View Document Text
2829 Technology Forest Blvd, Suite 300
The Woodlands, TX 77381
Tel.: (281) 528-1200
Fax: (888) 868-1168
www.AvionWealth.com
February 2026
FORM ADV PART 2
BROCHURE
This brochure provides information about the qualifications and business practices of Avion Wealth. If
you have any questions about the contents of this brochure, please contact us at (281) 528-1200. 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 Avion Wealth
is also available on
the SEC's website at
Additional
www.adviserinfo.sec.gov. The searchable IARD/CRD number for Avion Wealth is 134242.
Registration with the United States Securities and Exchange Commission or any state securities authority
does not imply a certain level of skill or training.
Item 2 Material Changes
As a registered investment adviser, we must ensure that our brochure is current and
accurate and makes full disclosure of all material facts relating to the advisory
relationship. If there have been any material changes to our business or advisory practices
since our last annual update, we will provide a description of such material changes here.
Since our last annual updating amendment dated March 2025, we have made no material
changes to our brochure:
ii
Item 3 Table of Contents
FORM ADV PART 2 ............................................................................................................. i
BROCHURE ............................................................................................................................ i
Item 2 Material Changes ..................................................................................................... ii
Item 3 Table of Contents .................................................................................................... iii
Item 4 Advisory Business ..................................................................................................... 1
Item 5 Fees and Compensation ........................................................................................... 5
Item 6 Performance-Based Fees and Side-By-Side Management ................................ 6
Item 7 Types of Clients ......................................................................................................... 6
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ........................ 6
Item 9 Disciplinary Information ......................................................................................... 8
Item 10 Other Financial Industry Activities and Affiliations ....................................... 8
Item 11 Code of Ethics and Personal Trading .................................................................. 9
Item 12 Brokerage Practices ................................................................................................. 9
Item 13 Review of Accounts .............................................................................................. 13
Item 14 Client Referrals and Other Compensation ...................................................... 13
Item 15 Custody ................................................................................................................... 13
Item 16 Investment Discretion .......................................................................................... 14
Item 17 Voting Client Securities ....................................................................................... 14
Item 18 Financial Information ........................................................................................... 14
Paul James Carroll, CFP® .................................................................................................... 16
Elizabeth A. Brady, CFP® ................................................................................................... 19
Ashley Dominey Stewart, CFP® ........................................................................................ 22
Sarah E. McIvor, CFP® ........................................................................................................ 26
Megan Beaufays, CFP® ....................................................................................................... 30
Christopher J. McBee, CFP® ............................................................................................... 34
Ryan D. Hague ..................................................................................................................... 38
iii
Ashely Owens ...................................................................................................................... 40
Customer Information Privacy Principles ...................................................................... 44
BUSINESS CONTINUITY PLAN SUMMARY STATEMENT .................................. 47
iv
Item 4 Advisory Business
Avion Wealth, LLC is registered investment adviser based in The Woodlands, Texas. We
are organized as a limited liability company under the laws of the State of Texas. We have
been providing investment advisory services since 2005. The firm is owned by Paul
James Carroll, Managing Member, Chief Executive Officer and Chief Compliance Officer.
Our mission is to provide our clients with sensible and unbiased financial planning
solutions where the interests of our clients always come first. Our goal is to assist our
clients in prioritizing and qualifying their financial goals, setting realistic expectations
and implementing a disciplined and prudent investment and savings strategy to achieve
these goals.
The following paragraphs describe our services and fees. Please refer to the description
of each investment advisory service listed below for information on how we tailor our
advisory services to your individual needs. As used in this brochure, the words "we",
"our" and "us" refer to Avion Wealth and the words "you", "your" and "client" refer to you
as either a client or prospective client of our firm. Also, you may see the term Associated
Person throughout this brochure. As used in this brochure, our Associated Persons are
our firm's officers, employees, and all individuals providing investment advice on behalf
of our firm.
Investment Consulting
We provide discretionary portfolio management services to our clients. Our investment
advice is tailored to meet our clients' needs and investment objectives. If you retain our
firm for portfolio management services, we will meet with you to determine your
investment objectives, risk tolerance, and other relevant information (the "suitability
information") at the beginning of our advisory relationship. We will use the suitability
information we gather to develop a strategy that enables our firm to give you continuous
and focused investment advice and/or to make investments on your behalf. As part of
our portfolio management services, we will customize an investment portfolio for you in
accordance with your risk tolerance and investing objectives. Once we construct an
investment portfolio for you, we will monitor your portfolio's performance on an ongoing
basis, and will rebalance the portfolio as required by changes in market conditions and
in your financial circumstances.
If you participate in our discretionary portfolio management services, we require you to
grant our firm discretionary authority to manage your account. Discretionary
authorization will allow our firm to determine the specific securities, and the amount of
securities, to be purchased or sold for your account without your approval prior to each
transaction. Discretionary authority is typically granted by the investment advisory
agreement you sign with our firm, a limited power of attorney, or trading authorization
forms. You may limit our discretionary authority (for example, limiting the types of
securities that can be purchased for your account) by providing our firm with your
restrictions and guidelines in writing.
As part of this service, we will assist you in determining your investment
goals and objectives, risk tolerance, and retirement plan time horizon in order to create
1
an initial portfolio allocation designed to complement your educational, home
ownership, and retirement funds goals and objectives. The advisory representative will
then prepare an investment policy describing asset-class allocation recommendations
without detailing specific holdings.
Our investment strategy will focus primarily on a buy and hold approach
as opposed to short-term trading. Each portfolio will be initially designed to meet a
particular investment goal, which your advisory representative has determined to be
suitable for your circumstances. Once the appropriate portfolio has been determined,
your advisory representative will review the portfolio at least monthly and, if necessary,
rebalance your portfolio, based upon your individual needs and stated goals and
objectives. As our client, you will have the opportunity to place reasonable restrictions
on the types of investments to be held in your portfolio. Our strategy, generally,
will be to seek long term portfolio growth while providing you with access to the
personal advisory services of an advisory representative on at least an annual basis, or
more often, depending upon your specific agreement with your advisory representative.
Our advisory representatives will not attempt to manage short-term market fluctuations
with active trading (market-timing/allocation, etc.).
In our work with clients, we discuss the payout options for defined benefit, 401(k) and
other retirement plan types. When doing so, we may recommend that the client choose
a lump sum payout. This may be a conflict of interest if the client decides to place those
funds with us to be managed.
Our fee for portfolio management services is based on a percentage of your assets we
manage and is charged according to the following fee schedule:
Portfolio Value
Advisory Fee
$0 to $2,500,000
1%
$2,500,001 to $4,000,000
0.9%
$4,000,001 to $7,000,000
0.8%
$7,000,001 to $10,000,000
0.7%
$10,000,001 to $15,000,000
0.6%
$15,000,001 to $25,000,000
0.55%
$25,000,001 to $50,000,000
0.5%
$50,000,001 & Above
Negotiable
2
* Our minimum quarterly investment advisory fee for Portfolio Management Services is
$5,000. However, the minimum may be less, based on the assets to be managed, the
advisor, and the complexity of the client work. This is dicussed in advance with the client
and included in the agreement. Also, the minimum quarterly investment advisory fee is
$9,000 for the Complex Entrepreneur client.
* Any fee agreement made and/or amended will be valid for 24 months, regardless of any
subsequent amendments at the firm level within those 24 hours.
* Older client relationships may be subject to different fee schedules or minimum quarterly
fees.
*
If for any reason the client named in the Investment Advisory Agreement no longer wants
to continue services with Avion Wealth within the first 60 days after the Investment
Advisory Agreement signing date, the client will receive a full refund of any fees paid.
For all accounts the fee schedule is tiered, whereby fees are assessed a flat percentage
according to the corresponding portfolio value bracket.
The annual fee for investment management services provided are based upon a
percentage (%) of the market value of the Assets under management in accordance with
the fee schedule in the Agreement signed by the client. Avion Wealth considers cash to
be an asset class and part of Assets under management and subject to the same fee
calculation as the client’s non-cash investments.
At our discretion, we may assess lower than stated fees for existing accounts. We may
also combine the account values of family members living in the same household to
determine the applicable advisory fee. For example, we may combine account values for
you and your minor children, joint accounts with your spouse, and other types of related
accounts. Combining account values may increase the asset total, which may result in
your paying a reduced advisory fee based on the available breakpoints in our fee
schedule stated above.
Unless otherwise agreed upon in writing, the advisory fee is allocated among all
aggregated accounts and deducted in accordance with such allocation.
We may enter into arrangements with clients where we will manage retirement plan
assets on a discretionary basis. If you engage our firm for such services, we must adhere
to ERISA bonding requirements pursuant to ERISA Section 412 as well as any other
applicable ERISA requirements.
