Overview
- Headquarters
- Miami, FL
- Average Client Assets
- $2.5 million
- SEC CRD Number
- 323979
Fee Structure
Primary Fee Schedule (BICE WEALTH MGMT - ADV PT 2A AND PRIVACY POLICY)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.75% |
| $1,000,001 | $3,000,000 | 1.50% |
| $3,000,001 | $5,000,000 | 1.25% |
| $5,000,001 | $10,000,000 | 1.00% |
| $10,000,001 | and above | 0.75% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $17,500 | 1.75% |
| $5 million | $72,500 | 1.45% |
| $10 million | $122,500 | 1.22% |
| $50 million | $422,500 | 0.84% |
| $100 million | $797,500 | 0.80% |
Clients
- HNW Share of Firm Assets
- 100.00%
- Total Client Accounts
- 65
- Non-Discretionary Accounts
- 65
Services Offered
Services: Portfolio Management for Individuals
Regulatory Filings
Primary Brochure: BICE WEALTH MGMT - ADV PT 2A AND PRIVACY POLICY (2026-03-30)
View Document Text
Bice Wealth Management LLC
Form ADV Part 2A Disclosure Brochure
& Privacy Policy
March 30, 2026
This Form ADV2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Bice
Wealth Management LLC (“BWM”, “Firm” or the “Adviser”). If you have any questions about the contents of this Disclosure
Brochure, please contact us at 786-266-4597 or by email contact@bicewm.com
BWM is an investment adviser registered with the U.S. Securities and Exchange Commission (“SEC”) that conducts
business nationally and internationally. The information in this Disclosure Brochure has not been approved or verified by
the SEC. Registration with the SEC does not imply a certain level of skill or training. This Disclosure Brochure provides
information about BWM to assist you in determining whether to retain the Adviser.
Additional information about BWM and its advisory persons are available on the SEC’s website at www.adviserinfo.sec.gov
by searching for our firm name or by our CRD number 323979.
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Form ADV Part 2A Disclosure Brochure | Page 1 of 18
Item 2. MATERIAL CHANGES
Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure
Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an
Adviser’s business practices and conflicts of interest. The Brochure Supplement provides information
about advisory personnel of BWM.
BWM believes that communication and transparency are the foundation of our relationship and
continually strive to provide our investment adviser clients (collectively "Clients") with the complete and
accurate information at all times. We encourage all current and prospective Clients to read this
Disclosure Brochure and discuss any questions you may have with us. And of course, we always
welcome your feedback.
Material Changes
No material changes have been made since the previous Disclosure Brochure.
Future Changes
From time to time, we may amend this Disclosure Brochure to reflect changes in our business practices,
changes in regulations and routine annual updates as required by the securities regulators. This
complete Disclosure Brochure or a Summary of Material Changes shall be provided to each Client
annually and if a material change occurs in the business practices.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov.
To review the firm information for BWM:
• Click Investment Adviser Search in the left navigation menu.
• Select Firm and enter 323979 (our firm’s CRD number).
• This will provide access to Form ADV Part 1 and Part 2.
You may also obtain a copy of this Disclosure Brochure at any time, without charge, or by contacting
us at 786-266-4597 or by email at contact@bicewm.com
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Form ADV Part 2A Disclosure Brochure | Page 2 of 18
Item 3. Table of Contents
ADV PART 2A – Disclosure Brochure
1. Cover Page
2. Material Changes
3. Table of Contents
4. Advisory Services
5. Fees and Compensation
6. Performance-Based Fees and Side-By-Side Management
7. Types of Clients
8. Methods of Analysis, Investment Strategies and Risk of Loss
9. Disciplinary Information
10. Other Financial Industry Activities and Affiliations
11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
12. Brokerage Practices
13. Review of Accounts
14. Client Referrals and Other Compensation
15. Custody
16. Investment Discretion
17. Voting Client Securities
18. Financial Information
Privacy Policy
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Item 4. ADVISORY SERVICES
A.
Firm Information
Bice Wealth Management LLC (“BWM”, “Firm” or the “Adviser”) is an investment adviser registered
with the U.S. Securities and Exchange Commission that conducts business both nationally and
internationally. BWM is organized as a limited liability company (“LLC”) under the laws of the State of
Florida. BWM was founded in September 2022, and is owned by Bice US Inc and operated by Felipe
Laborde (CIO of BWM).
