participate in sharp increases in a particular security, industry or market sector.
Another risk is that the ratio of securities, fixed income, and cash will change over time due to
stock and market movements and, if not corrected, will no longer be appropriate for the client’s
goals.
Risks Associated with Investing
We attempt to add value over the long-term by exposing client assets to a broadly diversified
basket of asset classes, increasing and decreasing exposures based on valuation. There is no
guarantee we will be right and achieve our objective of producing a low-volatility return series
with low drawdowns. While we may purchase individual stocks and bonds for clients, in most
cases we invest in ETFs or mutual funds to obtain exposure to equities, fixed-income markets,
foreign securities, commodities, natural resources, and other asset classes. Some of the risks
described below will therefore apply to underlying assets of a specific ETF or mutual fund.
While losses can and will occur, we generally recommend a broad and diversified allocation of
securities, thereby reducing specific risks associated with a concentrated or undiversified
portfolio. Below are some of the risks present with investing generally, as well as some key risks
of different types of investments. In general, investing in securities with concentrated exposures
to (i) particular asset class(es) and/or (ii) a particular sector and/or (iii) one or a select few markets
involves greater risk than investing in investments that have greater diversification. The following
is a list of risk factors more common in the investments we recommend for our clients. This list
is not exhaustive. All investments involve the risk of loss of principal which you should be
prepared to bear.
Common Stocks and Equity-Related Securities. Prices of common stock react to the economic
conditions of the company that issued the security, industry and market conditions, as well as
other factors, and may fluctuate widely. Investments related to the value of stocks may rise and
fall based on an issuer’s actual and anticipated earnings, changes in management, the potential
for takeovers and acquisitions, and other economic factors. Similarly the value of other equity-
related securities, including preferred stock, warrants and options may also vary widely.
Fixed-Income Securities. Prices of fixed income instruments (e.g., bonds) can exhibit some
volatility and change daily. Investments in fixed income instruments present numerous risks,
including credit, interest rate, reinvestment and prepayment risk, all of which affect the price of
the instruments. For instance, a rise in interest rates will generally cause the price of bonds to go
down. If the security is held to maturity and the issuer does not default, the client should receive
the face amount of the bond at the maturity date, as well as stated interest payments while the
bond is held. In this case, the change in price prior to maturity may not affect the client. If the
client needs to sell prior to maturity, however, the investor would likely experience a loss. Where
a client’s fixed income exposure is to bond funds or fixed-income ETFs, the fund or ETF does not
itself “mature,” although different issues held by the fund/ETF will mature and will experience
price fluctuations. Investors are therefore highly dependent on the manager’s ability to
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accurately anticipate the impact of rate changes and to appropriately manage the portfolio to
achieve both adequate returns and reasonable risk. The US has experienced a prolonged period
of historically low interest rates; future increases in rates could have a material negative impact
on the value of current fixed income holdings. In addition, the value of fixed income instruments
may decline in response to events affecting the issuer, its credit rating or any underlying assets
backing the instruments.
Mutual Funds. These are professionally-managed investments that pool money from multiple
investors to purchase securities. Mutual funds may be broad-based (e.g., focused on the market
overall, or focused on large-capitalization companies), or they can be narrower in scope, such as
those focused on the technology industry or the securities of specific country. The risks of mutual
funds are generally connected to the risks of the underlying securities they hold. Mutual funds
do not trade on an exchange but are priced daily based on the net asset value of the securities
held in the fund. Investors buy or sell fund shares based on that end-of-day price.
Exchange Traded Funds. Exchange-traded funds (“ETFs”) are funds bought and sold on a
securities exchange that attempt to track the performance of a specific index (such as the S&P
500), a commodity, or a basket of assets (such as a set of technology-focused, country-specific,
or other sector-specific stocks). The risks of owning an ETF generally reflect the risks of owning
the underlying securities they are designed to track, although lack of liquidity in an ETF could
result in its being more volatile than the underlying securities. ETFs have management fees that
increase their costs. ETFs are also subject to other risks, including: (i) the risk that their prices
may not correlate perfectly with changes in the underlying index; and (ii) the risk of possible
trading halts due to market conditions or other reasons that, in the view of the exchange upon
which an ETF trades, would make trading in the ETF inadvisable.