Our annual portfolio management fee is billed and payable quarterly in advance based
on the value of your account on the last day of the previous quarter. The initial fee is
payable when your account is established. If the portfolio management agreement is
executed at any time other than the first day of a calendar quarter, our fees will apply on
a pro rata basis, which means that the advisory fee is payable in proportion to the number
of days in the quarter for which you are a client. Additional deposits to your account
during a quarter are subject to the same fee procedures.
3
We will deduct our fee directly from your account through the qualified custodian
holding your funds and securities. We will deduct our advisory fee only when you have
given our firm written authorization permitting the fees to be paid directly from your
account. Further, the qualified custodian will deliver an account statement to you at least
quarterly. These account statements will show all disbursements from your account. You
should review all statements for accuracy. We will also receive a duplicate copy of your
account statements.
You may terminate the portfolio management agreement by providing written notice to
our firm. You will incur a pro rata charge for services rendered prior to the termination
of the agreement for services, which means you will incur advisory fees only in
proportion to the number of days in the quarter for which you are a client. If you have
pre-paid advisory fees that we have not yet earned, you will receive a prorated refund of
those fees.
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 interests 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.
Advanced Planning Services
We typically provide advanced financial planning services to you as part of our
investment advisory services. Services are provided in several areas depending on your
goals, objectives and financial situation.
Avion has developed a structured process to help organize and manage the details of
your complex affairs, so that you can be confident that nothing falls throught the cracks.
4
The Avion Wealth Formula is Wealth Management = Investment Consulting + Advanced
Planning + Relationship Management.
Wealth Management is described in the section on Investment Consulting section above.
Advanced Planning can include strategies and recommendations on minimizing taxes
and maximizing cash flow, wealth transfer (taking care of your heirs), protecting your
assets from legal and financial threats, and maximizing the impact of your charitable
giving.
Relationship Management refers to the Avion team that will work with you to achieve
your financial goals and objectives.
Avion may also refer clients to an accountant, attorney or other specialist, as appropriate
for their unique situation. When appropriate, we will provide a written summary of your
financial situation, observations, and recommendations.
Types of Investments
We primarily offer advice on equity securities, warrants, corporate debt securities,
commercial paper, certificates of deposit, municipal securities, investment company
securities, U.S. Government securities, options contracts on securities, futures contracts
on securities and commodities, and interest in partnerships investing in real estate, oil
and gas interests, and others.
Additionally, we may advise you on any type of investment that we deem appropriate
based on your stated goals and objectives. We may also provide advice on any type of
investment held in your portfolio at the inception of our advisory relationship.
You may request that we refrain from investing in particular securities or certain types of
securities. You must provide these restrictions to our firm in writing.
Assets Under Management
As of December 31, 2025, we manage $983,989,638 in client assets on a discretionary basis
and $561,310 on a non-discretionary basis.
Item 5 Fees and Compensation
Please refer to the "Advisory Business" section in this Brochure for information on our
advisory fees, fee paying arrangements, and refund policy according to each service we
offer.
Additional Fees and Expenses
As part of our investment advisory services to you, we may invest, or recommend that
you invest, in mutual funds and exchange traded funds. The fees that you pay to our firm
for investment advisory services are separate and distinct from the fees and expenses
charged by mutual funds or exchange traded funds (described in each fund's prospectus)
to their shareholders. These fees will generally include a management fee and other fund
expenses. You will also incur transaction charges and/or brokerage fees when
purchasing or selling securities. These charges and fees are typically imposed by the
5
broker-dealer or custodian through whom your account transactions are executed. We
do not share in any portion of the brokerage fees/transaction charges imposed by the
broker-dealer or custodian. To fully understand the total cost you will incur, you should
review all the fees charged by mutual funds, exchange traded funds, our firm, and others.
For information on our brokerage practices, please refer to the "Brokerage Practices"
section of this Disclosure Brochure.
Item 6 Performance-Based Fees and Side-By-Side Management
We do not accept performance-based fees or participate in side-by-side management.
Side-by-side management refers to the practice of managing accounts that are charged
performance-based fees while at the same time managing accounts that are not charged
performance-based fees.
Performance-based fees are fees that are based on a share of capital gains or capital
appreciation of a client's account. Our fees are calculated as described in the Advisory
Business section above, and are not charged on the basis of a share of capital gains upon,
or capital appreciation of, the funds in your advisory account.
Item 7 Types of Clients
We currently offer investment advisory services to individuals (including high net worth
individuals and trust). We will also service charitable organizations, corporations, and
other business entities. In general, we require a minimum of $1,000,000 to open and
maintain an advisory account. At our discretion, we may waive this minimum account
size. For example, we may waive the minimum if you appear to have significant potential
for increasing your assets under our management. We may also combine account values
for you and your minor children, joint accounts with your spouse, and other types of
related accounts to meet the stated minimum.
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Our investment strategies and advice may vary depending upon each client's
specific financial situation. As such, we determine investments and allocations based
upon your predefined objectives, risk tolerance, time horizon, financial horizon, financial
information, liquidity needs, and other various suitability factors. Your restrictions and
guidelines may affect the composition of your portfolio.
Investment Strategies
We may use one or more of the following investment strategies when formulating
investment advice:
• Modern Portfolio Theory (MPT) - Asset Allocation (MPT is utilized extensively).
MPT is a theory of investment which attempts to maximize portfolio expected
return for a given amount of portfolio risk, or equivalently minimize risk for a
given level of expected return, by carefully diversifying the proportions of various
assets. Market risk applies with MPT. Market risk is that part of a security's risk
6
that is common to all securities of the same general class (stocks and bonds) and
thus cannot be eliminated by diversification.
Methods of Analysis
We may use one or more of the following methods of analysis when providing
investment advice to you:
• Long Term Purchases - securities purchased with the expectation that the value of
those securities will grow over a relatively long period of time, generally greater
than one year.
• Short Term Purchases - securities purchased with the expectation that they will be
sold within a relatively short period of time, generally less than one year, to take
advantage of the securities' short term price fluctuations.
• Margin Transactions - a securities transaction in which an investor borrows money
to purchase a security, in which case the security serves as collateral on the loan.
• Options Trading/Writing: a securities transaction that involves buying or selling
(writing) an option. If you write an option, and the buyer exercises the option, you
are obligated to purchase or deliver a specified number of shares at a specified
price at the expiration of the option regardless of the market value of the security
at expiration of the option. Buying an option gives you the right to purchase or sell
a specified number of shares at a specified price until the date of expiration of the
option regardless of the market value of the security at expiration of the option.
Risk of Loss
Investing in securities involves risk of loss that you should be prepared to bear. We do
not represent or guarantee that our services or methods of analysis can or will predict
future results, successfully identify market tops or bottoms, or insulate clients from losses
due to market corrections or declines. We cannot offer any guarantees or promises that
your financial goals and objectives will be met. Past performance is in no way an
indication of future performance.
Recommendation of Particular Types of Securities
Where suitable, we primarily recommend investment in Exchange Traded Funds and
Indexed Mutual Funds; however, we may recommend other types of investments as
appropriate for you since each client has different needs and different tolerance for risk.
Each type of security has its own unique set of risks associated with it and it would not
be possible to list here all of the specific risks of every type of investment. Even within
the same type of investment, risks can vary widely. However, in very general terms, the
higher the anticipated return of an investment, the higher the risk of loss associated with
it.
Mutual funds and exchange traded funds are professionally managed collective
investment systems that pool money from many investors and invest in stocks, bonds,
7
short-term money market instruments, other mutual funds, other securities or any
combination thereof. The fund will have a manager that trades the fund's investments in
accordance with the fund's investment objective. While mutual funds and ETFs generally
provide diversification, risks can be significantly increased if the fund is concentrated in
a particular sector of the market, primarily invests in small cap or speculative companies,
uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular
type of security (i.e., equities) rather than balancing the fund with different types
of securities. Exchange traded funds differ from mutual funds since they can be bought
and sold throughout the day like stock and their price can fluctuate throughout the day.
The returns on mutual funds and ETFs can be reduced by the costs to manage the funds.
Also, while some mutual funds are "no load" and charge no fee to buy into, or sell out of
the fund, other types of mutual funds do charge such fees which can also reduce returns.