This Disclosure Brochure provides information regarding the qualifications, business practices, and the
advisory services provided by BWM.
B. Advisory Services Offered
BWM's primary business is to provide fee-based investment advisory services to investment adviser
Clients (collectively "Clients"). The Adviser will have continuous personal contact and interaction with
each Client to align the investment strategy according to their investment objectives, risk tolerance, and
personal needs. In the case of institutional investors, the Adviser will analyze and execute the
investment strategy in accordance to the client’s mandate or mutually agreed parameters, in order to
achieve the predetermined financial objectives.
Wrap Fee Programs
BWM does not sponsor or act as a portfolio manager for a wrap fee program.
Investment Management Services
BWM provides customized investment advisory solutions for its Clients. This is achieved through
continuous personal Client contact and interaction while providing discretionary & non-discretionary
investment management, and financial consulting services.
BWM determines a Client’s investment needs by conducting a review of the Client’s risk tolerance,
financial situation and stated investment objectives (i.e. preservation of capital, income, growth &
income, growth and speculation) and investment goals. BWM will then construct an investment solution.
The Adviser may also utilize individual stocks, bonds, private placements, mutual funds, ETFs,
alternative funds (such as, but not limited to, private capital funds and hedge funds), structured
products, listed options and cash instruments to meet the needs of its Clients. Investments may be
held in any currency.
BWM will meet with Clients at least annually or upon a Client’s request to discuss their investment
portfolio and to update the Clients’ financial information, as applicable. It is necessary for Clients to
inform BWM promptly with respect to any changes in their financial situation, investment goals and
objectives. Failure to notify BWM of any such changes could result in investment recommendations not
meeting the Clients’ needs.
BWM's investment strategy is primarily long-term focused, but the Adviser may buy, sell or re-allocate
positions that have been held less than one year to meet the objectives of the Client or due to market
conditions. BWM will construct, implement and monitor the portfolio to ensure it meets the goals,
objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the
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opportunity to place reasonable restrictions on the types of investments to be held in their respective
portfolio, subject to the acceptance by the Adviser.
BWM evaluates and selects securities for inclusion in Client portfolios only after applying their internal
due diligence process. BWM may recommend, on occasion, redistributing investment allocations to
diversify the portfolio. BWM may recommend specific positions to increase sector or asset class
weightings. BWM may recommend selling positions for reasons that include, but are not limited to,
harvesting capital gains or losses, business or sector risk exposure to a specific security or class of
securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of
Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk
tolerance.
BWM will provide investment advisory services and portfolio management services and will not provide
securities custodial or other administrative services. At no time will BWM accept or maintain custody of
a Client’s funds or securities, except for the authorized deduction of the Adviser’s fees. All Client assets
will be managed within their designated brokerage account or pension account, pursuant to the Client
investment advisory agreement.
Consulting Services
BWM provides consulting services to individuals pursuant to a consulting agreement. Services are
customized to the needs of each Client, depending on their goals and objectives, and may encompass
one or more areas of need, including, but not limited to financial consulting, business planning, and
other areas of a Client’s financial situation.
A financial consultation rendered to the Client will usually include general recommendations for a
course of activity or specific actions to be taken by the Client. For example, recommendations may be
made that the Client start or revise their investment programs, commence or alter retirement savings,
establish education savings and/or charitable giving programs. BWM may also refer Clients to an
accountant, attorney or another specialist, as appropriate for their unique situation. For consulting
engagements, the Adviser may not provide a written summary. Consultations are typically completed
within six months of contract date, assuming all information and documents requested are provided
promptly.
Consulting recommendations pose a conflict between the interests of the Adviser and the interests of
the Client. Clients are not obligated to implement any recommendations made by the Adviser or
maintain an ongoing relationship with the Adviser. If the Client elects to act on any of the
recommendations made by the Adviser, the Client is under no obligation to implement the transaction
through the Adviser. For example, the Adviser has an incentive to recommend that Clients engage the
Adviser for investment management services or to increase the level of investment assets with the
Adviser, as it would increase the amount of advisory fees paid to the Adviser.