Small- and Mid-Cap Risks. Securities of small-cap issuers may present greater risks than those of
large-cap issuers. For example, some small- and mid-cap issuers often have limited product lines,
markets, or financial resources. They may be subject to high volatility in revenues, expenses and
earnings. Their securities may be thinly traded, may be followed by fewer investment research
analysts and may be subject to wider price swings and thus may create a greater chance of loss
than when investing in securities of larger-cap issuers. The market prices of securities of small-
and mid-cap issuers generally are more sensitive to changes in earnings expectations, to
corporate developments and to market rumors than are the market prices of large-cap issuers.
High Yield Securities. High-Yield securities, by definition, provide a higher return than other
similar securities and therefore entail more risk. This relationship between potential risk and
potential reward is fundamental to investing. For example, high-yield bonds purchased at a
significant discount from their face value may be at greater risk of default than other bonds with
a lower stated interest rate or a lower yield-to-maturity. High-yield fixed income instruments
(some of which may be referred to as “junk bonds”) should be considered speculative and
investors should understand they pose a greater risk of default and price change than investment
grade fixed income instruments. Prices of high-yield instruments are especially sensitive to
developments affecting the issuer’s business and to changes in the ratings assigned to the issuer
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by rating agencies. High-yield instruments can experience sudden and sharp price swings due to
changes in economic conditions, stock market activity, sales by major investors, default,
perceived creditworthiness or other factors. The secondary market for high-yield fixed income
instruments may be less liquid than the market for investment grade instruments, and a client’s
account may be unable to sell illiquid high-yield instruments at an advantageous time or price. In
all cases, developments in the credit markets may adversely affect fixed income instruments held
in a client’s account and could result in substantial losses. An event of default by an issuer may
result in the issuer’s fixed income instruments being worthless.
Inflation Risk. When inflation is present, a dollar today will not buy as much as a dollar next year,
because purchasing power is eroding at the rate of inflation. This affects all investments, but
longer-term fixed income securities are particularly susceptible.
Limited Diversification. Investments may be primarily focused geographically in North American
countries. Furthermore, broad diversification of investments in number or by industry or
geography is not a primary investment of Armour Wealth Advisors. This limited diversity could
expose clients to losses disproportionate to market movements in general if there are
disproportionately greater adverse price movements in those investments.
Non-U.S. Securities. Investments in securities of non-U.S. issuers pose a range of potential risks
which could include expropriation, confiscatory taxation, imposition of withholding or other
taxes on dividends, interest, capital gains or other income, political or social instability, illiquidity,
price volatility and market manipulation. In addition, less information may be available regarding
securities of non-U.S. issuers, and non-U.S. issuers may not be subject to accounting, auditing
and financial reporting standards and requirements comparable to or as uniform as those of U.S.
issuers.
Emerging Markets. In addition to the risks associated with investments outside of the United
States, investments in emerging markets (i.e., the developing countries) may involve additional
risks. Emerging markets generally are not as efficient as those in developed countries. In some
cases, a market for the security may not exist locally, and transactions will need to be made on a
neighboring exchange. Volume and liquidity levels in emerging markets are lower than in
developed countries. When seeking to sell emerging market securities, little or no market may
exist for the securities. In addition, issuers based in emerging markets are not generally subject
to uniform accounting and financial reporting standards, practices and requirements comparable
to those applicable to issuers based in developed countries, thereby potentially increasing the
risk of fraud or other deceptive practices.
Item 9. Disciplinary Information
We are required to disclose whether there are legal or disciplinary events that are material to a
client’s or prospective client’s evaluation of our advisory business or the integrity of our
management. We do not have anything to disclose in this regard.
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Item 10. Other Financial Industry Activities & Affiliations
Neither Armour Wealth Advisors nor its associates are registered, or have a pending registration,
with another investment adviser, broker-dealer, or are otherwise engaged in other financial
industry activities.
Our owner, Sam Armour, owns another company, Armour Inc., an affiliate through shared
ownership. Armour Inc. offers trustee services and tax preparation services. While Armour Inc.’s
trustee services are not offered to our advisory clients, tax preparation services may be offered
to our advisory clients.