Mutual funds can also be "closed end" or "open end". Open-end funds calculate the value
of one share, known as the net asset value (NAV), only once a day, when the investment
markets close. All purchase and sales for the day are recorded at that NAV. To figure its
NAV, a fund adds up the total value of its investment holdings, subtracts the fund's fees
and expenses, and divides that amount by the number of fund shares that investors are
currently holding. NAV isn't necessarily a measure of a fund's success, as stock prices are,
however. Since open-end funds can issue new shares and buy back old ones all the time,
the number of shares and the dollars invested in the fund are constantly changing. That's
why in comparing two funds it makes more sense to look at their total return over time
rather than to compare their NAVs. Closed-end funds differ from open-end funds
because they raise money only once in a single offering, much the way a stock issue raises
money for the company only once, at its initial public offering, or IPO. After the shares are
sold, the closed-end fund uses the money to buy a portfolio of underlying investments, and
any further growth in the size of the fund depends on the return on its investments, not
new investment dollars. The fund is then listed on an exchange, the way an individual
stock is, and shares trade throughout the day.
Item 9 Disciplinary Information
Avion Wealth has been registered and providing investment advisory services since 2005.
Neither our firm nor any of our associated persons has any reportable legal or
disciplinary information.
Item 10 Other Financial Industry Activities and Affiliations
Neither Avion Wealth,, nor its representatives, are registered or have an application
pending to register, as a broker-dealer or a registered representative of a broker-dealer.
Neither Avion Wealth, nor its representatives, are registered or have an application
pending to register, as a futures commission merchant, commodity pool operator, a
commodity trading advisor, or a representative of the foregoing.
Avion Wealth does not have any relationship or arrangement that is material to its
advisory business or to its clients with any related person.
8
Item 11 Code of Ethics and Personal Trading
We strive to comply with applicable laws and regulations governing our practices.
Therefore, our Code of Ethics includes guidelines for professional standards of conduct
for our Associated Persons. Our goal is to protect your interests at all times and to
demonstrate our commitment to our fiduciary duties of honesty, good faith, and fair
dealing with you. All of our Associated Persons are expected to adhere strictly to these
guidelines. Our Code of Ethics also requires that certain persons associated with our firm
submit reports of their personal account holdings and transactions to a qualified
representative of our firm who will review these reports on a periodic basis. Persons
associated with our firm are also required to report any violations of our Code of Ethics.
Additionally, we maintain and enforce written policies reasonably designed to prevent
the misuse or dissemination of material, non-public information about you or your
account holdings by persons associated with our firm.
Our Code of Ethics is available to you upon request. You may obtain a copy of our Code
of Ethics by contacting us at (281) 528-1200 or via email at paul@avionwealth.com
Personal Trading Practices
Our firm or persons associated with our firm may buy or sell the same securities that we
recommend to you or securities in which you are already invested. A conflict of interest
exists in such cases because we have the ability to trade ahead of you and potentially
receive more favorable prices than you will receive. To eliminate this conflict of interest,
it is our policy that neither our Associated Persons nor we shall have priority over your
account in the purchase or sale of securities.
Item 12 Brokerage Practices
The custodians and brokers we use
Avion Wealth does not maintain custody of your assets, although we may be deemed to
have custody of your assets if you give us authority to withdraw assets from your account
(see Item 15 – Custody, below). Your assets must be maintained at a “qualified
custodian,” generally a broker-dealer or bank. We recommend the brokerage and
custodial services of Charles Schwab & Co., Inc. (“Schwab”) or Fidelity Institutional
Wealth Services (“Fidelity”), registered broker-dealer and the Securities Investor
Protection Corporation (“SIPC”). Both are qualified custodians. We are independently
owned and operated and are not affiliated with either Schwab or Fidelity. The qualified
custodian will hold your assets in a brokerage account and buy and sell securities when
we instruct them to. While we recommend that you use a qualified custodian, you will
decide whether to do so and will open your account at Schwab or Fidelity by entering
into an account agreement directly with them. We do not open the account for you,
although we may assist you in doing so. Even though your account is maintained at
Schwab or Fidelity, we can still use other brokers to execute trades for your account as
described below (see “Your brokerage and custody costs”).
9
How we select brokers/custodians
We seek to recommend a custodian 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
For our clients' accounts that Schwab and Fideltiy maintain, they generally do not charge
you separately for custody services but is compensated by charging you commissions or
other fees on trades that it executes or that settle into your account. Certain trades (for
example, many mutual funds and ETFs) may not incur custodial commissions or
transaction fees. Schwab is also compensated by earning interest on the uninvested cash
in your account in Schwab's Cash Features Program. The custodians charge you a flat
dollar amount as a "prime broker" or "trade away" fee for each trade that we have
executed by a different broker-dealer but where the securities bought or the funds from
the securities sold are deposited (settled) into your Schwab or Fidelilty account. These
fees are in addition to the commissions or other compensation you pay the executing
broker-dealer. Because of this, in order to minimize your trading costs, we have the
custodian execute most trades for your account. We have determined that having the
custodian execute most trades is consistent with our duty to seek "best execution" of your
10
trades. Best execution means the most favorable terms for a transaction based on all
relevant factors, including those listed above (see "How we select brokers/custodians").
Products and services available to us from the custodians
Schwab Advisor Services™ is Schwab's business serving independent investment
advisory firms like us. Both Schwab and Fidelity provide us and you with access to their
institutional brokerage services (trading, custody, reporting, and related services), many
of which are not typically available to the custodian’s retail customers. The custodians
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.
The custodian's support services are generally available on an unsolicited basis (we don't
have to request them) and at no charge to us. Following is a more detailed description of
the custodian's support services:
Services that benefit you
The custodian'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 the custodians include some to which we
might not otherwise have access or that would require a significantly higher minimum
initial investment by our clients. The custodian's services described in this paragraph
generally benefit you and your account.
Services that may not directly benefit you
The custodian also makes available to us other products and services that benefit us but
may not directly benefit you or your account. These products and services assist us in
managing and administering our clients' accounts. They include investment research,
both the custodian's own and that of third parties. We may use this research to service all
or a substantial number of our clients' accounts, including accounts not maintained at
either custodian. In addition to investment research, the custodians also makes available
software and other technology that:
• Provide access to client account data (such as duplicate trade confirmations and
account statements)
• Facilitate trade execution and allocate aggregated trade orders for multiple client
accounts
• Provide pricing and other market data
• Facilitate payment of our fees from our clients' accounts
• Assist with back-office functions, recordkeeping, and client reporting
Services that generally benefit only us
The custodians also offers other services intended to help us manage and further develop
our business enterprise. These services include:
11
• Educational conferences and events
• Consulting on technology, compliance, legal, and business needs
• Publications and conferences on practice management and business succession
• Access to employee benefits providers, human capital consultants, and insurance
providers
• Marketing consulting and support
The custodians may provide some of these services itself. In other cases, it will arrange
for third-party vendors to provide the services to us. The custodians may also discount
or waive its fees for some of these services or pay all or a part of a third party's fees. The
custodian may also provide us with other benefits, such as occasional business
entertainment of our personnel.
Our interest in Schwab's services
The availability of these services from Schwab benefits us because we do not have to
produce or purchase them. This creates an incentive to recommend that you maintain
your account with Schwab, based on our interest in receiving Schwab's services that
benefit our business and for which we would otherwise have to pay rather than based on
your interest in receiving the best value in custody services and the most favorable
execution of your 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. Our selection is primarily supported by the scope, quality, and price of
Schwab's services (see "How we select brokers/ custodians") and not Schwab's services
that benefit only us.
We do not receive client referrals from broker-dealers in exchange for cash or other
compensation, such as brokerage services or research.
Directed Brokerage
In limited circumstances, and at our discretion, some clients may instruct our firm to use
one or more particular brokers for the transactions in their accounts. If you choose to
direct our firm to use a particular broker, you should understand that this might prevent
from effectively negotiating brokerage commissions on your behalf. This practice may
also prevent our firm from obtaining favorable net price and execution. Thus, when
directing brokerage business, you should consider whether the commission expenses,
execution, clearance, and settlement capabilities that you will obtain through your broker
are adequately favorable in comparison to those that we would otherwise obtain for you.
Block Trades
We do not combine multiple orders for shares of the same securities purchased for advisory
accounts we manage (the practice of combining multiple orders for shares of the same
securities is commonly referred to as "block trading"). Accordingly, you may pay different
12
prices for the same securities transactions than other clients pay. Furthermore, we may not
be able to buy and sell the same quantities of securities for you and you may pay higher
commissions, fees, and/or transaction costs than other clients.
However, for accounts where we have been instructed by the client to use a particular
broker for transactions, trades will be placed in the these accounts after trades have been
placed via Fidelity or Schwab. This is done on the same day, and for mutual funds this will
not be an issue. However, when ETFs are traded via the directed broker after the trades
have been placed with Fidelity or Schwab, you may pay different prices than other clients
for the same securities transactions. Furthermore, we may not be able to buy and sell the
same quantities of securities for you and you may pay higher commissions, fees, and/or
transaction costs than other clients.