C. Client Account Management
Prior to engaging BWM to provide investment advisory services, each Client is required to enter into
one or more agreements with the Adviser that define the terms, conditions, authority and responsibilities
of the Adviser and the Client. These services may include:
• Establishing an Investment Strategy: BWM, in connection with the Client, will develop an
investment strategy targeted to achieve the Client’s investment goals and objectives. BWM does
not provide legal, tax or accounting advice. Clients should obtain their own independent tax
advise based on their particular circumstances.
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• Asset Allocation: BWM will develop a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation, unique constraints and tolerance for risk
for each Client.
• Portfolio Construction: BWM will develop a portfolio for the Client that is intended to meet the
•
stated goals and objectives of the Client.
Investment Management and Supervision – BWM will provide investment management and
ongoing oversight of the Client’s portfolio.
D. Assets Under Management
BWM has the following assets under management as of 12/31/2026:
Discretionary Accounts
Non-Discretionary Accounts
$ 0
$ 164,479,827
Item 5. Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided
by the Adviser. Each Client shall sign one or more agreements that detail the responsibilities of BWM
and the Client.
A. Fees for Advisory Services
Investment Management Services
Investment advisory fees are paid quarterly, in advance or arrears of each calendar quarter, pursuant
to the terms of the investment advisory agreement. Investment advisory fees are based on the market
value of assets under management at the end of the quarter.
Investment advisory fees are based off the annual rate ranging from 0.75% to 1.75%. Clients with more
than $5,000,000 in assets under management may have fees that are negotiable at the sole discretion
of the Adviser.
Investment Advisory Fee Schedule
Assets Under Management
Up to $1,000,000
$1,000,001 to $3,000,000
$3,000,001 to $5,000,000
$5,000,001 to $10,000,000
$10,000,000 and greater
BWM Base Fee
1.75%
1.50%
1.25%
1.00%
0.75%
The investment advisory fee in the first quarter of service is prorated to the inception date of the
account(s) to the end of the first quarter. Fees may be negotiable at the sole discretion of the Adviser.
The Client’s fees will take into consideration the aggregate assets under management with Adviser.
The designated Custodian will independently value all securities held in accounts managed by BWM.
BWM will not have the authority or responsibility to value portfolio securities.
In addition, the Adviser will provide the Client a report itemizing the fee, including the calculation period
covered by the fee, the account value and the methodology used to calculate the fee. It is the
responsibility of the Client to verify the accuracy of these fees as listed on the custodian’s brokerage
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statement as the Custodian does not assume this responsibility. Clients provide written authorization
permitting BWM to be paid directly from their accounts held by the Custodian as part of the investment
advisory agreement and separate account forms provided by the Custodian.
Consulting Services
BWM offers consulting services on an hourly basis ranging up to $500 per hour or on a fixed fee basis.
Fixed fee relationships are based on the number of hours to complete an engagement at the negotiated
hourly rate. An estimate for total hours and/or will be provided to the Client to enable them to determine
prior to establishing the advisory relationship. Consulting fees may be negotiable depending on the
nature and complexity of each Client’s circumstance
B. Fee Billing
Investment Management Services
Investment advisory fees will be calculated by the Adviser or its delegate and deducted from the Client’s
account[s] at the Custodian. The billing method will be determined by the investment advisory
agreement executed by the Client. When fees are deducted from the Custodian, the Adviser (or its
delegate) shall provide the Custodian with the amount of the fees to be deducted from the Client’s
account[s] for the respective period end date. The amount due is calculated by applying the monthly or
quarterly rate to the total assets under management with BWM at the respective period end. Clients
will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the
investment advisory fee.
In addition, the Adviser will provide the Client a report itemizing the fee, including the calculation period
covered by the fee, the account value and the methodology used to calculate the fee. It is the
responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s brokerage
statement as the Custodian does not assume this responsibility. Clients provide written authorization
permitting BWM to be paid directly from their accounts held by the Custodian as part of the investment
advisory agreement and separate account forms provided by the Custodian.
instructed by you, we will combine
the value of related accounts
Unless otherwise
fee
calculation/payment purposes to assist you in meeting fee breakpoints and therefore potentially
lowering the overall fee. BWM extends this option to accounts residing in the same household and
certain members of the same family. For example, we combine account values for you and your minor
children, joint accounts with your spouse, and other types of related accounts.