Additional information about our IARs, including details of their outside business activities, can
be found in each IAR’s respective Form ADV Part 2B Brochure Supplement.
Item 11. Code of Ethics, Participation or Interest in Client Transactions &
Personal Trading
We have adopted a Code of Ethics (the “Code”) that describes the standards of conduct expected
of advisory personnel; requires compliance with applicable laws and regulations; and addresses
conflicts that arise from personal trading by advisory personnel. We will provide a copy of our
Code of Ethics at no cost to current and prospective clients upon request.
The firm also subscribes to the code of ethics promulgated by the Certified Financial Planner
Board of Standards. This organization oversees the CFP® and creates ongoing standards for
certification, professional development, and ethical behavior.
If our firm or a related person invests in the same securities (or related securities, e.g., warrants,
options or futures) that our firm or a related person recommends to clients, we are required to
describe our practice and discuss the conflicts of interest this presents and generally how we
address the conflicts that arise in connection with personal trading.
At times Armour Wealth Advisors and/or its employees may take positions in the same securities
as clients, and we will try to avoid conflicts with clients. The firm and its employees will generally
be “last in” and “last out” for the trading day when trading occurs in close proximity to client
trades. We will not violate our fiduciary responsibilities to our clients. Front-running (trading
shortly ahead of clients) is prohibited.
Neither Armour Wealth Advisors nor its employees recommends to clients, or buys or sells for
client accounts, any securities in which the firm or its related persons has a material financial
interest.
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Item 12. Brokerage Practices
The Custodian and Brokers We Use
We do not maintain custody of client assets that we manage, although we are deemed to have
custody if clients give us authority to withdraw fees or pay funds to a third party from their
accounts (see Item 15. Custody section, below).
Client assets must be maintained in an account at a “qualified custodian,” generally a broker-
dealer or bank. We require that our clients use Charles Schwab & Co., Inc. (“Schwab”), a
registered broker-dealer, member SIPC, as the qualified custodian. Armour Wealth Advisors is
independently owned and operated and is not affiliated with Schwab. Schwab will hold client
assets in a brokerage account and buy and sell securities when Armour Wealth Advisors instructs
them to. While we require that you use Schwab as custodian/broker, you will decide whether to
do so and will open your account with Schwab by entering into an account agreement directly
with them. We do not open the account for you, although we assist you in doing so. If you do not
wish to place your assets with Schwab, then we cannot manage your account. Not all advisors
require their clients to use a particular broker-dealer or other custodian selected by the advisor.
Even though your account is maintained at Schwab, we can still use other brokers to execute
trades for your account as described below (see “Your brokerage and custody costs”).
Factors We Consider in Selecting or Recommending Broker-Dealers
We seek to use a custodian/broker that will hold your assets and execute transactions on terms
that are overall most advantageous when compared with other available providers and their
services. We consider a wide range of factors, including:
Combination of transaction execution services and asset custody services (generally without
a separate fee for custody)
Capability to execute, clear, and settle trades (buy and sell securities for your account)
Capability to facilitate transfers and payments to and from accounts (wire transfers, check
requests, bill payment, etc.)
Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded
funds (ETFs), etc.)
Availability of investment research and tools that assist us in making investment decisions
Quality of services
Competitiveness of the price of those services (commission rates, margin interest rates, other
fees, etc.) and willingness to negotiate the prices
Reputation, financial strength, security and stability
Prior service to us and our clients
Availability of other products and services that benefit us, as discussed below (see “Products
and services available to us from Schwab”)
Your Brokerage and Custody Costs
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Schwab generally does not charge separately for custody services but is compensated by charging
accounts commissions or other fees on trades that it executes or that settle into your Schwab
account. Certain trades (for example, many mutual funds and ETFs) may not incur Schwab
commissions or transaction fees. Schwab is also compensated by earning interest on the
uninvested cash in accounts in Schwab’s Cash Features Program. Our client accounts are charged
a percentage of the dollar amount of assets in the account in lieu of commissions, which Armour
Wealth Advisors pays on behalf of clients (see Item 5 of this brochure for discussion of our
bundled fee).