Item 13 Review of Accounts
Paul James Carroll, Chief Executive Officer, or the assigned advisory representative on
the account will review your accounts on a monthly basis. We will conduct an extensive
client account review and meeting at least annually or more frequently if economic,
political, or market conditions dictate or upon your request. We may conduct interim
meetings or account reviews at your request or upon our receipt of information material
to the management of your portfolio.
You will receive statements directly from your account custodian on either a monthly or
quarterly basis. The statements will reflect the position, current pricing, transactions in
each account, including fees paid from your account to our firm. You may also receive
periodic asset allocation reports showing drift and total balance of the account.
Item 14 Client Referrals and Other Compensation
We receive an economic benefit from our custodians in the form of the support products
and services it makes available to us and other independent investment advisors whose
clients maintain their accounts at Schwab and Fidelity.
We compensate individuals and/or firms for client referrals. We will enter into an
agreement with the individual or firm and remit a portion of its advisory fees for referrals.
This arrangement is fully explained to the client when this situation arises. Our client
advisory fees are not affected by the referral fees paid to the individual or firm. All
promoters who refer clients will comply with the requirements of the jurisdiction where
they operate. When applicable, the promoter will be licensed as investment advisor(s) or
notice filed in the applicable jurisdiction.
Item 15 Custody
We directly debit your account(s) for the payment of our advisory fees. This ability to
deduct our advisory fees from your accounts causes our firm to exercise limited custody
over your funds or securities. We do not have physical custody of any of your funds
and/or securities. Your funds and securities will be held with a bank, broker-dealer, or
other independent qualified custodian. You will receive account statements from the
independent qualified custodian(s) holding your funds and securities at least quarterly.
13
The account statements from your custodian(s) will indicate the amount of our advisory
fees deducted from your account(s) each billing period. You should carefully review
account statements for accuracy. If you are not receiving at least quarterly custodial
account statements, please contact us at the number on the cover page of this brochure.
As a result of assisting clients with standing letters of authorization to move funds to
other accounts of a client, the firm has been deemed to have custody. This is reported to
the SEC but the firm believes it meets the conditions for exemption and is not required to
seek a surprise annual audit.
Item 16 Investment Discretion
You may grant our firm discretion over the selection and amount of securities to be
purchased or sold for your account(s) without obtaining your consent or approval prior
to each transaction. Before we can buy or sell securities on your behalf, you must first
sign our discretionary management agreement.
You may specify investment objectives, guidelines, and/or impose certain conditions or
investment parameters for your account(s). For example, you may specify that the
investment in any particular stock or industry should not exceed specified percentages
of the value of the portfolio and/or restrictions or prohibitions of transactions in the
securities of a specific industry or security. Please refer to the "Advisory Business" section
in this Brochure for more information on our discretionary management services.
Item 17 Voting Client Securities
We will not vote proxies on behalf of your advisory accounts. At your request, we may
offer you advice regarding corporate actions and the exercise of your proxy voting rights.
If you own shares of common stock or mutual funds, you are responsible for exercising
your right to vote as a shareholder.
In most cases, you will receive proxy materials directly from the account custodian.
However, in the event we were to receive any written or electronic proxy materials, we
would forward them directly to you by mail, unless you have authorized our firm to
contact you by electronic mail, in which case, we would forward any electronic
solicitation to vote proxies.
Item 18 Financial Information
Our firm does not have any financial conditions or impairments that would prevent us
from meeting our contractual commitments to you. We do not take physical custody of
client funds or securities, or serve as trustee or signatory for client accounts, and we do
not require the prepayment of fees six or more months in advance and in excess of $1,200.
Therefore, we are not required to include a financial statement with this brochure.
In an effort to support companies and industries impacted by the current Covid-19
pandemic, on March 27, 2020, Congress passed the CARES Act. A key component of the
CARES Act is the Paycheck Protection Program (PPP). The PPP was intended to provide
low interest and forgivable loans to businesses and the self-employed to help retain
employees and cover certain expenses. The Small Business Administration, SBA, has so
14
far issued 4.2 million loans to small business owners throughout the US since the rollout
of the program. Our firm applied for a loan to participate in the Paycheck Protection
Program as part of the CARES Act and was granted one on April 20, 2020 in the amount
of $180,000. The company intends to use the loan proceeds for purposes consistent with
the PPP; certain amounts of the loan may be forgiven if they are used for qualifying
expenses as described in the CARES Act.
Your Privacy
We view protecting your private information as a top priority. Pursuant to applicable
privacy requirements, we have instituted policies and procedures to ensure that we keep
your personal information private and secure.
We do not disclose any nonpublic personal information about you to any nonaffiliated
third parties, except as permitted by law. In the course of servicing your account, we may
share some information with our service providers, such as transfer agents, custodians,
broker-dealers, accountants, consultants, and attorneys.
We restrict internal access to nonpublic personal information about you to employees who
need that information in order to provide products or services to you. We maintain physical
and procedural safeguards that comply with regulatory standards to guard your nonpublic
personal information and to ensure our integrity and confidentiality. We will not sell
information about you or your accounts to anyone. We do not share your information unless
it is required to process a transaction, at your request, or required by law.
You will receive a copy of our privacy notice prior to or at the time you sign an advisory
agreement with our firm. Thereafter, we will deliver a copy of the current privacy policy
notice to you on an annual basis. Please contact Paul James Carroll, Principal and Chief
Compliance Officer at (281) 528-1200 or via email at: paul@avionwealth.com, if you have
any questions regarding this policy.
Trade Errors
In the event a trading error occurs in your account, our policy is to restore your account
to the position it should have been in had the trading error not occurred. Depending on
the circumstances, corrective actions may include canceling the trade, adjusting an
allocation, and/or reimbursing the account. If a trade error results in a profit, the
custodian will donate the proceeds to charity.
Class Action Lawsuits
We do not determine if securities held by you are the subject of a class action lawsuit or
whether you are eligible to participate in class action settlements or litigation nor do we
initiate or participate in litigation to recover damages on your behalf for injuries as
a result of actions, misconduct, or negligence by issuers of securities held by you.
15
Paul James Carroll, CFP®
2829 Technology Forest Blvd Suite 300
The Woodlands, TX 77381
Tel.: (281) 528-1200
February 2026
FORM ADV PART 2B
BROCHURE SUPPLEMENT
This brochure supplement provides information about Paul James Carroll that
supplements the Avion Wealth's brochure. You should have received a copy of that
brochure. Please contact Paul Carroll at (281) 528-1200 if you did not receive Avion
Wealth's brochure or if you have any questions about the contents of this supplement.
Additional information about Paul Carroll is available on the SEC's website at
www.adviserinfo.sec.gov. The searchable CRD number for Paul Carroll is 1896590.
16
Item 2 Educational Background and Business Experience
Paul James Carroll, CFP®
Year of Birth: 1962
Formal Education After High School:
• Texas A&M University Masters of Science Finance 1987
• University of Maryland Bachelors of Science Business 1985
Business Background:
• Avion Wealth, LLC fka Efficient Wealth Management, LLC, Managing
Member/Chief Executive Officer/Chief Compliance Officer 11/2003 to Present
• United Airlines Pilot 1997 to 2019
Certifications:
CERTIFIED FINANCIAL PLANNER™ (CFP®), 2006
The CERTIFIED FINANCIAL PLANNERTM, CFP® and federally registered CFP (with
flame design) marks (collectively the "CFP® marks") are professional certification marks
granted in the United States by Certified Financial Planner Board of Standards Inc. ("CFP
Board").
The CFP® certification is a voluntary certification; no federal or state law or regulation
requires financial planners to hold CFP® certification. It is recognized in the United States
and a number of other countries for its (1) high standard of professional education;
(2) stringent code of conduct and standards of practice; and (3) ethical requirements
that govern professional engagements with clients. Currently more than 73,000
individuals have obtained CFP® certification in the United States.
To attain the right to use the CFP® marks an individual must satisfactorily
fulfill the following requirements:
• Education - Complete an advanced college-level course of study addressing the
financial planning subject areas that CFP Board's studies have determined as
necessary for the competent and professional delivery of financial planning
services and attain a Bachelor's Degree from a regionally accredited United States
college or university (or its equivalent from a foreign university). CFP Board's
financial planning subject areas include insurance planning and risk management
employee benefits planning investment planning income tax planning retirement
planning and estate planning;
• Examination - Pass the comprehensive CFP® Certification Examination. The
examination administered in 10 hours over a two-day period includes case studies
and client scenarios designed to test one's ability to correctly diagnose financial
17
planning issues and apply one's knowledge of financial planning to real world
circumstances;
• Experience - Complete at least three years of full-time financial planning-related
experience (or the equivalent measured as 2000 hours per year); and
• Ethics - Agree to be bound by CFP Board's Standards of Professional
Conduct a set of documents outlining the ethical and practice standards for
CFP® professionals.