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than BWM, in connection with
investment made on behalf of the Client’s account[s]. The Client is responsible for all custodial and
securities execution fees and other brokerage fees charged by the Custodian. The Investment Advisory
Fee charged by BWM is separate and distinct from these custodian and execution fees.
Please refer to Item 12 – Brokerage Practices for additional information on brokerage practices.
D. Advance Payment of Fees and Termination
Investment Management Services
BWM is compensated for its investment management services either in advance of the quarter or at
the end of the quarter after investment advisory services are rendered. Either party may request to
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terminate the investment advisory agreement with BWM, at any time, by providing advance written
notice to the other party. The Client shall be responsible for investment advisory fees up to and including
the effective date of termination. Upon termination, the Adviser will refund any unearned, prepaid
investment advisory fees from the effective date of termination to the end of the quarter. The Client’s
investment advisory agreement with the Adviser is non-transferable without Client’s written approval.
Item 6. Performance-Based Fees and Side-By-Side Management
BWM does not charge performance-based fees for its investment advisory services. The fees charged
by BWM are as described in Item 5 – Fees and Compensation above and are not based upon the
capital appreciation of the funds or securities held by any Client.
BWM does not manage any proprietary investment funds or limited partnerships (for example, a mutual
fund or a hedge fund) and has no financial incentive to recommend any particular investment options
to its Clients.
Item 7. Types of Clients
BWM offers investment advisory services to high net worth individuals, corporations, institutions or
other entities in Florida and other states, though most of BWM's clients are non-U.S. residents with a
concentration of Latin American clients. The relative percentage each type of Client is available on
BWM's Form ADV Part 1. These percentages will change over time. BWM generally does not impose
a minimum account size for establishing a relationship.
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
BWM primarily employs fundamental analysis methods in developing investment strategies for its
Clients. Research and analysis from BWM is derived from numerous sources, including financial media
companies, third party research materials, internet sources, and review of company activities, including
annual reports, prospectuses, press releases and research prepared by others.
As noted above, BWM generally employs a long-term investment strategy for its Clients, as consistent
with their financial goals. BWM will typically hold all or a portion of a security for more than a year, but
may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of
Clients. At times, BWM may also buy and sell positions that are more short-term in nature, depending
on the goals of the Client and/or the fundamentals of the security, sector or asset class.
B. Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value.
Clients should be prepared to bear the potential risk of loss. BWM will assist Clients in determining an
appropriate strategy based on their tolerance for risk and other factors noted above. However, there is
no guarantee that a Client will meet their investment goals.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time
horizon, unique constraints, tolerance for risk and other factors to develop an appropriate strategy for
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managing a Client's account. Client participation in this process, including full and accurate disclosure
of requested information, is essential for the analysis of a Client's account[s]. The Adviser shall rely on
the financial and other information provided by the Client or their designees without the duty or
obligation to validate the accuracy and completeness of the provided information. It is the responsibility
of the Client to inform the Adviser of any changes in financial condition, goals or other factors that may
affect this analysis.
The risks associated with a particular strategy are provided to each Client in advance of investing Client
accounts. The Adviser will work with each Client to determine their tolerance for risk as part of the
portfolio construction process. Following are some of the risks associated with the Adviser’s investment
approach:
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets,
liquidity events, as well as economic, political, or social events in the U.S. and abroad. This risk is linked
to the performance of the overall financial markets.
Infectious Disease Risk
The outbreak of COVID-19, a novel coronavirus disease, has negatively affected economies, markets
and individual companies throughout the world, including those in which separately managed accounts
invest. The effects of this COVID-19 pandemic to public health, and business and market conditions,
including exchange trading suspensions and closures may continue to have a significant negative
impact on the performance of the separately managed accounts, increase separately managed account
volatility, exacerbate pre-existing political, social and economic risks to separately managed accounts,
and negatively impact broad segments of businesses and populations. The Adviser’s operations may
be interrupted as a result, which may contribute to the negative impact on investment performance. In
addition, governments, their regulatory agencies, or self-regulatory organizations may take actions in
response to the pandemic that affect the instruments in which a separately managed, or the issuers of
such instruments, in ways that could have a significant negative impact on such account. The full impact
of the COVID-19 pandemic or other future Epidemics or pandemics, is currently unknown.