The availability of Schwab’s services benefits Armour Wealth Advisors because we do not have
to produce or purchase them. These benefits give Armour Wealth Advisors an incentive to
require that clients maintain their accounts with Schwab based on our interest in receiving
Schwab’s and the third parties’ services that benefit our business rather than based on clients’
interests in receiving the best value in custody services and the most favorable execution of their
transactions. This creates a conflict of interest. We believe, however, that our selection of
Schwab as custodian and broker is in the best interests of our clients. It is primarily supported by
the scope, quality and price of Schwab’s services and not Schwab’s or third parties’ services that
benefit only Armour Wealth Advisors or may only indirectly benefit our clients.
Products and Services Available to Us from Schwab
Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms
like Armour Wealth Advisors. They provide us and our clients with access to its institutional
brokerage – trading, custody, reporting and related services – many of which are not typically
available to Schwab retail customers. Schwab also makes available various support services.
Some of those services help us manage or administer our clients’ accounts while others help us
manage and grow our business. Schwab’s support services described below are generally
available on an unsolicited basis (we don’t have to request them) and at no charge to us. Here is
a more detailed description of Schwab’s support services:
Services that Benefit Clients Directly. Schwab’s institutional brokerage services include
access to a broad range of investment products, execution of securities transactions, and
custody of client assets. The investment products available through Schwab include some
to which we might not otherwise have access or that would require a significantly higher
minimum initial investment by our clients. Schwab’s services described in this paragraph
generally benefit each client and each client account.
Services that May Not Directly Benefit Clients. Schwab also makes available to us other
products and services that benefit us but may not directly benefit a specific client or client
account. These products and services assist us in managing and administering our clients’
accounts. They include investment research, both Schwab’s own and that of third parties.
We may use this research to service all or some substantial number of our clients’
accounts. In addition to investment research, Schwab also makes available software and
other technology that:
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Provide access to client account data (such as duplicate trade confirmations and
account statements);
Facilitate trade execution and allocate aggregated trade orders for multiple
client accounts;
Provide pricing and other market data;
Facilitate payment of our fees from our clients’ accounts; and
Assist with back-office functions, recordkeeping and client reporting.
Services that Generally Benefit Only Us. Schwab also offers other services intended to
help us manage and further develop our business enterprise. These services include:
Educational conferences and events
Technology, compliance, legal, and business needs;
Publications and conferences on practice management and business succession;
and
Access to employee benefits providers, human capital consultants and
insurance providers.
Schwab may provide some of these services itself. In other cases, it will arrange for third-
party vendors to provide the services to us. 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 us with other benefits such as occasional business entertainment of our
personnel. We do not currently use consulting services provided by Schwab but do take
part in educational conferences and events, and use publications provided on practice
management. We will review the availability of benefit providers and other services
offered as we continue to operate and may make use of other opportunities in the future.
Our Interest in Schwab’s Services
The availability of the services described above from Schwab benefits us because we do not have
to produce or purchase them. We don’t have to pay for these Schwab’s services, and they are
not contingent upon us committing any specific amount of business to Schwab in trading
commissions or assets in custody. Separately, however, Schwab has also agreed to pay up to
$50,000 we would otherwise incur for technology, marketing and consulting products and
services once the value of our clients’ assets in accounts at Schwab reaches $120 Million.
Consequently, we may have an incentive to require that clients maintain their accounts with
Schwab based on our interest in receiving Schwab’s and services that benefit our business rather
than based on clients’ interest in receiving the best value in custody services and the most
favorable execution of their transactions. This is a potential conflict of interest. We believe,
however, that our selection of Schwab as custodian and broker is in the best interests of our
clients. It is primarily supported by the scope, quality and price of Schwab’s services and not
Schwab’s services and Schwab’s payment for third party services that benefit only us.
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Brokerage for Client Referrals
Client referrals are not a consideration for us in recommending brokers.
Directed Brokerage
Because the firm offers services solely through a bundled fee through Schwab, however, as a
practical matter Armour Wealth Advisors does not facilitate the use of directed brokerage
because all transactions will be executed through Schwab.