Individuals who become certified must complete the following ongoing
education and ethics requirements in order to maintain the right to continue to use the
CFP® marks:
• Continuing Education - Complete 30 hours of continuing education hours every
two years including two hours on the Code of Ethics and other parts of the
Standards of Professional Conduct to maintain competence and keep up with
developments in the financial planning field; and
• Ethics - Renew an agreement to be bound by the Standards of Professional
Conduct. The Standards prominently require that CFP® professionals provide
financial planning services at a fiduciary standard of care. This means CFP®
professionals must provide financial planning services in the best interests of their
clients.
Item 3 Disciplinary Information
Mr. Carroll does not have any reportable legal or disciplinary information.
Item 4 Other Business Activities
Mr. Carroll does not have any other business activities.
Item 5 Additional Compensation
Mr. Carroll does not receive any additional compensation or economic benefit from a
non-client for providing investment advisory services beyond what is received as a result
of his employment with Avion Wealth. As part of his employment, Mr. Carroll does
receive overrides for a percentage of client revenue for which he is the servicing advisor.
In addition, he would receive override compensation for any clients he brings to the firm.
Item 6 Supervision
Mr. Carroll is Chief Executive Officer Officer of Avion Wealth; therefore Mr. Carroll's
advisory activities are not supervised by any other individual.
18
Elizabeth A. Brady, CFP®
2829 Technology Forest Blvd, Suite 300
The Woodlands, TX 77381
Tel.: (281) 528-1200
February 2026
FORM ADV PART 2B
BROCHURE SUPPLEMENT
This brochure supplement provides information about Elizabeth A. Brady that
supplements the Avion Wealth's brochure. You should have received a copy of that
brochure. Please contact Paul Carroll at (281) 528-1200 if you did not receive Avion
Wealth's brochure or if you have any questions about the contents of this supplement.
Additional information about Elizabeth Brady is available on the SEC's website at
www.adviserinfo.sec.gov. The searchable CRD number for Elizabeth A. Brady is
6284248.
19
Item 2 Educational Background and Business Experience
Elizabeth A. Brady, CFP®
Year of Birth: 1990
Formal Education After High School:
• Texas A&M University, Bachelor of Arts, Economics, 2012
Business Background:
• Avion Wealth, LLC fka Efficient Wealth Management, LLC, Partner, 04/2016 to
Present
• Avion Wealth, LLC fka Efficient Wealth Management, LLC, Wealth Manager,
10/2013 to Present
• Efficient Wealth Management, LLC, Relationship Manager, 06/2012 to 10/2013
License:
• Series 65 attained in 2013
Certifications:
CERTIFIED FINANCIAL PLANNER™ (CFP®), 2019
The CERTIFIED FINANCIAL PLANNERTM, CFP® and federally registered CFP (with flame
design) marks (collectively the "CFP® marks") are professional certification marks granted
in the United States by Certified Financial Planner Board of Standards Inc. ("CFP Board").
The CFP® certification is a voluntary certification; no federal or state law or regulation
requires financial planners to hold CFP® certification. It is recognized in the United States
and a number of other countries for its (1) high standard of professional education;
(2) stringent code of conduct and standards of practice; and (3) ethical requirements
that govern professional engagements with clients. Currently more than 73,000
individuals have obtained CFP® certification in the United States.
To attain the right to use the CFP® marks an individual must satisfactorily
fulfill the following requirements:
• Education - Complete an advanced college-level course of study addressing the
financial planning subject areas that CFP Board's studies have determined as
necessary for the competent and professional delivery of financial planning
services and attain a Bachelor's Degree from a regionally accredited United States
college or university (or its equivalent from a foreign university). CFP Board's
financial planning subject areas include insurance planning and risk management
employee benefits planning investment planning income tax planning retirement
planning and estate planning;
20
• Examination - Pass the comprehensive CFP® Certification Examination. The
examination administered in 10 hours over a two-day period includes case studies
and client scenarios designed to test one's ability to correctly diagnose financial
planning issues and apply one's knowledge of financial planning to real world
circumstances;
• Experience - Complete at least three years of full-time financial planning-related
experience (or the equivalent measured as 2000 hours per year); and
• Ethics - Agree to be bound by CFP Board's Standards of Professional
Conduct a set of documents outlining the ethical and practice standards for
CFP® professionals.
Individuals who become certified must complete the following ongoing
education and ethics requirements in order to maintain the right to continue to use the
CFP® marks:
• Continuing Education - Complete 30 hours of continuing education hours every
two years including two hours on the Code of Ethics and other parts of the
Standards of Professional Conduct to maintain competence and keep up with
developments in the financial planning field; and
• Ethics - Renew an agreement to be bound by the Standards of Professional
Conduct. The Standards prominently require that CFP® professionals provide
financial planning services at a fiduciary standard of care. This means CFP®
professionals must provide financial planning services in the best interests of their
clients.
Item 3 Disciplinary Information
Elizabeth A. Brady does not have any reportable legal or disciplinary information.
Item 4 Other Business Activities
Elizabeth A. Brady does not have any other business activities.
Item 5 Additional Compensation
Elizabeth A. Brady does not receive any additional compensation or economic benefit
from a non-client for providing investment advisory services beyond what is received as
a result of her employment with Avion Wealth. As part of her employment, Ms. Brady
does receive overrides for a percentage of client revenue for which she is the servicing
advisor. In addition, she would receive override compensation for any clients she brings
to the firm.
Item 6 Supervision
Elizabeth’s advisory activities are supervised by Paul Carroll, Chief Executive Officer.
Mr. Carroll can be reached at (281) 528-1200.
21
Ashley Dominey Stewart, CFP®
2829 Technology Forest Blvd, Suite 300
The Woodlands, TX 77381
Tel.: (281) 528-1200
February 2026
FORM ADV PART 2B
BROCHURE SUPPLEMENT
This brochure supplement provides information about Ashley Dominey Stewart that
supplements the Avion Wealth’s brochure. You should have received a copy of that
brochure. Please contact Paul Carroll at (281) 528-1200 if you did not receive Avion
Wealth’s brochure or if you have any questions about the contents of this supplement.
Additional information about Ashley Stewart is available on the SEC's website at
www.adviserinfo.sec.gov. The searchable CRD number for Ashley Stewart is 5538191.
22
Item 2 Educational Background and Business Experience
Ashley Dominey Stewart, CFP®
Year of Birth: 1986
Formal Education After High School:
• Texas Tech University, Masters of Science, Personal Financial Planning, 2009
• Texas Tech University, Bachelors of Science, Personal Financial Planning, 2008
Business Background:
• Avion Wealth, LLC fka Efficient Wealth Management, LLC, Partner, 07/2018 to
Present
• Avion Wealth, LLC fka Efficient Wealth Management, LLC, Wealth Manager,
01/2014 to Present
• Avion Wealth LLC fka Efficient Wealth Management, LLC, Senior Relationship
Manager, 10/2013 to 01/2014
• Houston Wealth Strategies, Associate Wealth Advisor, 08/2012-09/2013
• Saunders & Associates, LLC, Associate Planner, 04/2011 to 08/2012
• Edward Jones, Summer Intern National Headquarters, Summer 2008
Certifications:
CERTIFIED FINANCIAL PLANNER™ (CFP®), 2013
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with
flame design) marks (collectively, the “CFP® marks”) are professional certification marks
granted in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP
Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation
requires financial planners to hold CFP® certification. It is recognized in the United States
and a number of other countries for its (1) high standard of professional education; (2)
stringent code of conduct and standards of practice; and (3) ethical requirements that
govern professional engagements with clients. Currently, more than 73,000 individuals
have obtained CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the
following requirements:
23
• Education – Complete an advanced college-level course of study addressing the
financial planning subject areas that CFP Board’s studies have determined as
necessary for the competent and professional delivery of financial planning
services, and attain a Bachelor’s Degree from a regionally accredited United States
college or university (or its equivalent from a foreign university). CFP Board’s
financial planning subject areas include insurance planning and risk management,
employee benefits planning, investment planning, income tax planning, retirement
planning, and estate planning;
• Examination – Pass the comprehensive CFP® Certification Examination. The
examination, administered in 10 hours over a two-day period, includes case studies
and client scenarios designed to test one’s ability to correctly diagnose financial
planning issues and apply one’s knowledge of financial planning to real world
circumstances;
• Experience – Complete at least three years of full-time financial planning-related
experience (or the equivalent, measured as 2,000 hours per year); and
• Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set
of documents outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and
ethics requirements in order to maintain the right to continue to use the CFP® marks:
• Continuing Education – Complete 30 hours of continuing education hours every
two years, including two hours on the Code of Ethics and other parts of the Standards
of Professional Conduct, to maintain competence and keep up with developments in
the financial planning field; and
• Ethics – Renew an agreement to be bound by the Standards of Professional Conduct.