Loss of Value
There can be no assurance that a specific investment will achieve its investment objectives and past
performance should not be seen as a guide to future returns. The value of investments and the income
derived may fall as well as rise and investors may not recoup the original amount invested. Investments
may also be affected by any changes in exchange control regulation, tax laws, withholding taxes,
international, political, and economic developments, and government, economic or monetary policies.
Interest Rate Risk
Fixed income securities and funds that invest in bonds and other fixed income securities may fall in
value if interest rates change. Generally, the prices of debt securities rise when interest rates fall, and
their prices fall when interest rates rise. Longer-term debt securities are usually more sensitive to
interest rate changes.
Fixed Income Market Risk
Fixed income securities increase or decrease in value based on changes in interest rates. If rates
increase, the value of fixed income securities generally declines. On the other hand, if rates fall, the
value of the fixed income securities generally increases.
Credit Risk
Investments in bonds and other fixed income securities are subject to the risk that the issuer(s) may
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not make required interest payments. An issuer suffering an adverse change in its financial condition
could lower the credit quality of a security, leading to greater price volatility of the security. A lowering
of the credit rating of a security may also offset the security's liquidity, making it more difficult to sell.
Funds investing in lower quality debt securities are more susceptible to these problems and their value
may be more volatile.
Foreign Exchange Risk
Foreign investments may be affected favorably or unfavorably by exchange control regulations or
changes in the exchange rates. Changes in currency exchange rates may influence the share value,
the dividends or interest earned, and the gains and losses realized. Exchange rates between currencies
are determined by supply and demand in the currency exchange markets, the international balance of
payments, governmental intervention, speculation, and other economic and political conditions. If the
currency in which a security is denominated appreciates against the US Dollar, the value of the security
will increase. Conversely, a decline in the exchange rate of the currency would adversely affect the
value of the security.
Margin Risk
When you purchase securities, you may pay for the securities in full or you may borrow part of the
purchase price from your broker-dealer. If you intend to borrow funds in connection with your account,
you will be required to open a margin account, which will be carried by the broker-dealer of your
account. The securities purchased in such an account are the broker-dealer’s collateral for its loan to
you.
If the securities in a margin account decline in value, the value of the collateral supporting this loan also
declines, and, as a result, a brokerage firm is required to take action, such as issue a margin call and/or
sell securities or other assets in your accounts, in order to maintain necessary level of equity in the
account.
It is important that you fully understand the risks involved in trading securities on margin, which are
applicable to any margin account that you may maintain, including any margin account that may be
established as a part of our Investment Management Services and held by your broker-dealer. These
risks include the following:
• You can lose more funds than you deposit in your margin account.
• The broker-dealer can force the sale of securities or other assets in your account.
• The broker-dealer can sell your securities or other assets without contacting you.
• You may not be able to choose which securities or other assets in your margin account are
liquidated or sold to meet a margin call.
• The broker-dealer may move securities held in your cash account to your margin account
and pledge the transferred securities.
• You may not be entitled to an extension of time on a margin call.
Options Risks
Transactions in options carry a high degree of risk. A relatively small market movement will have a
proportionately larger impact, which may work for or against the investor. The placing of certain orders,
which are intended to limit losses to certain amounts, may not be effective because market conditions
may make it impossible to execute such orders. Selling an option generally entails considerably greater
risk than purchasing options. Although the premium received by the seller is fixed, the seller may
sustain a loss well in excess of that amount. The seller will also be exposed to the risk of the purchaser
exercising the option and the seller will be obliged either to settle the option in cash or to acquire or
deliver the underlying investment. If the option is "covered" by the seller holding a corresponding
position in the underlying investment or a future on another option, the risk may be reduced.
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Equity Risks
Investments in equities generally refers to buying shares of stocks by an individual or firms in return for
receiving a future payment of dividends and capital gains if the value of the stock increases. There is
an innate risk involved when purchasing a stock that it may decrease in value and the investment may
incur a loss.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of
the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition,
ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a
liquidity risk if the ETFs has a large bid-ask spread and low trading volume. The price of an ETF
fluctuates based upon the market movements and may dissociate from the index being tracked by the
ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may
have a different price than the same ETF purchased or sold a short time later.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The
price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds.
The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the
day will typically have the same price as a mutual fund purchased later that same day.