Aggregation of Client Orders
We do not typically aggregate client orders because our portfolio management focuses
primarily on mutual funds and ETFs, pricing of which does not generally benefit from batching
(or “blocking”) multiple client orders into a single order.
Item 13. Review of Accounts
We monitor individual investments on an ongoing basis and may make adjustments to client
portfolios as we determine is appropriate in light of individual client needs and objectives.
Individual client portfolios are reviewed on a quarterly basis at a minimum. In-person portfolio
and plan reviews are available on request. On-going client account reviews are conducted by the
advisory representative working with the client with additional oversight by Sam Amour,
Managing Member & Chief Compliance Officer.
In situations where Armour Wealth Advisors is overseeing client assets that reside in outside
investment programs (e.g., 529 Savings plans), those accounts are reviewed at a minimum of
once per quarter. Market conditions that might cause a wide variance in the specified asset
allocation, or other factors could cause a more frequent review.
Clients receive statements at least quarterly directly from their qualified custodian(s). Armour
Wealth Advisors provides quarterly performance reports to clients which are created through a
third-party software. These reports show performance at the client’s household level and by
account. Performance is reflected from both inception and YTD and is net of fees. We urge
clients to compare the statements the receive from their qualified custodian with any reports
we provide to them.
Item 14. Client Referrals & Other Compensation
We receive an economic benefit from Schwab in the form of the support products and services
it makes available to us and to other independent investment advisors that have their clients
maintain accounts at Schwab. These products and services, how they benefit us, and the related
conflicts of interest are described more fully in Item 12, Brokerage Practices. The availability to
Armour Wealth Advisors of Schwab’s products and services is not based on our giving particular
investment advice, such as buying particular securities for our clients.
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We do not receive compensation for client referrals from any entity outside of our firm, nor do
we compensate anyone outside of our firm for referring clients.
Item 15. Custody
Although client assets are held at a third-party independent custodian (typically Schwab), we are
deemed to have custody of client funds when our clients have with standing letters of
authorization (SLOA) on file with Schwab to move funds to a third party without obtaining written
authorization each time.
When a client signs an SLOA through their custodian, it authorizes us to send money to a third
party on your behalf without requiring a signed letter of instruction each time. Schwab maintains
strict controls around our ability to withdraw funds through an SLOA, which means we are not
able to access your funds beyond your instruction concerning to whom and how those funds are
transmitted. 100% of the details provided in our ADV Part 1, Item 9 are related to custody for
SLOAs.
The client’s qualified custodian will send an account statement, at least quarterly, to each of its
clients for which the custodian maintains funds or securities, identifying the amount of funds and
of each security in the account at the end of the period and setting forth all transactions in the
account during that period. Account statements are sent directly to the client’s mailing address
provided to us on their Schwab account paperwork, or via email notification via the email address
the client provided if non-paper copies were elected. These custodial statements are the official
record of individual client accounts for tax and other recordkeeping purposes. We urge clients
to review these statements carefully and compare them with the fee billing statements received
from Armour Wealth Advisors. Clients should notify both Armour Wealth Advisors and the
custodian promptly of any discrepancies.
Item 16. Investment Discretion
We maintain full discretion under a limited power of attorney as to the securities and amount
of securities transacted on behalf of client accounts. Authority is granted when clients execute
our Investment Management Agreement with Limited Power of Attorney. We do not have
discretion to select a custodian on the client’s behalf or to establish accounts for clients.
Item 17. Voting Client Securities
Armour Wealth Advisors does not vote proxies for its individual clients. Clients will receive their
proxies and other solicitations directly from their custodian or transfer agent, not from Armour
Wealth Advisors.
If we elect to exercise voting authority over individual client proxies in the future, we will adopt
proxy voting policies and procedures and will appropriately amend this Brochure. Questions
about proxies may be made via the contact information on the cover page.
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Item 18. Financial Information
An investment advisor must disclose any financial condition likely to impair its ability to meet
contractual commitments, or if the firm has a bankruptcy within the past ten years. Armour
Wealth Advisors does not have anything to disclose. Armour Wealth Advisors does not require
prepayment of fees that equal $1,200 or greater and that are prepaid six months or more in
advance.
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