The Standards prominently require that CFP® professionals provide financial
planning services at a fiduciary standard of care. This means CFP® professionals
must provide financial planning services in the best interests of their clients.
Item 3 Disciplinary Information
Ashley Dominey Stewart does not have any reportable legal or disciplinary information.
Item 4 Other Business Activities
Ashley Dominey Stewart does not have any other business activities.
Item 5 Additional Compensation
Ashley Dominey Stewart does not receive any additional compensation or economic
benefit from a non-client for providing investment advisory services beyond what is
received as a result of her employment with Avion Wealth. As part of her employment,
24
Ms. Stewart does receive overrides for a percentage of client revenue for which she is the
servicing advisor. In addition, she would receive override compensation for any clients
she brings to the firm.
Item 6 Supervision
Ashley’s advisory activities are supervised by Paul Carroll, Chief Executive Officer. Mr.
Carroll can be reached at (281) 528-1200.
25
Sarah E. McIvor, CFP®
2829 Technology Forest Blvd, Suite 300
The Woodlands, TX 77381
Tel.: (281) 528-1200
February 2026
FORM ADV PART 2B
BROCHURE SUPPLEMENT
This brochure supplement provides information about Sarah E. McIvor that supplements
the Avion Wealth’s brochure. You should have received a copy of that brochure. Please
contact Paul Carroll at (281) 528-1200 if you did not receive Avion Wealth's brochure or
if you have any questions about the contents of this supplement.
Additional information about Sarah E. McIvor is available on the SEC's website at
www.adviserinfo.sec.gov. The searchable CRD number for Sarah E. McIvor is 6438824.
26
Item 2 Educational Background and Business Experience
Sarah E. McIvor, CFP®
Year of Birth: 1989
Formal Education After High School:
• Texas A&M University, CFP® Certification, 2018
• Texas A&M University, Bachelor of Business Administration, Management, 2011
Business Background:
• Avion Wealth, LLC fka Efficient Wealth Management, LLC, Partner, 10/2020 to
Present
• Avion Wealth, LLC fka Efficient Wealth Management, LLC, Wealth Manager,
04/2018 to Present
• Avion Wealth, LLC fka Efficient Wealth Management, LLC, Associate Wealth
Manager, 04/2016 to 08/2018
• Avion Wealth, LLC fka Efficient Wealth Management, LLC, Relationship Manager,
04/2014 to 04/2016
• BBVA Compass, Asst. Branch Manager, 07/2012 to 04/2014
• College Station ISD, Substitute Teacher, 01/2012 to 06/2012
License:
• Series 65 attained in 2014
Certifications:
CERTIFIED FINANCIAL PLANNER™ (CFP®), 2018
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with
flame design) marks (collectively, the “CFP® marks”) are professional certification marks
granted in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP
Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation
requires financial planners to hold CFP® certification. It is recognized in the United States
and a number of other countries for its (1) high standard of professional education; (2)
stringent code of conduct and standards of practice; and (3) ethical requirements that
govern professional engagements with clients. Currently, more than 73,000 individuals
have obtained CFP® certification in the United States.
27
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the
following requirements:
• Education – Complete an advanced college-level course of study addressing the
financial planning subject areas that CFP Board’s studies have determined as
necessary for the competent and professional delivery of financial planning
services, and attain a Bachelor’s Degree from a regionally accredited United States
college or university (or its equivalent from a foreign university). CFP Board’s
financial planning subject areas include insurance planning and risk management,
employee benefits planning, investment planning, income tax planning, retirement
planning, and estate planning;
• Examination – Pass the comprehensive CFP® Certification Examination. The
examination, administered in 10 hours over a two-day period, includes case studies
and client scenarios designed to test one’s ability to correctly diagnose financial
planning issues and apply one’s knowledge of financial planning to real world
circumstances;
• Experience – Complete at least three years of full-time financial planning-related
experience (or the equivalent, measured as 2,000 hours per year); and
• Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set
of documents outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and
ethics requirements in order to maintain the right to continue to use the CFP® marks:
• Continuing Education – Complete 30 hours of continuing education hours every
two years, including two hours on the Code of Ethics and other parts of the Standards
of Professional Conduct, to maintain competence and keep up with developments in
the financial planning field; and
Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The
Standards prominently require that CFP® professionals provide financial planning
services at a fiduciary standard of care. This means CFP® professionals must provide
financial planning services in the best interests of their clients.
Item 3 Disciplinary Information
Sarah E. McIvor does not have any reportable legal or disciplinary information.
Item 4 Other Business Activities
Sarah E. McIvor does not have any other business activities.
Item 5 Additional Compensation
Sarah E. McIvor does not receive any additional compensation or economic benefit from
28
a non-client for providing investment advisory services beyond what is received as a
result of her employment with Avion Wealth. As part of her employment, Ms. McIvor
does receive overrrides for a percentage of client revenue for which she is the servicing
advisor. In addition, she would receive override compensation for any clients she brings
to the firm.
Item 6 Supervision
Sarah’s advisory activities are supervised by Paul Carroll, Chief Executive Officer. Mr.
Carroll can be reached at (281) 528-1200.
29
Megan Beaufays, CFP®
2829 Technology Forest Blvd, Suite 300
The Woodlands, TX 77381
Tel.: (281) 528-1200
February 2026
FORM ADV PART 2B
BROCHURE SUPPLEMENT
information about Megan Beaufays
This brochure supplement provides
that
supplements the Avion Wealth's brochure. You should have received a copy of that
brochure. Please contact Paul Carroll at (281) 528-1200 if you did not receive Avion
Wealth's brochure or if you have any questions about the contents of this supplement.
Additional information about Megan Beaufays is available on the SEC's website at
www.adviserinfo.sec.gov. The searchable CRD number for Megan Beaufays is 6082233.
30
Item 2 Educational Background and Business Experience
Megan Beaufays, CFP®
Year of Birth: 1987
Formal Education After High School:
• Bowling Green State University, Ohio, Bachelor of Arts in Communication, 2009
Business Background:
• Avion Wealth, LLC, Wealth Manager, 11/2023 to Present
• Avion Wealth, LLC, Relationship Manager, 08/2020 to 11/2023
• LPL Financial, Registered Representative, 01/2019 to 04/2020
• PNC Bank, Mortgage Loan Officer, 06/2017 to 01/2019
• PNC Investments, Licensed PCG Relationship Manager, 06/2015 to 06/2017
• JP Morgan Securities fka Chase Investment Services, Licensed Banker, 06/2012 to
06/2015
• JP Morgan Chase Bank, Personal Banker, 06/2011 to 06/2015
License:
• Series 65 attained in 2021
Certifications:
CERTIFIED FINANCIAL PLANNER™ (CFP®), 2023
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with
flame design) marks (collectively, the “CFP® marks”) are professional certification marks
granted in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP
Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation
requires financial planners to hold CFP® certification. It is recognized in the United States
and a number of other countries for its (1) high standard of professional education; (2)
stringent code of conduct and standards of practice; and (3) ethical requirements that
govern professional engagements with clients. Currently, more than 73,000 individuals
have obtained CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the
following requirements:
31
• Education – Complete an advanced college-level course of study addressing the
financial planning subject areas that CFP Board’s studies have determined as
necessary for the competent and professional delivery of financial planning
services, and attain a Bachelor’s Degree from a regionally accredited United States
college or university (or its equivalent from a foreign university). CFP Board’s
financial planning subject areas include insurance planning and risk management,
employee benefits planning, investment planning, income tax planning, retirement
planning, and estate planning;
• Examination – Pass the comprehensive CFP® Certification Examination. The
examination, administered in 10 hours over a two-day period, includes case studies
and client scenarios designed to test one’s ability to correctly diagnose financial
planning issues and apply one’s knowledge of financial planning to real world
circumstances;
• Experience – Complete at least three years of full-time financial planning-related
experience (or the equivalent, measured as 2,000 hours per year); and
• Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set
of documents outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and
ethics requirements in order to maintain the right to continue to use the CFP® marks:
• Continuing Education – Complete 30 hours of continuing education hours every
two years, including two hours on the Code of Ethics and other parts of the Standards
of Professional Conduct, to maintain competence and keep up with developments in
the financial planning field; and
Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The
Standards prominently require that CFP® professionals provide financial planning
services at a fiduciary standard of care. This means CFP® professionals must provide
financial planning services in the best interests of their clients.
Item 3 Disciplinary Information
Megan Beaufays does not have any reportable legal or disciplinary information.
Item 4 Other Business Activities
Megan Beaufays does not have any other business activities.