Alternative Investments (Limited Partnerships)
The performance of alternative investments (limited partnerships) can be volatile and may have limited
liquidity. An investor could lose all or a portion of their investment. Such investments often have
concentrated positions and investments that may carry higher risks. Client should only have a portion
of their assets in these investments.
Recommendation of Particular Types of Securities
We recommend various types of securities and we do not necessarily recommend one particular type
of security over another 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 that investment.
Past performance is not a guarantee of future returns. Investing in securities and other
investments involve a risk of loss that each Client should understand and be willing to bear.
Clients are reminded to discuss these risks with the Adviser.
Item 9. Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to a client’s evaluation of the firm or its supervised
persons. BWM has no such events to report.
There are no legal, civil, or disciplinary events involving BWM or Mr. Felipe Laborde that would be
material to a client’s evaluation of our advisory business or the integrity of our management. Neither
BWM nor Mr. Laborde has ever been involved in any regulatory, civil, or criminal proceeding. No
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lawsuits, arbitration claims, or administrative proceedings have ever been filed against BWM or Mr.
Laborde.
BWM values the trust Clients place in the Adviser. We encourage all Clients to review the background
of BWM and our supervised persons through the SEC’s Investment Adviser Public Disclosure (“IAPD”)
system at www.adviserinfo.sec.gov, using our firm’s name or CRD No. 323979.
Item 10. Other Financial Industry Activities and Affiliations
Other Business Activities
Mr. Laborde has
three Outside Business Activities. He serves as Head of Wealth
Management for Banco BICE and BICE Inversiones Corredores de Bolsa S.A., both financial
institutions in Chile. These roles are unrelated to BWM’s advisory services but may create potential
time-and-attention or perceived conflicts because they occur during securities trading hours. Mr.
Laborde does not provide advice to BWM Clients on behalf of these firms, nor does he direct BWM
Client business to them.
Mr. Laborde also owns TCMG Investments LLC, a personal holding company that is not related to the
financial services industry and does not create a conflict of interest.
BWM monitors Outside Business Activities through its compliance program and Code of Ethics to
ensure that all advisory services are provided independently and in the best interest of Clients.
Neither BWM nor its Supervised Persons is registered with or affiliated with a futures commission
merchant, commodity pool operator, or commodity-trading adviser. BWM does not refer Clients to other
investment advisers.
Item 11. Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
A. Code of Ethics
BWM has implemented a Code of Ethics that defines our fiduciary commitment to each Client. This
Code of Ethics applies to all persons associated with BWM (our “Supervised Persons”). The Code of
Ethics was developed to provide general ethical guidelines and specific instructions regarding our
duties to you, our Client. BWM and its Supervised Persons owe a duty of loyalty, fairness and good
faith towards each Client. It is the obligation of BWM associates to adhere not only to the specific
provisions of the Code, but also to the general principles that guide the Code. The Code of Ethics
covers a range of topics that address employee ethics and conflicts of interest. To request a copy of
our Code of Ethics, please contact us at 786-266-4597 or via email at contact@bicewm.com
B. Personal Trading with Material Interest
BWM allows our Supervised Persons to purchase or sell the same securities that may be recommended
to and purchased on behalf of Clients. BWM does not act as principal in any transactions. In addition,
the Adviser does not act as the general partner of a fund, or advise an investment company. BWM
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does not have a material interest in any securities traded in Client accounts.
C. Personal Trading in Same Securities as Clients
BWM allows Supervised Persons to purchase or sell the same securities that may be recommended to
and purchased on behalf of Clients. Owning the same securities that BWM recommends (purchase or
sell) to Clients presents a conflict of interest that, as fiduciaries, BWM must disclose to Clients and
mitigate through policies and procedures. As noted above, the Adviser has adopted a Code, which
addresses insider trading (material non- public information controls) and personal securities reporting
procedures. When trading for personal accounts, Supervised Persons of BWM have a conflict of
interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can
be violated if personal trades are made with more advantageous terms than Client trades, or by trading
based on material non-public information. This risk is mitigated by BWM requiring reporting of personal
securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”). The
Adviser has also adopted written policies and procedures to detect the misuse of material, non- public
information.
D. Personal Trading at Same Time as Client
While BWM allows Supervised Persons to purchase or sell the same securities that may be
recommended to and purchased on behalf of Clients. BWM will place trades only after Client orders
have been placed and filled. At no time, will BWM or any Supervised Person of BWM, transact in
any security to the detriment of any Client.