Item 5 Additional Compensation
Megan Beaufays does not receive any additional compensation or economic benefit from
a non-client for providing investment advisory services beyond what is received as a
result of her employment with Avion Wealth. As part of her employment, Ms. Beaufays
does receive overrides for a percentage of client revenue for which she is the servicing
32
advisor. In addition, she would receive override compensation for any clients she brings
to the firm.
Item 6 Supervision
Megan’s advisory activities are supervised by Paul Carroll, Chief Executive Officer. Mr.
Carroll can be reached at (281) 528-1200.
33
Christopher J. McBee, CFP®
2829 Technology Forest Blvd, Suite 300
The Woodlands, TX 77381
Tel.: (281) 528-1200
February 2026
FORM ADV PART 2B
BROCHURE SUPPLEMENT
This brochure supplement provides information about Christopher McBee that
supplements the Avion Wealth's brochure. You should have received a copy of that
brochure. Please contact Paul Carroll at (281) 528-1200 if you did not receive Avion
Wealth's brochure or if you have any questions about the contents of this supplement.
Additional information about Christopher McBee is available on the SEC's website at
www.adviserinfo.sec.gov. The searchable CRD number for Christopher McBee is
5651350.
34
Item 2 Educational Background and Business Experience
Christopher McBee
Year of Birth: 1987
Formal Education After High School:
• Texas A&M University, Bachelor of Business Administration in Finance, 2009
Business Background:
• Avion Wealth, LLC, Relationship Manager, 02/2023 to Present
• Foreside Fund Services, LLC, Registered Representative, 08/2019 to 01/2023
• Yorktown Management & Research Co., Regional Sales Associate, 07/2019 to
01/2023
• Invesco Advisers, Inc., Internal Sales Consultant, 08/2014 to 06/2019
• IMG Financial Group, Financial Advisor, 03/2009 to 08/2014
• Minnesota Life Insurance Co., Agent, 03/2009 to 08/2014
• Securian Financial Services Inc., Registered Representative, 03/2009 to 08/2014
License:
• Series 7 and Series 66 attained in 2009
• SIE – Securities Industry Essentials Examiniation attained in 2018
Certifications:
CERTIFIED FINANCIAL PLANNER™ (CFP®), 2024
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with
flame design) marks (collectively, the “CFP® marks”) are professional certification marks
granted in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP
Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation
requires financial planners to hold CFP® certification. It is recognized in the United States
and a number of other countries for its (1) high standard of professional education; (2)
stringent code of conduct and standards of practice; and (3) ethical requirements that
govern professional engagements with clients. Currently, more than 73,000 individuals
have obtained CFP® certification in the United States.
35
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the
following requirements:
• Education – Complete an advanced college-level course of study addressing the
financial planning subject areas that CFP Board’s studies have determined as
necessary for the competent and professional delivery of financial planning
services, and attain a Bachelor’s Degree from a regionally accredited United States
college or university (or its equivalent from a foreign university). CFP Board’s
financial planning subject areas include insurance planning and risk management,
employee benefits planning, investment planning, income tax planning, retirement
planning, and estate planning;
• Examination – Pass the comprehensive CFP® Certification Examination. The
examination, administered in 10 hours over a two-day period, includes case studies
and client scenarios designed to test one’s ability to correctly diagnose financial
planning issues and apply one’s knowledge of financial planning to real world
circumstances;
• Experience – Complete at least three years of full-time financial planning-related
experience (or the equivalent, measured as 2,000 hours per year); and
• Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set
of documents outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and
ethics requirements in order to maintain the right to continue to use the CFP® marks:
• Continuing Education – Complete 30 hours of continuing education hours every
two years, including two hours on the Code of Ethics and other parts of the Standards
of Professional Conduct, to maintain competence and keep up with developments in
the financial planning field; and
Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The
Standards prominently require that CFP® professionals provide financial planning
services at a fiduciary standard of care. This means CFP® professionals must provide
financial planning services in the best interests of their clients.
Item 3 Disciplinary Information
Christopher McBee does not have any reportable legal or disciplinary information.
Item 4 Other Business Activities
Christopher McBee does not have any other business activities.
36
Item 5 Additional Compensation
Christopher McBee does not receive any additional compensation or economic benefit
from a non-client for providing investment advisory services beyond what is received as
a result of his employment with Avion Wealth. As part of his employment, Mr. McBee
does receive overrides for a percentage of client revenue for which he is the servicing
advisor. In addition, he would receive override compensation for any clients he brings to
the firm.
Item 6 Supervision
Chris’s advisory activities are supervised by Paul Carroll, Chief Executive Officer. Mr.
Carroll can be reached at (281) 528-1200.
37
Ryan D. Hague
2829 Technology Forest Blvd, Suite 300
The Woodlands, TX 77381
Tel.: (281) 528-1200
February 2026
FORM ADV PART 2B
BROCHURE SUPPLEMENT
This brochure supplement provides information about Ryan Hague that supplements the
Avion Wealth's brochure. You should have received a copy of that brochure. Please
contact Paul Carroll at (281) 528-1200 if you did not receive Avion Wealth's brochure or
if you have any questions about the contents of this supplement.
Additional information about Ryan Hague is available on the SEC's website at
www.adviserinfo.sec.gov. The searchable CRD number for Ryan Hague is 8074427.
38
Item 2 Educational Background and Business Experience
Ryan Hague
Year of Birth: 2001
Formal Education After High School:
• Grand Canyon University, Bachelor of Business Science in Finance and Economics,
2023
Business Background:
• Avion Wealth, LLC, Relationship Manager, 05/2025 to Present
• Safeguard Investment Advisory Group, Client Service Specialist, 01/2025 to
04/2025
• Lockton Companies, Account Associate, 01/2024 to 01/2025
• TFO Family Office Partners, Wealth Associate Intern, 06/2023 to 12/2023
License:
• Series 65 attained in 2024
Item 3 Disciplinary Information
Ryan Hague does not have any reportable legal or disciplinary information.
Item 4 Other Business Activities
Ryan Hague does not have any other business activities.
Item 5 Additional Compensation
Ryan Hague does not receive any additional compensation or economic benefit from a
non-client for providing investment advisory services beyond what is received as a result
of his employment with Avion Wealth. As part of his employment, Mr. Hague does
receive overrides for a percentage of client revenue for which he is the servicing advisor.
In addition, he would receive override compensation for any clients he brings to the firm.
Item 6 Supervision
Chris’s advisory activities are supervised by Paul Carroll, Chief Executive Officer. Mr.
Carroll can be reached at (281) 528-1200.
39
Ashely Owens
2829 Technology Forest Blvd, Suite 300
The Woodlands, TX 77381
Tel.: (281) 528-1200
February 2026
FORM ADV PART 2B
BROCHURE SUPPLEMENT
This brochure supplement provides information about Ashley Owens that supplements
the Avion Wealth's brochure. You should have received a copy of that brochure. Please
contact Paul Carroll at (281) 528-1200 if you did not receive Avion Wealth's brochure or
if you have any questions about the contents of this supplement.
Additional information about Ashley Owens is available on the SEC's website at
www.adviserinfo.sec.gov. The searchable CRD number for Ashley Owens is 7726721.
40
Item 2 Educational Background and Business Experience
Ashley Owens
Year of Birth: 1996
Formal Education After High School:
• Arizona State University, Bachelor of Science in Economics, 2021
• College for Financial Planning – 2026 - present
Business Background:
• Avion Wealth, LLC, Retirement Manager, 09/2025 to Present
• Providen Wealth Advisors, LLC, Paraplanner, 01/2025 to 09/2025
• Osaic Wealth, Inc., Registered Assistant, 07/2024 to 12/2024
• Schroeder Wealth Advisors, Financial Data Analyst, 04/2023 to 12/2024
License:
• Series 66 - Passed 2024
• Series 7 – Passed 2024
• Life & Health Insurance – Passed 2025
Item 3 Disciplinary Information
Ashley Owens does not have any reportable legal or disciplinary information.
Item 4 Other Business Activities
Ashley Owens does not have any other business activities.
Item 5 Additional Compensation
Ashley Owens does not receive any additional compensation or economic benefit from a
non-client for providing investment advisory services beyond what is received as a result
of her employment with Avion Wealth. As part of her employment, Ms. Owens does
receive overrides for a percentage of client revenue for which she is the servicing advisor.
In addition, she would receive override compensation for any clients she brings to the
firm.
Item 6 Supervision
Ashley’s advisory activities are supervised by Paul Carroll, Chief Executive Officer. Mr.
Carroll can be reached at (281) 528-1200.
41
CODE OF ETHICS
Avion Wealth
Preamble
Our clients’ interests always come first. Our experience shows that if we serve our clients
well, our own success will follow. Our assets are our people, capital and reputation. If
any of these is ever diminished, the last is the most difficult to restore.
Introduction
This is the Code of Ethics (the "Code") of Avion Wealth (the "Company"). The
Company’s Policies on Insider Trading and Personal Securities Transactions are included
in the Code.
General Principles
The Company is a fiduciary for its investment advisory clients. Because of this fiduciary
relationship, it is generally improper for the Company or its Associated Persons to: use
for their own benefit (or the benefit of anyone other than the client), to the detriment
of the client, information about the Company’s trading or recommendations for client
accounts; or take advantage of investment opportunities that would otherwise be
available for the Company’s clients.
Also, as a matter of business policy, the Company wants to avoid even the
appearance that the Company, its Associated Persons, or others receive any improper
benefit from information about client trading or accounts or from our relationships with
our clients or with the brokerage community.
The Company expects all Associated Persons to comply with the spirit of the Code, as
well as the specific rules contained in the Code.
The Company treats violations of this Code (including violations of the spirit of the Code)
very seriously. Violation of either the letter or the spirit of this Code, may result in the
Company taking disciplinary measures, including, without limitation, imposing
penalties or fines, reduction of compensation, demotion, requiring unwinding of the
trade, requiring disgorgement of trading gains, suspending or terminating of
employment, or any combination of the foregoing.
Improper trading activity can constitute a violation of this Code. Nevertheless, the
Code can be violated by failing to file required reports, or by making inaccurate
or misleading reports or statements concerning trading activity or securities
accounts. Individual conduct can violate this Code even if no clients are harmed by
such conduct.
This is an abbreviated version of the Avion Wealth Code of Ethics. The full version is
available upon request. Please contact us at:
42
Avion Wealth
2829 Technology Forest Blvd Suite 300
The Woodlands, TX 77381
Phone: 281 528-1200
Fax: 888 868-1168
Email: Paul@AvionWealth.com
43
Customer Information Privacy Principles
Like most industries today, the financial services industry is rapidly being shaped by
technology, which is literally changing the way we do business. To be successful in this
environment, we must continue to insure that our customers are confident that we will
manage their financial affairs expertly and confidentially.
At Avion Wealth, our customers have access to a broad range of products and services.
To deliver these products and services as effectively and conveniently as possible, it is
essential that we use technology to manage and maintain certain customer information.
We want to assure all of our customers that whenever information is used, it is done
with discretion. The safeguarding of customer information is an issue we take
seriously at Avion Wealth. To affirm our continuing commitment to the proper use
of customer information, we have set forth the following Privacy Principles. It is these
Privacy Principles that guide us in serving the privacy needs of our customers.
1. Recognition of a Customer’s Expectation of Privacy: At Avion Wealth, we
believe the confidentiality and protection of customer information is one of our
fundamental responsibilities. And while information is critical to providing
quality service, we recognize that one of our most important assets is our
customers’ trust. Thus, the safekeeping of customer information is a priority for
Avion Wealth.
2. Use, Collection, and Retention of Customer Information: Avion Wealth limits
the use, collection, and retention of customer information to what we believe is
necessary or useful to conduct our business, provide quality service, and offer
products, services, and other opportunities that may be of interest to our
customers. Information collected may include, but is not limited to: name, address,
telephone number, tax identification number, date of birth, employment status,
annual income and net worth.
3. Maintenance of Accurate Information: Avion Wealth recognizes that it must
maintain accurate customer records. Therefore, Avion Wealth has established
procedures to maintain the accuracy of customer information and to keep such
information current and complete. These procedures include responding to
requests to correct inaccurate information in a timely manner.
44
4. Limiting Employee Access to Information: At Avion Wealth, employee access to
personally identifiable customer information is limited to those with a business
reason to know such information. Employees are educated on the importance of
maintaining the confidentiality of customer information and on these Privacy
Principles. Because of the importance of these issues, all Avion Wealth employees
are responsible for maintaining the confidentiality of customer information and
employees who violate these Privacy Principles will be subject to disciplinary
measures.
5. Protection of Information via Established Security Procedures: Avion Wealth
recognizes that a fundamental element of maintaining effective customer privacy
procedures is to provide reasonable protection against the unauthorized access to
customer information. Therefore, Avion Wealth has established appropriate
security standards and procedures to guard against any unauthorized access to
customer information.
6. Restrictions on the Disclosure of Customer Information: Avion Wealth does not
disclose any nonpublic personal information about its customers or former
customers to any nonaffiliated third parties. In the course of servicing a client’s
account, Avion Wealth may share some information with its service providers,
such as transfer agents, custodians, broker/dealers, accountants and lawyers; in
the normal course of our business (for example, with consumer reporting agencies
and government agencies); when legally required or permitted in connection with
fraud investigations and litigation; in connection with acquisitions and sales; and
at the request or with the permission of a customer.
It is Avion Wealth’s policy never to sell information about current or former customers or
their accounts to anyone. It is also Avion Wealth’s policy not to share information unless
required to process a transaction, at the request of a customer, or as required by law.
7. Maintaining Customer Privacy in Business Relationships with Third Parties: If
we provide personally identifiable customer information to a third party with
which we have a business relationship, we will insist that the third party keep such
information confidential, consistent with the conduct of our business relationship.
8. Disclosure of Privacy Principles to Customers: Avion Wealth recognizes and
respects the privacy expectations of our customers. We want our customers to
understand our commitment to privacy in our use of customer information. As a
result of our commitment, we have developed these Privacy Principles which are
made readily available to our customers. Customers who have questions about
these Privacy Principles or have a question about the privacy of their customer
information should call Paul J. Carroll at 281-528-1200 or e-mail him at
paul@avionwealth.com.
These Privacy Principles apply to individuals, and we reserve the right to change these
Privacy Principles, and any of the policies or procedures described above, at any time
45
without prior notice. These Privacy Principles are for general guidance and do not
constitute a contract or create legal rights and do not modify or amend any agreements
we have with our customers.
Paul J. Carroll, Principal
Avion Wealth
46
BUSINESS CONTINUITY PLAN SUMMARY STATEMENT
Avion Wealth has developed and implemented a Business Continuity Plan (“BCP”) that
includes redundant data centers and alternate facilities to protect its business processes
and technology environment in the event of a significant business disruption. Avion
Wealth’s policy is to respond to a significant business disruption (SBD) in an effort to
safeguard employees’ lives and firm property, make a financial and operational
assessment, quickly recover and resume operations, protect the firm’s books and records,
and allow our customers to transact business.
The plan addresses business disruptions that may be caused by a local incident or by a
regional or market related disaster that applies to many companies. The Plan covers our
critical business processes and related employees essential for Avion Wealth to continue
to conduct business for an interim or temporary period during a business interruption.
Every important aspect of Avion Wealth’s securities business, including data back-up
and recovery; all mission critical systems; financial and operational assessments;
alternative communications with customers, employees, and regulators; alternate
physical location of employees; critical supplier, contractor, bank and counter-party
impact; regulatory reporting; and assuring our customers prompt access to their funds
and securities if we are unable to continue our business is addressed in this plan.
Avion Wealth’s goal is to recover its Critical Business Processes with minimal
interruption, depending on the nature of the disruption. In a disruption to only our firm
or a building housing our firm, we will transfer our operations to a local site when needed
and expect to recover and resume business relatively quickly. In a disruption affecting
our business district, city, or region, we will transfer our operations to a site outside of
the affected area, and presume to recover and resume business within a short period of
time. If the significant business disruption is so severe that it prevents us from remaining
in business, we will assure our customer’s prompt access to their funds and securities.
If after a significant business disruption you cannot contact us as you usually do at (281)
528-1200, or you may go to our website for contact instructions: www.AvionWealth.com.
If you cannot access us through either of those means, you can directly contact the
custodian of your account:
Charles Schwab & Co., Inc.
800-435-4000
www.schwab.com
Fidelity Institutional Wealth Services
800-343-3548
www.fidelity.com
47
They can provide instructions on how they may provide prompt access to your funds
and securities including accepting buy and sell orders and issuing checks and wires from
your account. If your account is held at a mutual fund or insurance company, you should
contact the company directly for access to your securities.
Please be advised that our business continuity plan is subject to change and modification.
Our firm will update this plan whenever we have a material change to our operations,
structure, business, or location or to our custodians. In addition, our firm will review our
plan annually to modify it for any changes. If the plan is modified, we will promptly post
the revised summary on our Website. If you have questions about our business continuity
planning or would like a written copy of the summary of our BCP, you can contact us at:
Avion Wealth
2829 Technology Forest Blvd Suite 300
The Woodlands, TX 77381
Email: Paul@AvionWealth.com
48