Item 12. Brokerage Practices
A. Recommendation of Custodian[s]
BWM does not recommend broker-dealers for the custody of securities. This is the client’s choice. The
firm receives no securities commission from any broker-dealer. Your choice may limit the available
options of investment.
Item 13. Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by Mr. Laborde, CIO of
BWM. Formal reviews are generally conducted at least annually or more frequently depending on the
needs of the Client. Reviews may also be conducted when BWM is advised of a change in Clients’
financial circumstances or investment objectives and goals. Supporting documentation of all reviews
and notes are retained in BWM's Review File.
B. Causes for Reviews
In addition to the investment monitoring noted in Item 13.A. above, each Client account shall be
reviewed at least annually. Reviews may be conducted more frequently at the Client’s request.
Accounts may be reviewed as a result of major changes in economic conditions, known changes in the
Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is
encouraged to notify BWM if changes occur in his/her personal financial situation that might adversely
Bice Wealth Management LLC | 1000 Brickell Ave., Suite #500, Miami, FL 33131 | 786-266-4597
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affect his/her investment plan. Additional reviews may be triggered by material market, economic or
political events.
C. Review Reports
The Client will receive brokerage statements no less than quarterly from the Custodian. These
brokerage statements are sent directly from the Custodian to the Client. The Client may also establish
electronic access to the Custodian’s website so that the Client may view these reports and their account
activity. Client brokerage statements will include all positions, transactions and fees relating to the
Client’s account[s]. BWM may provide additional reports to Clients regarding their holdings,
performance and other aspects of their accounts.
Item 14. Client Referrals and Other Compensation
BWM may occasionally utilize the services of “Solicitors” for referrals. Any firm or person performing
formal business development services for BMW as a Solicitor must comply with Investment Advisers
Act requirements and applicable state regulations. The client fee is not affected by this fact, simply a
portion of your fee is given to the solicitor. If you are referred by a Solicitor you will sign an additional
form indicating such fact and specifying the percentage being distributed.
Item 15. Custody
BWM does not accept or maintain custody of any Client accounts, except for the authorized deduction
of investment advisory fees. All Clients must place their assets with a qualified custodian. Clients are
required to select their own custodian to retain their funds and securities and direct BWM to utilize that
custodian for the Client’s security transactions. BWM urges Clients to review and compare statements
provided by the Custodian with reports provided by BWM to ensure accuracy, as the Custodian does
not perform such reviews. For more information about custodians and brokerage practices, see Item
12 - Brokerage Practices.
Item 16.
Investment Discretion
BWM generally has discretion over the selection and amount of securities to be bought or sold in Client
accounts without obtaining prior consent or approval from the Client. However, these purchases or
sales may be subject to specified investment objectives, guidelines, or limitations previously set forth
by the Client and agreed to by BWM.
Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such
authority will be evidenced by the Client's execution of an investment advisory agreement containing
all applicable limitations to such authority. Discretion authority may be limited (for example, limiting the
types of securities that can be purchased, or geographic restrictions may be placed by instructing BWM
not to buy any stock in a certain country/region) by providing us with restrictions and guidelines in
writing. Non-discretionary investment management means that we must obtain your approval prior to
placing any trades in your account. All discretionary trades made by BWM will be in accordance with
each Client's investment objectives and goals.
Item 17. Voting Client Securities
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BWM does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements
directly from the Custodian and are responsible for such instruction to Custodian. BWM does not offer
any advisory or consulting assistance to its Clients regarding proxy matters. Class Actions and other
legal matters communicated to Clients must be addressed directly by each Client with his or her
lawyers. BWM offers no legal advice to Clients.
Item 18. Financial Information
Neither BWM, nor its management have any adverse financial situations that would reasonably impair
the ability of BWM to meet all obligations to its Clients. Neither BWM, nor any of its advisory persons,
has been subject to a bankruptcy or financial compromise. BWM is not required to deliver a balance
sheet along with this Disclosure Brochure as the firm does not collect fees of $500 or more for services
to be performed six months or more in advance.
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Bice Wealth Management LLC
PRIVACY POLICY
March 30, 2026
Our Commitment to You
Bice Wealth Management LLC (“BWM”, “Firm” or the “Adviser”) is committed to safeguarding the use
of your personal information that we have as your Investment Adviser. BWM (also referred to as "we",
"our" and "us" throughout this notice) protects the security and confidentiality of the personal information
we have and implements controls to ensure that such information is used for proper business purposes
in connection with the management or servicing of our relationship with you. Our relationship with you
is our most important asset. We understand that you have entrusted us with your private information,
and we do everything we can to maintain that trust.
BWM does not sell your non-public personal information to anyone. Nor do we provide such information
to others except for discrete and proper business purposes in connection with the servicing and
management of our relationship with you as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used
are set forth in this Privacy Policy.
Why you need to know?
Registered Investment Advisers (“RIAs”) share some of your personal information. Federal and State
laws give you the right to limit some of this sharing. Federal and State laws require RIAs to disclose
how we collect, share, and protect your personal information.
Assets and liabilities
What information do we collect from you?
Social security or taxpayer identification
number
Name, address and phone number[s]
Income and expenses
Investment activity
Investment experience and goals
E-mail address(es)
Account information (including other
institutions)
Account applications and forms
Investment questionnaires and suitability documents
What sources do we collect information from in addition to you?
Custody, brokerage and advisory
agreements
Other advisory agreements and legal
documents
Transactional information with us or others Other information needed to service account
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How we share your information?
RIAs do need to share personal information regarding its clients to effectively implement the RIA’s
services. In the section below, we list some reasons we may share your personal information.
Sharing
Limitations
BWM may share this
Information.
Clients cannot limit the
Adviser’s ability to share.
BWM may share this
information.
Clients cannot limit the
Adviser’s ability to share.
limit
BWM does not share
personal information.
Clients cannot limit the
Adviser’s ability to share.
BWM does not share
personal information.
Clients can limit the Adviser’s
ability to share.
Basis for sharing
Servicing our Clients
We may share non-public personal
information with nonaffiliated third parties
(such as brokers, custodians, regulators,
credit agencies, other financial institutions)
as necessary for us to provide agreed
services to you consistent with applicable
law, including but not limited to:
• Processing transactions;
• General account maintenance;
• Responding to regulators or legal
investigations;
• Credit reporting, etc.
Administrators
We may disclose your non-public personal
information to companies we hire to help
administrate our business. Companies we
hire to provide services of this kind are not
allowed to use your personal information for
their own purposes and are contractually
obligated to maintain strict confidentiality.
their use of your personal
We
information to the performance of the
specific service we have requested.
Marketing Purposes
BWM does not disclose, and does not
intend to disclose, personal information
with non affiliated third parties to offer you
services. Certain laws may give us the right
to share your personal information with
financial
institutions where you are a
customer and where BWM or the client has
a formal agreement with the financial
institution.
We will only share
information for purposes of servicing
for marketing
your accounts, not
purposes.
Authorized Users
In addition, your non-public personal
information may also be disclosed to you
and persons we believe
to be your
authorized agent or representative.
Bice Wealth Management LLC | 1000 Brickell Ave., Suite #500, Miami, FL 33131 | 786-266-4597
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Clients can limit the Adviser’s
ability to share.
BWM does not share
personal information
regarding former
clients
Information About Former Clients
BWM does not disclose, and does not
intend
to disclose, nonpublic personal
information to non-affiliated third parties
with respect to persons who are no longer
our clients.
How do we protect your information?
To safeguard your personal information from unauthorized access and use, we maintain physical,
procedural and electronic safeguards. These include computer safeguards such as passwords,
secured files and buildings.
Our employees are advised about BWM's need to respect the confidentiality of each client’s non-
public personal information. We train our employees on their responsibilities.
We require third parties that assist in providing our services to you to protect the personal information
they receive. This includes contractual language in our third party agreements.
Changes to our Privacy Policy.
We will send you notice of our Privacy Policy annually for as long as you maintain an ongoing
relationship with us.
Periodically we may revise our Privacy Policy, and will provide you with a revised policy if the changes
materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit
the sharing of nonpublic personal information other than as described in this notice unless we first
notify you and provide you with an opportunity to prevent the information sharing.
Questions: You may ask questions or voice any concerns, as well as obtain a copy of our current
Privacy Policy by contacting us at 786-266-4597 or by email at contact@bicewm.com
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